Cboe Global Markets, Inc. (f/k/a CBOE Holdings, Inc.) recently received comments on its Form 10-Q related to FASB’s new revenue recognition standard. The SEC comments were:

  • Please explain to us how you determined that rebates paid to customers in accordance with published fee schedules should not be accounted for as a reduction of the transaction price. Refer to ASC 606-10-32-25 to 32-27.
  • We note your disclosure that you recognize revenue for certain services over time. Please tell us how you considered the requirements in ASC 606-10-50-13 to 50-15 to disclose information about remaining performance obligation or application of optional exemptions.

I outlined another comment letter received by an issuer here. There are no common threads between the two letters, except both asked questions about recognizing revenue over time.