SEC now: Non-GAAP 2025 comment letter trends

We continue our SEC-focused series with an episode on non-GAAP financial measures, commonly used by companies to supplement their financial statements and provide investors with a deeper understanding of their performance or financial condition. Given their importance, it’s been a top focus area for the SEC staff over the last several years, and we expect that trend to continue. We highlight common comment letter themes and share practical guidance for year-end reporting and comment letter responses.

In this episode, we discuss:

• 2:17 – Overview of non-GAAP measures 
• 6:20 – SEC comment letter trends and recurring issues
• 23:15– Possible shifts in focus under the new SEC administration
• 27:35 – Year-end reminders and best practices for responding to SEC comments

In case you missed it, check out our first episode in this SEC-focused series: SEC now: Today’s landscape and recent developments.

For more on the SEC, listen to our recent episode on frequency of reporting, SEC to revisit quarterly reporting: Pros, cons, and what’s ahead. Also, check out our SEC reporting series from earlier this year where we take a “back to basics” look at key reporting areas:

• Inside SEC reporting: Capital formation
• Inside SEC reporting: Acquisitions and divestitures
• Inside SEC reporting: Pro forma financial information
• Inside SEC reporting: Form 8-K (current report)

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Our guests are Kevin Vaughn, a PwC National Office partner specializing in SEC reporting matters, and John Ly, a PwC National Office managing director within the SEC & Capital Markets group.

Our host is Kyle Moffatt, PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. 

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com

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