Pwc's Cfodirect Podcast

2024 SEC comment letter trends: Non-GAAP measures

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Sinopsis

Did you enjoy this episode? Text us your thoughts and be sure to include the episode name.This final episode of our 2024 SEC comment letter podcast miniseries discusses non-GAAP measures. Non-GAAP measures are commonly used by companies as supplements to their financial statements to deepen investors’ understanding of their performance or financial condition. Given their importance, not only does non-GAAP top the list this year, but it’s been a top focus area for the SEC staff in the last several years, and we expect that trend to continue. We discuss the issues most frequently raised by the SEC staff and offer advice to preparers for getting ahead of them.  In this episode, we discuss: 3:11 – Overview of non-GAAP comment letter trends 9:09 – Insights into comments on basic compliance areas 22:24 – Individually tailored accounting principles   27:27 – Adjustments for cash operating expenses that are normal and recurring41:17 – Controls over non-GAAP measures46:12 – Advice and other considerations when respond