Focus for Q2: Practical Tips for “Self-Correcting” Non-GAAP Disclosure in Light of the SEC’s Updated Guidance
In the wake of its release on May 17, 2016 of updated Compliance and Disclosure Interpretations (“CDIs”) relating to the disclosure of non-GAAP financial measures, the SEC’s Division of Corporation Finance has indicated in no uncertain terms that now is the time for companies to review their non-GAAP measures and make any revisions called for by the new guidance. To assist companies in this review, we have attached, in Appendix A, a blackline of the new and revised CDIs against the previous version of the CDIs and, in Appendix B, excerpts from previous comment letters that serve as harbingers of things to come.
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