• In Depth: Non-GAAP Question 100.04 Comment Letters

    Clear, consistent, and comparable presentation of a company’s financial condition is a hallmark of transparency in U.S. trading markets. Thus, regulatory attention often focuses on instances where companies stray from using generally accepted accounting principles (GAAP) and report non-GAAP measures in financial statement filings with the U.S. Securities and Exchange Commission (SEC). The SEC’s December…

  • A Survey of Non-GAAP Comment Letters

    This report reviews recently released U.S. Securities and Exchange Commission (SEC) comment letters related to the use of non-generally accepted accounting principles (non-GAAP) financial measures in mandated financial reporting for U.S. publicly traded companies. To help provide compliance guidance, this report provides excerpts of SEC staff comment letters related to topics discussed as questions in…