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Technical Line - How to appropriately use non-GAAP measures to discuss the effects of COVID-19


Many registrants are considering using non-GAAP financial measures to discuss the effects of the COVID-19 pandemic in their upcoming earnings releases and analyst calls. We answer a number of frequently asked questions (FAQs) about the recent SEC staff accommodation when a registrant is facing difficulties in reporting financial results due to the pandemic and publicly discloses a GAAP measure that includes best estimates or ranges rather than final results. The FAQs also address which types of pandemic-related adjustments to a non-GAAP measure are appropriate, and inappropriate, under the SEC staff’s guidance. They also address how a registrant can convey information to investors about pandemic-related items that cannot be included as an adjustment to a non-GAAP measure.

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