The total amount of comment letters stemming from 10-K and 10-Q filings has once again decreased (as shown in the chart below). From 2017 to 2018, total comment letters decreased by roughly 26%, which is slightly steeper than the decline we’ve … Continue reading
Category Archives: Non-GAAP
Pros and Cons of Using Non-GAAP Metrics for Executive Compensation, Including ESG Considerations
This article was first available to subscribers of Accounting Quality Insights by Audit Analytics on Bloomberg, Eikon, FactSet, and S&P Global. There has been considerable debate about companies that use non-GAAP metrics for executive compensation and whether these firms are … Continue reading
Could SEC Charges Have Been Predicted for GT Advanced Technologies?
Note: This article was first available to subscribers of Accounting Quality Insights by Audit Analytics on Bloomberg, Eikon, FactSet, and S&P Global. Key Points: SEC fined former CEO of GT Advanced Technologies (GTAT) over $140,000 in connection with making false … Continue reading
Academic Literature Review: Accounting Reporting Complexity and Non-GAAP Earnings Disclosure
The overall complexity of financial disclosures affects the ability of anyone reading the financial statements, including stockholders, regulators, and investors, to analyze and assess the information presented. One way to measure complexity of disclosures is by determining accounting reporting complexity … Continue reading
A Look at Top SEC Comment Letter Issues in 2018
The number of SEC comment letters has been declining for nine consecutive years. During the first nine months of 2018, 2,174 letters were filed1 (831 CORRESPs and 1,343 UPLOADs) – a decrease of 40% from the 3,629 letters that were … Continue reading
Trends in SEC Non-GAAP Comment Letters 2016-2018
Key Findings The overall number of comment letters issued by the SEC has decreased since 2010 The percentage of comment letters referencing a non-GAAP metric increased through 2017, but has been trending downward in the first 6 months of 2018 … Continue reading
Long-Term Trends in Non-GAAP Disclosures: A Three-Year Overview
Regulation G, adopted by the SEC in 2003, established a regulatory framework that companies must follow to present metrics that are not calculated in accordance with GAAP. Regulation G defines a non-GAAP metric as a numerical measure that excludes amounts … Continue reading