All Posts by Charles Hall


About the Author

Charles Hall is a practicing CPA and Certified Fraud Examiner. For the last thirty years, he has primarily audited governments, nonprofits, and small businesses.He is the author of The Little Book of Local Government Fraud Prevention and Preparation of Financial Statements & Compilation Engagements. He frequently speaks at continuing education events.Charles is the quality control partner for McNair, McLemore, Middlebrooks & Co. where he provides daily audit and accounting assistance to over 65 CPAs. In addition, he consults with other CPA firms, assisting them with auditing and accounting issues.

accountant's scanning system
Aug 27

Accountant’s Scanning System: How to Build

By Charles Hall | Technology

Are you overwhelmed by stacks of paper? Do you find it difficult to locate information you know you have? Today, I teach you how to build an accountant’s scanning system.

accountant's scanning system

I have the privilege of visiting other CPA firms, and our firm has about 120 people, so I have the opportunity to see plenty of offices. It is my observation that some CPAs are paperless, but many are not.

One problem with “paper everywhere” is we can’t find what we need. We have it (somewhere), but we can’t find it. Scanning is the easiest way to capture and organize the paper monster.

To create order, take three steps:

  1. Buy a scanner
  2. Build a scanning structure
  3. Build scanning habits

1. Buy a Scanner

My scanner is a Fujitsu iX500. (There is a newer model now, the iX1500.) It sits just to my right in my office (see picture below), so I don’t have to leave my desk to scan. Convenience is key to creating order. Otherwise, you will think I’ll scan that later, but it doesn’t happen. Then the paper litters your desk–and distracts you.

accountant's scanning system

Picture of my office

The iX1500 costs $420, so it’s not a huge cash outlay. The scanner’s footprint is small (the dimensions are 11.5 x 6 x 6.3 inches) and it weighs 7.5 pounds. Also, the scanner comes with  software (ScanSnap) that offers you destinations such as these:

accountant's scanning system

ScanSnap File Locations

I often scan to Evernote, my cloud-based library. (Amazon also offers Fujitsu ScanSnap iX1500 Document Scanner with Evernote Premium.) If I were buying my first scanner and didn’t have cloud-based storage, this would be my choice.

Another favorite destination: Caseware, our paperless engagement software. 

2. Build a Scanning Structure

So, of course, when you scan, you need final resting places for your documents.

My two primary file locations are:

  • Evernote for non-engagement documents
  • Caseware for engagement documents

Non-Engagement Documents

If you’ve followed my blog, you know I’m a raving Evernote lunatic. Why? 

  • Ease of use 
  • Notebooks (you use notebooks to organize your documents)
  • Tags (you can tag each note with multiple tags, making it easy to find the material)
  • Feed-ability (I can feed Evernote from my scanner, email, clip-apps, drag and drop, and many other ways)
  • Find-ability (Evernote even recognizes hand-written notes making it possible to search electronically and find keywords–even if written)
  • Accessibility (I can access Evernote from my iPhone, iPad, and desktop)
  • Cost (paid version starts at $7.99 per month; they do offer a free version but with limitations)
  • Allows storage of a variety of documents (including Excel, Word, PDF, Audible files)

There are other cloud-based storage systems such as OneNote and Dropbox. Pick one and learn it well.

Engagement Documents

If your audit and tax services are not already paperless, consider making the leap. We have used Caseware for years and, personally, I love it. We use this software for storage of the following engagement files:

  • Tax
  • Audit
  • Reviews
  • Compilations
  • AUPs

My firm has built templates for each of these services, so everyone in our firm knows where documents (including scans) belong.

To scan promptly, you need to build habits, so creating a repeatable, mental system is critical to the process.

3. Build Scanning Habits

Build your scanning habits. My system is as follows:

  • If it takes less than two minutes to scan, scan now
  • If it takes more than two minutes, I place the paper in a file tray where I will later batch process
  • Scan all paper by the end of the day
  • Don’t leave unscanned paper on my desk (it’s a distraction)
  • Keep a shred box just below my scanner (where I place sensitive paper documents)
  • For long documents (e.g., CPE workbook), ask an assistant to break down the paper copy, scan it, and email it to me (I don’t use my Fujitsu scanner for heavy-duty scanning. We have a copy machine that will convert large scans to PDF.)

