The SEC’s Division of Corporate Finance has sent hundreds of comment letters this year questioning the prominence of non-GAAP figures in companies’ earnings releases and other filings in what experts said is an easy gotcha for the staff. …In a review of comment letters sent to Russell 3000 companies between January 2022 and May 2023…
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…
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…