SEC Comment Letters On Non-GAAP Measures

In a recent article for Agenda, I commented on the comment letters from the Securities and Exchange Commission (SEC) related to non-GAAP measures and what this focus could mean for audit committees.

In December 2022, the SEC released several new or revised Compliance & Disclosure Interpretations (C&DIs) regarding the use of non-GAAP measures in SEC filings.

"These [C&DIs] highlighted a renewed focus from the SEC on non-GAAP measures," I explained in the article. "But even before that, the most frequent topic in comment letters in the past few years was non-GAAP measures." I added, "Overall, the SEC is focused on transparency and investor protection, and equal or greater prominence fits right in there."