Like any new habit, new scanning actions will–at first–feel awkward and inconvenient. But push through the pain and the actions will become routine. (Some of the above thoughts come from David Allen’s book: Getting Things Doneone of the best productivity books you’ll find.)

Act Now

You may feel like the above will take too much time to implement, especially if you have lots of paper. So how do you eat an elephant? One bite at a time.

Schedule your scanning plan. Pick two days a week and put one hour a day on your calendar. Then attack. Slay your paper monster. I dare you.

More Evernote Information

For more information about Evernote, check out these posts:

Evernote for CPAs

Seven Ways to Feed Evernote

Tips on Searching Your Evernote Account

steps to prevent fraud
Aug 12

10 Powerful Steps to Reduce Fraud

By Charles Hall | Fraud

As businesses grow, the risk of theft increases. In this post, I offer ten powerful steps to reduce fraud.

Windows open. Curtains blowing. The sound of crickets and an occasional train in the distance. It was a simple childhood. It was my childhood. My mother parked her black Ford Falcon and left the keys in the ignition. The doors to our home were unlocked. We trusted our neighbors and they trusted us. And why would we not? We’d known each other forever.

steps to prevent theft


But then one night at the dinner table, my father said, “someone stole Miss Gussie’s Chevy.” Unthinkable. Our innocence was broken, and soon my mother took precautionary measures. Each evening, after parking, she would place the car keys under the car seat. No need to take chances. We began to close the windows at night, but still, the back door was left unlocked in case my father needed to go out for a smoke.

A couple of months later, I overheard my mother whispering to my grandmother that a man slithered into Miss Kidd’s house in the dead of night and had taken valuables. Miss Kidd lived diagonally from our home, just a stone’s throw away. To think that someone just walked–unannouncedinto the octogenarian’s home. How could this be?

Fear was palpable. Our neighborhood’s character shifted. No longer would Mom leave the keys in the car. No longer would we leave the windows open. No more cricket sounds. And my father even locked the back door.

Safely we would sleep, not because there were no threats, but because of protection.Continue reading

Preparation of Financial Statements
Aug 11

Preparation of Financial Statements: The SSARS Guidance

By Charles Hall | Preparation, Compilation & Review

Are you aware of the option in the SSARS titled Preparation of Financial Statements (AR-C 70)? Many CPAs still believe the lowest level of service in the SSARS is a compilation, but this is not true. CPAs can and do issue financial statements without a compilation report. Today I provide an in-depth look at AR-70, Preparation of Financial Statements

Preparation of Financial Statements

Preparation of Financial Statements


AR-C 70, Preparation of Financial Statements, is the guidance for the preparation of financial statements.


AR-C 70, Preparation of Financial Statements, is applicable when a public accountant is engaged to prepare financial statements or prospective financial information.

This section can also be applied to the preparation of other historical financial information (e.g., schedule of rents).

AR-C 70 does not apply when the accountant prepares financial statements or prospective financial information: 

  • And is engaged to perform an audit, review, or compilation of financial statements
  • Solely for submission to taxing authorities
  • For inclusion in written personal financial plans
  • In conjunction with litigation services that involve pending or potential legal or regulatory proceedings, or 
  • In conjunction with business valuation services

Are there other times when AR-C 70 is not applicable? Yes. The preparation guidance does not apply when the accountant is merely assisting in the preparation of financial statements; such services are considered bookkeeping.

Examples of bookkeeping services include:

  • Preparing or proposing certain adjustments, such as those applicable to deferred income taxes or depreciation
  • Drafting financial statement notes
  • Entering general ledger transactions or processing payments in the client’s accounting software

When AR-C 70 is applicable, certain compliance actions—such as the creation of a signed engagement letter—are required. If the accountant is merely assisting with bookkeeping services, AR-C 70 is not triggered, and compliance with the standard is not necessary.

If the accountant is only entering transactions into a general ledger and making journal entries, he is merely assisting with bookkeeping. Such assistance is often provided in an online bookkeeping software such as QuickBooks. If this is the only service provided, AR-C 70 is not applicable.

If the accountant is engaged to prepare financial statements and performs any of the following, then AR-C 70 applies.

