10 -31 SEC Accounting and Auditing Enforcement release (AAER) NO. 108 specifies certain conditions or criteria that a bill and hold transactions of a public company should meet in order to qualify for Revenue recognition. The AAER also specifies certain factors that should be considered in evaluating whether a bill and hold transaction meets the requirements for revenue recognition. AAER. NO. 108 states that a bill and hold transaction should meet the following conditions:

1. The Risks of ownership must have passed to the buyer

2. The customer must have made a fixed commitment to purchase the goods, preferably reflected in written documentation.

3. The buyer, not the seller, must request that the transaction be on a