Non-GAAP Metrics in SAB 99 Materiality Analyses

The pros and cons of non-GAAP metrics have been discussed in more than a few recent articles. Proponents of non-GAAP frequently claim that GAAP contains many ambiguities and loopholes, and that non-GAAP metrics can be more current and relevant. Opponents sometimes … Continue reading

Walmart Reports Material Weakness

In a 10-Q filed yesterday, September 9th, Walmart disclosed a significant deficiency that rose to the level of material weakness in its SOX Section 302 Disclosure Controls and Procedures assessment. The deficiency related to the company’s application of lease accounting. According to … Continue reading

2014 SEC Filing Highlights, Part 1 of 2

In this post we kick off what we hope will be an annual series. It is a full-year recap of some of the most notable SEC disclosures that we track: a “best-of-the-year” review. In this first post, we’ll look at the largest restatement; the … Continue reading

Exploring the Disclosure of Cybersecurity

The SEC has been concerned with cybersecurity disclosures for many years. In 2011, guidance was issued to clarify public companies’ responsibility to disclose cybersecurity issues. The guidance requires public companies to disclose cybersecurity as a Risk Factor for companies that … Continue reading

SEC Questions Internal Controls at Citigroup

On August 1, 2014 Citigroup Inc [C] received a comment letter from the SEC. One of the comments referred to a $235 million after-tax charge resulting from a fraud discovered at its Banco Nacional de Mexico (Banamex) subsidiary, which was recorded during the … Continue reading

GT Advanced Technologies: Red Flags Exhibited Prior to Bankruptcy

On October 6th, GT Advanced Technologies (GTAT) and its subsidiaries filed for bankruptcy protection under Chapter 11. Speculation about the company’s negative prospects were apparent after Apple decided not to use GT Advanced as a supplier for the behemoth’s latest iPhone. … Continue reading