  • The accountant prepares financial statements that are provided to another accountant (another firm) for audit purposes
  • The accountant prepares financial statements separately from a tax return (e.g., the accountant might prepare a tax return that includes financial statements and then—at the client’s request—creates financial statements separately from the return)
  • The accountant uses the client’s general ledger information to prepare financial statements outside of the accounting software (e.g., the accountant places information from a Quickbooks general ledger into Excel and creates financial statements)

As you can see, the preparation standard makes a distinction between:

  • Preparing financial statements (which triggers AR-C 70) and 
  • Merely assisting (which does not trigger AR-C 70)

Are there any other situations where AR-C 70 does not apply? Yes. The AICPA’s Center for Plain English Accounting addressed this question in the following question and answer:

Q: If financial statements are prepared by the accountant as a by-product of another engagement (for example, an engagement to prepare a tax return), is the accountant required to follow section 70 of SSARS No. 21 and include any special disclaimer or “no assurance” statement on those financial statements? 

A: No. The accountant is only required to perform the preparation engagement in accordance with section 70 of SSARS No. 21 when engaged to prepare financial statements. Therefore, because the accountant was not engaged to prepare the financial statements, there is no requirement to include a statement on each page of the financial statements indicating that no assurance is provided on the financial statements.

The author requested that the AICPA define the word engaged. They responded that a client’s request for the preparation of financial statements service is the trigger for being “engaged.” In other words, a client’s request for the preparation of financial statements means we are “engaged,” provided we accept the work. Once the client makes the request, the accountant will create an engagement letter in compliance with AR-C 70.

If the client does not request the preparation of financial statements and the accountant creates the statements as a byproduct of another service (e.g., tax return), he is not subject to the requirements of AR-C 70. 

So when is AR-C 70 applicable? When a public accountant is engaged to prepare financial statements


The objective of the accountant is to prepare financial statements in accordance with the chosen reporting framework.


A compilation report from the accountant is not required (and should not be provided) when preparing financial statements under AR-C 70.

Financial Statements

The accountant can prepare financial statements as directed by management or those charged with governance. The financials should be prepared using an acceptable reporting framework such as the following:

  • Cash basis
  • Tax basis
  • Regulatory basis
  • Contractual basis
  • Other basis (as long as the basis uses reasonable, logical criteria that are applied to all material items) 
  • Generally accepted accounting principles (GAAP)

When preparing financial statements in accordance with a special purpose framework (e.g., tax basis), the accountant is required to include a description of the financial reporting framework either on the face of the financial statements or in a note. Here’s a sample disclosure in a financial statement title: Statement of Assets, Liabilities, and Equity—Tax Basis.

Management determines the financial statements to be prepared. Financial statements normally include the following:

  • Balance sheet
  • Income statement
  • Cash flow statement

The accountant can, if so directed by management, create and issue just one financial statement (e.g., income statement). 

The financial statements can be for an annual period or for a shorter or longer period. So, financial statements can be for a fiscal year, quarterly, or monthly, for example.

The accountant should also obtain an understanding of the significant accounting policies to be used in the preparation of the financial statements.

In preparing the financial statement, the accountant may need to assist management with judgements regarding amounts or disclosures. The accountant should discuss these judgments with management. Why? So management can understand and accept responsibility for the financial statements.

Documentation Requirements

preparation of financial statements

The accountant should prepare and retain the following documentation:

  • Engagement letter (or contract)
  • The financial statements 

Documentation related to significant consultations or professional judgments are to be included in the engagement file. Also, if the accountant departs from a relevant presumptively mandatory requirement, he should document the justification for the departure and how the alternative procedures performed were sufficient to achieve the intent of the requirement. (The SSARSs use the word should to indicate a presumptively mandatory requirement.)

Engagement Letter

Is an engagement letter required for a preparation service? Yes. Moreover, the letter should be signed by the accountant or the firm and management or those charged with governance. A verbal understanding is not sufficient. Though AR-C 70 does not specify how often the engagement letter should be updated, it is best to do so annually. 

The engagement letter should specify:

  • The objectives of the engagement
  • The responsibilities of management
  • The responsibilities of the accountant
  • The limitations of the preparation engagement
  • Identification of the applicable financial reporting framework 
  • The agreement of management that: 
    • Each page of the financial statements will include a statement that no assurance is provided, or
    • The accountant will issue a disclaimer stating that no assurance is provided
  • Whether the financial statements will:
    • Contain known departures from the applicable reporting framework, and 
    • Whether substantially all disclosures will be omitted

No Report

As noted above, no compilation report will be issued for a preparation service. The preparation service is considered a nonattest, nonassurance service, and no compilation, review, or audit procedures are required.

