On January 30, 2020, the SEC issued Guidance on the use of key performance
indicators and metrics in MD&A.
Item 303(a) of Regulation S-K requires disclosure in MD&A of
information not otherwise required, including key performance
indicators and other metrics, that the company believes is
necessary to an understanding of its financial condition, changes
in financial condition and results of operations. Some companies
also disclose non-financial and financial metrics to describe their
business, including those that relate to external or macro-economic
matters, and/or those that are company or industry specific.
The Guidance reminds companies to consider the extent to which
an existing regulatory disclosure framework applies to these
metrics, such as GAAP or, for "non-GAAP measures,"
Regulation G or Item 10 of Regulation S-K. In addition, companies
should consider what additional information may be necessary to
provide adequate context for an investor to understand the
