BDO Comment Letter - Internal-Use Software (Subtopic 350-40)

Accounting Standards Update, Intangibles, Goodwill and Other – Internal-Use Software (Subtopic 350-40): Customer's Accounting for Implementation Costs Incurred in a Cloud Computing Arrangement That Is a Service Contract; Disclosures for Implementation Costs Incurred for Internal-Use Software and Cloud Computing Arrangements (File Reference No. 2018-230)

BDO supports the proposed guidance for cloud computing fees, but recommends including examples in the final standard.