The accountant will do one of the following:

  1. On each financial statement page (including the related notes), indicate, at a minimum, that “no assurance is provided,” or
  2. Provide a disclaimer (see example below)

If the accountant uses the first option, wording such as the following should be included on each page of the financial statements (including the related notes):

  • No assurance is provided on these financial statements
  • These financial statements have not been subjected to an audit or review or compilation engagement, and no assurance is provided on them, or
  • ABC CPAs prepared these financial statements in accordance with professional standards of the AICPA, and no assurance is provided

Other statements can be used to communicate that no assurance is provided, but the minimum wording must include “No assurance is provided.” The “no assurance” wording is made at management’s discretion, and the accountant’s firm name is not required to be included. The wording is normally placed at the bottom of each page. If the client does not allow the accountant to include such a statement on each page of the financial statements, the accountant should:

  • Issue a disclaimer (see below)
  • Perform a compilation in accordance with AR-C 80, or
  • Withdraw from the engagement


If the disclaimer option is used, AR-C 70 provides the following language:

The accompanying financial statements of XYZ Company as of and for the year ended December 31, 20XX, were not subjected to an audit, review, or compilation engagement by me (us) and I (we) do not express an opinion, a conclusion, nor provide any assurance on them.

[Signature of accounting firm or accountant, as appropriate] 

[Accountant’s city and state]


Though not required, the disclaimer can be placed on firm letterhead. Notice that the disclaimer language above has no disclaimer title. While the standard is silent about providing a title, the accountant may add one. For example, Accountant’s Disclaimer. A salutation is not required, but may be added.

Some accountants prefer to provide a disclaimer on letterhead. Why? Any third party reader can see that the accounting firm is involved in the preparation of the statements and that no assurance is provided. 

A third party may not know that an external accountant was involved in preparing the statements if the “no assurance is provided” legend is used and the firm’s name is not included. Remember, however, it is the client’s decision as to whether the “no assurance” legend is added or a disclaimer is provided.


Preparation of financial statements is a nonattest, nonassurance service. When an accountant performs only a preparation engagement, consideration of independence is not necessary. 

If an accountant signs client checks and performs bookkeeping services, independence is not required. Moreover, if the accountant prepares financial statements for the same client, independence is not required. Signing checks, bookkeeping, and the preparation of financial statements are all nonattest services.

But what happens if the accountant prepares financial statements and issues a compilation report?

Suppose an accountant issues monthly financial statements for January through November with no compilation report (using the preparation option), but in December issues financial statements with a compilation report. Providing the monthly preparation services and the December compilation service triggers a requirement to consider independence. 

Just remember this for now: Independence is not required for preparation engagements, and there are no requirements to disclose a lack of independence in a preparation engagement.

Omission of Substantially All Disclosures

Can the accountant omit all disclosures (notes to the financial statements) in a preparation engagement? Yes. Alternatively, the accountant can provide selected disclosures or if needed, full disclosure. In short, the accountant can do any of the following:

  1. Omit all disclosures
  2. Provide selected disclosures
  3. Provide full disclosure

Regardless, the engagement letter should describe the level of disclosure to be provided in the financial statements. Also, the omission of substantially all disclosures should be communicated either on the face of the financial statements or in a selected note. There is no provision in the preparation standard to report the omission of disclosures in the accountant’s disclaimer that precedes the financial statements. 

The accountant can communicate the omission of disclosures by including wording such as the following at the bottom of each financial statement page or in a note:

  • Substantially all disclosures required by accounting principles generally accepted in the United States are not included.
  • Substantially all disclosures ordinarily included in financial statements prepared in accordance with the tax-basis of accounting are not included.

The accountant can also communicate the omission of disclosures in the title of the financial statements. For example:

ABC Company

Statement of Income

Substantially All Disclosures Omitted

December 31, 2020

Information Provided is Incomplete or Inaccurate

Deficiencies in the information provided to the accountant should be communicated to management, and the inaccuracy or incompleteness of such information should be corrected. Deficiencies in the information include insufficient records, documents, explanations, and judgments.

Reporting Known Departures from the Applicable Financial Reporting Framework

How should a departure from the applicable financial reporting framework be reported? Discuss the departure with management to see if it can be corrected. If it is not corrected, disclose the departure. How?

