Overview
In our comment letter, we support the FASB’s proposal to (1) improve the guidance in ASC 815 by expanding the scope of contracts that would be excluded from derivative accounting and (2) clarify how to account for a share-based payment from a customer that is consideration for the transfer of goods or services under ASC 606. However, we recommend revising certain aspects of the proposed guidance to address potential operational issues, including eliminating the predominant characteristics assessment and clarifying certain language.