It is time once again to look at macro trends in SEC Comment Letters. As with every year we will look primarily at comments from 10-K’s and 10-Q’s, but like last year we will also be analyzing 8-K’s and what … Continue reading
Category Archives: Non-GAAP
SEC Comment Letters Every Analyst Should Read
As part of its requirements under the Sarbanes-Oxley Act of 2002, the SEC reviews the financial reporting of every public company at least once every three years. If the SEC has questions, the company will receive a SEC Comment Letter. … Continue reading
Non-GAAP Reporting One Year After New SEC Guidance
Audit Analytics released our latest report, Corporate Implementation of SEC’s Compliance & Disclosure Interpretations Regarding Non-GAAP Financial Measures, at this year’s annual AICPA conference on current SEC and PCAOB developments, held in Washington, D.C. The SEC recently provided an update to the Compliance & Disclosure … Continue reading
A Look at Top SEC Comment Letter Issues in 2017
2017 marked the eighth consecutive year of decline in the number of SEC comment letters. During the first six months of 2017, 2,315 letters1 were filed (905 CORRESPs and 1,410 UPLOADs) – a decrease of 246 letters (9.6%) from the first … Continue reading
Reporting multiple Earnings Per Share numbers – General Electric is not alone
On the recent Q3 earnings call, General Electric [GE] pledged to simplify adjusted EPS (Earnings Per Share) numbers that are being reported to investors. Among other things, Jamie Miller, the incoming CFO of GE, plans to move off reporting industrial and … Continue reading
SEC Updates Non-GAAP C&DIs for Business Combinations
On October 17, 2017, the SEC released two new updates to the Compliance & Disclosure Interpretations (“C&DIs”). The C&DIs comprise the Division’s interpretations of the rules and regulations on the use of non-GAAP financial measures. The two updates focus on the … Continue reading
Could the MDC Partners Enforcement Action have been Predicted?
How likely is a company to be cited for a violation of non-GAAP reporting rules? Is non-GAAP violation a primary offense? That is, can a company face an enforcement action just for that? Let’s take a look at a recent … Continue reading