A departure from the applicable financial reporting framework should be disclosed either on the face of the financial statements or in a note. If it takes more than a few words to describe the departure, note disclosure may be the better option—you’ll have more room there. There is no provision in the preparation standard to disclose departures in the accountant’s disclaimer that precedes the financial statements.

Other Historical or Financial Information

In addition to historical financial statements, AR-C 70 may be applied to the following:

  • Specified elements, accounts, or items of a financial statement, including schedules of:
    • Rents
    • Royalties
    • Profit participation, or
    • Income tax provisions
  • Supplementary information
  • Required supplementary information
  • Pro forma financial information

Prospective Financial Information

prospective financial statements

AR-C 70 can be applied to prospective information.

Prospective financial information is defined as any financial information about the future. 

Prospective financial information can be presented as:

  • A complete set of financial statements, or
  • One or more elements, items, or accounts

If you prepare prospective financial information, the summary of significant assumptions must be included Why? It is considered essential to the user’s understanding of such information.

If you prepare a financial projection, you should not exclude:

  • The identification of hypothetical assumptions, or
  • The description of the limitations on the usefulness of the presentation

AR-C 70 references the AICPA Guide Prospective Financial Information as suitable criteria for the preparation and presentation of prospective financial information.

Prescribed Forms

Is it permissible to perform a preparation of financial statement engagement with regard to prescribed forms?

Yes. There is nothing in AR-C 70 that prohibits the accountant from performing a preparation engagement with regard to prescribed forms (e.g., bank personal financial statement). However, the accountant is required to follow all of the preparation guidance. Clients may not want to add wording to the prescribed forms such as “no assurance is provided” or “substantially all disclosures are omitted.” As an alternative to adding such wording, the accountant can provide a disclaimer before the prescribed form. 

Selected notes can follow the form if needed. If this option is used, the order of the deliverable is as follows:

  • Disclaimer 
  • Prescribed form 
  • Selected notes

When a bank, credit union, regulatory or governmental agency, or other similar entity designs a prescribed form to meet its needs, there is a presumption that the required information is sufficient. What should be done if the prescribed form conflicts with the applicable basis of accounting? For example, what if the prescribed form requires all numbers to be in compliance with GAAP with the exception of receivables? Follow the form. In effect, the prescribed form is the reporting framework. Report departures from the prescribed form and its related instructions on the face of the financial statements (the form) or in a note. 

Draft Financial Statements

The client may request a draft copy of the financial statements prior to final issuance. To avoid confusion, mark statements with words like:

  • Draft Financial Statements
  • Working Draft
  • Draft - Subject to Change

Preparation of Financial Statements - A Simple Summary

  • AR-C 70 is applicable when the accountant is engaged to prepare financial statements and is not applicable when the accountant is engaged to perform a compilation or if the accountant is merely assisting with bookkeeping
  • The objective of the accountant is to prepare financial statements in accordance with the chosen reporting framework
  • The financial statements can be prepared in accordance with GAAP or a special purpose reporting framework
  • The financial statements can be distributed to third parties (and not just management)
  • The accountant must either:
    • State on each financial statement page that “no assurance is provided,” or
    • Provide a disclaimer
  • Documentation requirements include:
    • The engagement letter, and 
    • The financial statements  
  • An engagement letter must be signed by:
    • The accountant or the accountant’s firm, and
    • Management or those charged with governance
  • No report (e.g., compilation report) is attached to the financial statements
  • Consideration of independence is not required
  • Substantially all disclosures can be omitted 
  • The omission of substantially all disclosures should be:
    • Disclosed on the face of the financial statements, or
    • In a note
  • Selected disclosures can be provided 
  • Departures from the applicable financial reporting framework should be:
    • Disclosed on the face of the financial statements, or
    • In a note
  • A preparation engagement can be applied to historical financial statements and historical information (e.g., specified items of a financial statement).
  • A preparation engagement can be applied to prospective financial information. The summary of significant assumptions must be included.
  • A preparation engagement can be performed in relation to prescribed forms (e.g., bank personal financial statements)
  • Mark draft financial statements with appropriate wording (e.g., Draft Financial Statements)
peer reviewers focus on independence
Aug 05

Peer Reviewers Focus on Independence Documentation

By Charles Hall | Auditing , Preparation, Compilation & Review

Peer reviewers focus on independence documentation. Today I’ll provide you with examples of what peer reviewers are looking for and guidance to keep you out of hot water.

peer reviewers focus on independence

Documentation of Nonattest Services

Peer reviews focus upon nonattest services provided to attest clients. How do we know? Well, see the peer review checklist question below (for an attest engagement).

nonattest services

The big “no-no” is to assume management responsibilities and then perform an attest service. Why? Performing management responsibilities impairs your independence. 

