Topic 8: Retail Companies

A. Sales Of Leased Or Licensed Departments

Facts: At times, department stores and other retailers have included the sales of leased or licensed departments in the amount reported as “total revenues.”

Question: Does the staff have any objection to this practice?

Interpretive Response: The staff believes that FASB ASC Topic 840, Leases, requires department stores and other retailers that lease or license store space to account for rental income from leased departments in accordance with FASB ASC Topic 840. Accordingly, it would be inappropriate for a department store or other retailer to include in its revenue the sales of the leased or licensed departments. Rather, the department store or other retailer should include the rental income as part of its gross revenue. The staff would not object to disclosure in the footnotes to the financial statements of the amount of the lessee’s sales from leased departments. If the arrangement is not a lease1 but rather a service arrangement that provides for payment of a fee or commission, the retailer should recognize the fee or commission as revenue when earned. If the retailer assumes the risk of bad debts associated with the lessee’s merchandise sales, the retailer generally should present bad debt expense in accordance with Rule 5-03 of Regulation S-X.

B. Finance Charges

Facts: Department stores and other retailers impose finance charges on credit sales.

Question: How should such charges be disclosed?

Interpretive Response: As a minimum, the staff requests that the amount of gross revenue from such charges be stated in a footnote and that the income statement classification which includes such revenue be identified. The following are examples of acceptable disclosure:

Example 1

Consumer Credit Operations:

The results of the Consumer Credit Operations which are included in the Statement of Earnings as a separate line item are as follows for the fiscal year ended January 31, 20x0:

Service charges	$167,000,000
Operating expenses
Interest	60,000,000
Payroll	35,000,000
Provision for uncollected accounts	29,000,000
All other credit and collection expenses	32,000,000
Provision for Federal income taxes	5,000,000
Total operating expenses	$161,000,000
Consumer credit operations earnings	$ 6,000,000

Example 2

Service charges on retail credit accounts are netted against selling, general and administrative expense. The cost of administering retail credit program continued to exceed service charges on customer receivables as follows:

(in millions)	20x2	20x1	Percent Increase (decrease)
Costs:
Regional office operations	$ 45	$ 42	9
Interest	51	44	13
Provision for doubtful accounts	21	15	34
Total	$117	$102	15
Less service charge income	96	79	22
Net cost of credit	$ 21	$ 23	(10)
Net cost as percent of credit sales	1.4%	1.6%

The above results do not reflect either “in store” costs related to credit operations or any allocation of corporate overhead expenses.

This SAB is not intended to change current guidance in the accounting literature. For this reason, adherence to the principles described in this SAB should not raise the costs associated with record-keeping or with audits of financial statements.

C. Impact of a Registrant’s Adoption of FASB ASC Topic 606, Revenue from Contracts with Customers

Topic 8 is no longer applicable upon a registrant’s adoption of ASC Topic 606. Topic 8 provides the staff’s views regarding (i) the prohibition of presenting sales of a leased or licensed department within a retailer’s statement of comprehensive income consistent with the principles codified within ASC Subtopic 605-45 and (ii) the disclosure of finance charges imposed by retailers on credit sales. ASC Topic 606 provides guidance regarding the identification of performance obligations in a contract with a customer, presentation of revenue as a principal (on a gross basis) or as an agent (on a net basis) as well as presentation of the effects of financing in the statement of comprehensive income, which eliminates the need for the guidance in Topic 8. Prior to adoption of ASC Topic 606, registrants should continue to refer to prior Commission and staff guidance on revenue recognition topics.

Footnotes

The FASB ASC Master Glossary defines a lease as “an agreement conveying the right to use property, plant, or equipment (land and/or depreciable assets) usually for a stated period of time.”