When applying SAB 101, what is the staffs view of the pool of contract acquisition and origination costs that are eligible for capitalization?
As noted in footnote 29 of SAB 101, SFAS No. 91 includes a definition of incremental direct costs in its glossary. Paragraph 6 of SFAS No. 91 provides further guidance on the types of costs eligible for capitalization as customer acquisition costs indicating that only costs that result from successful loan origination efforts are capitalized. The FASB staff has published an Implementation Guide on SFAS No. 91 that provides additional guidance on the costs that qualify for capitalization as customer acquisition costs. Further, FTB 90-1 also requires capitalization of incremental direct customer acquisition costs and requires that those costs be “identified consistent with the guidance in paragraph 6 of Statement 91.” Although the facts of a particular situation should be analyzed closely to capture those costs that are truly direct and incremental, the staff generally would not object to an accounting policy that results in the capitalization of costs in accordance with paragraph 6(a) a
