Non-GAAP financial measures reporting compliance can be challenging in the best of times. With the SEC’s recent updated non-GAAP guidance, issued December 2022, it’s not unreasonable to expect additional scrutiny on financial reporting.

Our two recent reports provide excerpts of non-GAAP comment letters issued to Russell 3000 companies and identifies affected industries.

Our first report examines comment letters on 18 non-GAAP issues released January 2022-May 2023. Our second report drills down into Question 100.04 individually tailored accounting measures.

MyLogIQ’s key findings from the two reports were that:

  • Three of the five issues updated in the 2022 guidance made up nearly two-thirds of all non-GAAP comment letters.

    • The top three were:
    *Prominence of non-GAAP measures.
    *Recurring expenses.
    *Question 100.04 individually tailored accounting measures rounded out the top three.

  • The top three sectors receiving Question 100.04 letters were:

    *Technology & Communications
    *Financials
    *Services.

Question 100.04 comment letters revealed that revenue was the top item cited in questions about individually tailored accounting measures.

For details, download our reports:

  • A Review of Non-GAAP Comment Letters
  • Non-GAAP Question 100.04 Comment Letters