ASU 2009-14 (EITF 09-3) applies specifically to sales of hardware along with software that is more than incidental to the tangible product as a whole.
ASC Subtopic 605-25 (EITF 08-1) generally applies to multiple-element revenue arrangements. However, there may be other Codification Subtopics that provide guidance on separation of deliverables and allocation of arrangement consideration to those deliverables that applies to specific industries or transactions. ASC paragraph 605-25-15-3A explains how the guidance on separation and allocation in ASC Subtopic 605-25 interacts with the separation and allocation guidance in other Subtopics. If there is no separation and allocation guidance in another Codification Subtopic that applies, the guidance in ASC Subtopic 605-25 applies.
I’m not aware of any industry-specific guidance that would apply to the fact pattern you’ve described, but I have no experience in the financial services area. Please consult with your auditors to determine whether other separation and allocation guidance may apply.
