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Early Returns: Companies Change Non-GAAP Financial Disclosures Following Recently Issued SEC Guidance
1 September 2016
View Client Update
On May 17, 2016, the SEC issued 12 new Compliance and Disclosure Interpretations ("C&DIs") on the use and presentation of non-GAAP financial measures.
We surveyed the impact that the C&DIs had on earnings releases issued by a sample of
companies. Of the 100 companies included in our survey sample, a significant majority modified their non-GAAP disclosures as compared with their disclosures from the prior fiscal period’s earnings releases.
Since the publication of the C&DIs, the SEC has also issued comment letters focused on non-GAAP disclosures.
Registrants should expect continued focus by the SEC on the use of non-GAAP financial measures and should further review their presentation and disclosure of non-GAAP measures against the C&DIs and specific issues raised in SEC comment letters.
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