Looking at accounting and journal entry considerations, if accounts receivables are debited and revenue is credited, it can be interpreted as the business recognizing revenue without the customer paying. As such, the U.S. Securities and Exchange Commission (SEC) sees the potential for intentional manipulation of earnings. It is important to review this type of transaction to see how the U.S. government and accounting standards treat deviations from these activities.

Defining Bill-and-Hold Arrangements

This type of agreement permits sellers to recognize revenue before delivery is made. Instead of shipping the product first, the seller bills the customer first, and delivery is arranged for a future date.

Based upon Accounting Standards Codification (ASC 606-10-55-83) and the U.S. Securities and Exchange Commission (SEC), for a customer to have obtained control of a product in a bill-and-hold arrangement, they must meet all of the following in order to move ownership of the product to the customer, with the seller still in custody of it.

• Customers have explicitly asked for such an arrangement. Purchasers have to demonstrate a material reason for buying the goods through this route.
• The goods must be sequestered explicitly for and attributed exclusively to the customer.
• Customers must be able to physically receive the goods.
• The separated goods are expressly prohibited from being used for any other purposes, including those of other customers.
• Purchasers assume all risk.
• There’s a written, fixed commitment to buy the goods.
• The ultimate delivery of goods must be done according to a set timeline that follows realistic commercial uses.
• The finished goods shall be 100 percent finished and be transit prepared.

Illustrating a Bill-and-Hold Arrangement

Companies in commodity-intensive establishments (miners, farmers, etc.) often use heavy equipment to recover and produce outputs. Since a mining or energy company is unsure of the profitability when recovering resources that are price-dependent on dynamic economic conditions, they often enter into a bill-and-hold arrangement with their supplier. Since the steel producer and the drilling company have an existing arrangement with standard terms, there’s an established history of bill-and-hold transactions. If machinery or drilling equipment is fully built for one of these companies, the equipment manufacturer will sequester the equipment and prohibit it from being shipped to any other buyer. Similarly, the invoice for the equipment must be satisfied by the customer in full within 30 days of the equipment being placed and waiting for the resource company buyers. The last step is for the buyer to arrange delivery in a reasonable manner.   

Based on this real-world example, revenue should be recognized once it’s set aside exclusively for a particular mining or natural resource extraction company.

Considerations Beyond the Goods Themselves

Goods producers also must determine if there’s a custodial component during a bill-and-hold arrangement. If a custodial arrangement exists, either part of the original cost of goods sold to the customer needs to be determined or a separate charge, and therefore, exclusive recognition of revenue for the custodial services provided should be addressed outside of the bill-and-hold arrangement.

When it comes to revenue recognition under certain circumstances, goods producers may be able to recognize revenue despite the traditional requirement that goods have left a business, and the seller has materially satisfied their traditional requirement for accounting standards.

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