Overview
In the nearly six months since the Securities and Exchange Commission (SEC) staff updated its Compliance and Disclosure Interpretations (C&DIs) on non-GAAP financial measures, the staff has focused on compliance with that guidance in its reviews of earnings releases and SEC filings. The clear message is that companies need to reevaluate their use and presentation of non-GAAP financial measures. This publication discusses the SEC staff’s main areas of focus in comment letters seeking compliance with the updated C&DIs, changes companies have made to their disclosures and challenges companies are encountering with their non-GAAP disclosures.
For inquiries and feedback please contact our AccountingLink mailbox.
