AICPA
The AICPA has no formal position on applicability of ASC 606 to CIRAs and has no plans to issue any specific guidance. (as of January 31, 2020 per discussion with accounting standards division of AICPA)
Note for practioners - Date January 2020 - Several CPA firms have had direct communications with AICPA staff regarding revenue recognition for the CIRA industry. AICPA is well aware of the differing positions adopted by CPA firms regarding interpretation of ASC 606 for community associations. AICPA states that they have no contact with PPC and are not responsible for any positions taken in the PPC publication. AICPA has stated that they will point us to the FASB standard but will not provide an interpretation. AICPA has NO current plans to issue clarifying interpretations at any point in the future. Discussions with AICPA Peer Review Division have been somewhat more productive. Although the peer review division has accepted information from CPAs documenting their reasons why they believe ASC 606 does not apply to community associations, AICPA will not discuss how they are intending to update the CIRA Peer Review Checklist regarding applicabilty of ASC 606 to CIRAs.
A "white paper" that has been circulated as being the work product of an AICPA committee has been confirmed by AICPA as NOT being a recommendation of that committee. The white paper may have been developed by certain members of the committee, but the committee developed questions only and issued no formal position paper.
On February 19, 2020 the AICPA National A&A Resource Center issued a report under its "Center for Plain English Accounting" (CPEA) section entitled "The New Revenue Recognition Standard - Industry Impacts: CIRAs." That 13 page document clearly states on page 2 that "The positions expressed in this report should not be viewed as official positions of the AICPA" and on page 13 states "The CPEA makes no warranties or representations concerning the accuracy of any reports issued." It's good that the report contains those qualifications regarding the content of the report because the only way the authors could reach the conclusions expressed in the report is to completely overlook certain facts that exist within ASC 606 and stated in their own report.
The report goes on to restate what are effectively the same positions expressed in the PPC Guide 2019 update. The main difference is that this report at least acknowledges the opposing positions, but still effectively dismisses those opposing positions without providing any serious consideration of their reasons for doing so. In other words, this report represents nothing more than the interpretation of the two authors that wrote it. This report is not reproduced on this website as it is available only by subscription to the CPEA and is copyrighted by the Association of International Certified Professional Accountants (the other AICPA).
