It is the almost the end of the year—the time by which privately held franchisors must have responded to the impact of a new accounting rule (ASC 606) governing when initial franchise fees may be recognized as revenue or else confront in 2020 the need to defer or escrow initial franchise fees (or be refused franchise registration altogether). ASC 606 became effective Jan. 1, 2019 for non-public business entities, meaning that their fiscal year end 2019 audited financial statements must be in full compliance therewith.

Let us explain.