Insights & Publications
Diversity, Equity & Inclusion
© 2023 Debevoise & Plimpton LLP
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.
Mergers & Acquisitions
Regulatory, Reporting and Other Advisory Services
Matthew E. Kaplan
Joshua M. Samit
UK Modern Slavery Act Transparency Statement
Debevoise Login (2)
Debevoise Women's Review