On 28 August 2017, the Staff updated its interpretive guidance relating to revenue recognition for bill-and-hold arrangements through a release as well as a "Staff Accounting Bulletin".

The interpretive release is intended to bring existing guidance into conformity with Financial Accounting Standards Board Accounting Standards Codification Topic 606, Revenue from Contracts with Customers ('ASC Topic 606'). Following adoption of ASC Topic 606, registrants should no longer rely on the guidance in Securities Exchange Act Release No. 23507 and Accounting and Auditing Enforcement Release No. 108, In the Matter of Stewart Parness, which provide the criteria to be met in order to recognise revenue when delivery has not occurred.

Furthermore, the SEC's Office of the Chief Accountant and Division of Corporation Finance released Staff Accounting Bulletin No. 116 (SAB 116), with the purpose of bringing Staff guidance on revenue recognition in conformity with the Financial Accounting Standards Board's adopted and revised ASC Topic 606.

As noted by the Staff, registrants should continue to rely on prior guidance until they adopt ASC Topic 606.

The SEC's interpretive release on bill-and-hold guidance is available at: https://www.sec.gov/rules/interp/2017/33-10402.pdf

SEC Staff Accounting Bulletin No. 116 is available at:

https://www.sec.gov/interps/account/sab116.pdf

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