Preparing Financial Statements

Below is another question from the peer review checklists. Notice the first item below: Accepting responsibility for the preparation and fair presentation of the client’s financial statements. The client (not the auditor) must assume responsibility for the financial statements


If the client can’t–or is unwilling to–assume responsibility for the financial statements, then we are not independent, and we cannot perform an audit or a review. This assumption of responsibility does not mean the client has the ability to create financial statements, but it does mean that:

  • that the client will oversee the nonattest service,
  • the client will evaluate the adequacy and results of the nonattest service, and
  • the client will accept responsibility for the nonattest service

If we prepare financial statements and perform an audit, review, or compilation, we have performed a nonattest service and an attest service. Why is this important? Because if we perform a nonattest service and an attest service for the same client, we must assess our independence. And if we are not independent, then we can’t perform an audit or review engagement. (It is permissible to perform the compilation engagement when independence is impaired, but the accountant must say–in the compilation report–that he is not independent.)

Other Peer Review Questions

The peer review checklists also ask for:

  • The name and title of the client personnel overseeing the nonattest service and
  • A description of the accountant’s “assessment and factors leading to your satisfaction that the client personnel overseeing the service had sufficient skills, knowledge and experience.”

Separate Form to Document Independence

So do we need a separate form in our file to document independence?

It certainly would not hurt, and I suggest that you do. PPC and CCH offer such forms (and I am sure other work paper providers do the same). These forms provide a place to document all nonattest services and to assess and document our client’s ability to assume responsibility for the nonattest services.

The PPC and CCH forms also address the cumulative effect of performing multiple nonattest services. The AICPA has stated that the performance of multiple nonattest services can impair independence. So you should document your consideration of whether the cumulative nonattest services create a problem. Peer review checklists ask if we documented this consideration.

Additionally, if significant threats are present, the accountant should document the safeguard(s) used to mitigate the risk. This documentation is particularly crucial in Yellow Book engagements. The PPC and CCH independence forms will assist you with this documentation. Below are peer review checklist questions:

Alignment in Independence Documentation

We should–in the engagement letter–specify the nonattest services and the responsibilities of management. If you are performing an audit or a review engagement, add additional language to the representation letter regarding the nonattest services performed and the client’s responsibility for those services.

So I am suggesting you document the nonattest services in three places:

  • Engagement letter,
  • Independence form, and
  • Representation letter (when relevant)

And when you do, please make sure the nonattest services listed in each document are the same. 

ASU 2018-08
Jul 31

ASU 2018-08: Nonprofit Revenue Recognition

By Charles Hall | Accounting and Auditing

In June of 2018, FASB issued ASU 2018-08: Clarifying the Scope and the Accounting Guidance for Contributions Received and Contributions Made.

Today I provide an overview of how this standard affects nonprofit revenue recognition. 

ASU 2018-08

ASU 2018-08: Nonprofit Revenue Recognition

The purpose of the standard is to provide guidance in regard to recognizing revenues in nonprofit organizations. This standard is conceptually consistent with Topic 606, Revenue from Contracts with Customers, which requires revenue to be recognized when performance obligations are satisfied. ASU 2018-08 requires contribution revenue recognition when conditions are met (see below).

Once ASU 2018-08 becomes effective (years ending December 31, 2019 for many nonprofits), nonprofits will recognize revenues in one of three ways:

  1. Exchange transaction
  2. Conditional Contribution
  3. Unconditional Contribution 

1. Exchange transaction

If a nonprofit is paid based on commensurate value, then there is an exchange transaction. The nonprofit recognizes revenue as it provides the service or goods. Apply Topic 606, Revenue from Contracts With Customers, for these transactions. An example of an exchange transaction is a nonprofit is paid market rate for painting a local store.

