Non-GAAP: What’s trending in SEC comments

In each episode of our What’s trending in SEC comments series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance for the most common topical areas of financial reporting.

This week we focus on non-GAAP measures. Kyle Moffatt, a partner in PwC’s National Office, joined Heather Horn to break down some of the questions raised in these comments, giving you a deeper understanding of the SEC staff’s expectations, as well as context and insights into the non-GAAP rules.

Topics include:

• 1:35 - Background on non-GAAP measures. Disclosing non-GAAP measures is a common way companies supplement their financial statement disclosures to further tell the story of their businesses. Kyle gives some helpful background and examples of some commonly utilized measures.
• 8:57 - Presenting non-GAAP measures. There can be pitfalls associated with these alternative measures. Kyle and Heather discuss what issuers should keep in mind when deciding how to present them.
• 22:30 - What types of comments are companies receiving? Kyle discusses the main themes of the SEC staff’s non-GAAP comments. Common questions relate to prominence relative to GAAP metrics, the reconciliation of each non-GAAP metric to GAAP, and the appropriateness of adjustments, among others.
• 27:43 - Key takeaways and reminders. We close with some future areas to pay attention to and helpful advice for year-end reporting. Heather tries to stump Kyle with some niche accounting and pop culture questions.

Want to learn more?

• Listen to our previous comment letter podcasts on MD&A, Debt, warrants, and equity, Revenue, Goodwill, Inventory and cost of sales, and Segment reporting
• Listen to What you missed at the 2021 AICPA Conference
• In the loop: To GAAP or to non-GAAP COVID-19: What you should know
• See our overview of SEC Comment Letter Trends
• Staff Accounting Bulletin Topic 11 B
• SEC Non-GAAP Financial Measures: Questions and Answers of General Applicability

Kyle Moffatt is a partner in PwC's National Office where he consults with engagement teams and audit clients on SEC reporting matters. He joined PwC in April 2020 after spending almost 20 years with the SEC.

Transcripts available upon r

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