ASU 2018-08 makes it plain that benefits received by the public as a result of the assets transferred is not equivalent to commensurate value received by the resource provider.

2. Conditional Contribution

A conditional contribution is one where:

  • a barrier is present and
  • a right of return or right of release for the contributor exists

The following ​are indicators of a barrier:

  • Recipient must achieve a measurable, performance-related outcome (e.g., providing a specific level of service, creating an identified number of units of output, holding a specific event)
  • A stipulation limits the recipient’s discretion on the conduct of the activity (e.g., specific guidelines about incurring qualifying expenses)
  • A stipulation is related to the primary purpose of the agreement (e.g., must report on funded research)

Recognize revenue when the barrier is overcome.

ASU 2018-08

An example of meeting a measurable outcome would be if the donor requires the serving of meals to 1,000 homeless persons. Another example of the first indicator above is a matching requirement.

An example of limited discretion would be a requirement to hire specific individuals to conduct an activity.

Are budgets an indicator of limited discretion? A line-item budget for a grant is often seen as a guardrail rather than a barrier. A June 2019 FASB Q&A states “Thus, stipulations other than adherence to a budget (for example, the need to incur qualifying expenses) would normally need to be present for a barrier to entitlement to exist.” The Q&A goes on to say, “The unique facts and circumstances of each grant agreement must be analyzed within the context of the indicators to conclude whether a barrier to entitlement exists.”

An example of a stipulation related to the primary purpose of the agreement is a grant that requires the filing of an annual report of funded research. If the grantor requires repayment of the amount received should the report not be filed, then the requirement is a barrier. Judgment is necessary to determine whether a requirement is a barrier. For example, filing routine reports to a resource provider showing progress on a funded activity may be seen as routine and not a barrier. Goals or budgets where no penalty is assessed if the organization fails to achieve them are not considered barriers.

Per ASU 2018-08 “Conditional contributions received are accounted for as a liability or are unrecognized initially, that is, until the barriers to entitlement are overcome, at which point the transaction is recognized as unconditional and classified as either net assets with restrictions or net assets without restrictions.”

3. Unconditional Contribution

If there are no barriers or if barriers have been overcome, the receipt is unconditional. There might still be a purpose or time restriction, resulting in the funds being classified as “With Donor Restrictions” until the restriction is satisfied. Recognize the revenue either as:

  • Net Assets with Donor Restriction
  • Net Assets without Donor Restriction

Effective Date 

A public company or a not-for-profit organization that has issued, or is a conduit bond obligor for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market would apply the new standard for transactions in which the entity serves as a resource recipient to annual reporting periods beginning after June 15, 2018, including interim periods within that annual period. Other organizations would apply the standard to annual reporting periods beginning after December 15, 2018, and interim periods within annual periods beginning after December 15, 2019.

A public company or a not-for-profit organization that has issued, or is a conduit bond obligor for, securities that are traded, listed, or quoted on an exchange or an over-the counter market would apply the new standard for transactions in which the entity serves as a resource provider to annual reporting periods beginning after December 15, 2018, including interim periods within that annual period. Other organizations would apply the standard to annual reporting periods beginning after December 15, 2019, and interim periods within annual periods beginning after December 15, 2020.

Early adoption of the amendments in this ASU is permitted.

Transition Guidance

ASU 2018-08 should be applied on a modified prospective basis. Retrospective application is permitted. Under a modified prospective basis, the amendments should be applied to agreements that are either:

  • Not completed as of the effective date
  • Entered into after the effective date

A completed agreement is an agreement for which all the revenue of a recipient or expenses of a resource provider have been recognized before the effective date of ASU 2018-08.

No prior-period results should be restated. There is no cumulative-effect adjustment to the opening balance of net assets at the beginning of the year of adoption.


In the year of adoption, the entity is required to disclose:

  • The nature of and reason for the accounting change
  • An explanation of the reasons for significant changes in each financial statement line item in the current  annual or interim period resulting from applying the amendments instead of the previous guidance


Per ASU 2018-08,Accounting for contributions is an issue primarily for not-for-profit (NFP) entities because contributions are a significant source of revenue for many of those entities. However, the amendments in this Update apply to all entities, including business entities, that receive or make contributions of cash and other assets, including promises to give within the scope of Subtopic 958-605 and contributions made within the scope of Subtopic 720-25, Other Expenses—Contributions Made.”

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