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Non-GAAP Financial Measures: Disclosure and Other Controls & Procedures

By Randi Morrison posted 01-21-2019 10:24 PM

  

Among the several noteworthy non-GAAP takeaways from this Paul Weiss memo on the AICPA Conference is that SEC Staff "may request information provided to registrants' boards to support statements that non-GAAP financial measures are used to assess business or operating performance." While that makes sense, not all companies' documentation and other practices/policies may currently be well-positioned for this potential "ask." This is a good prompt for taking a fresh look at your non-GAAP policies & procedures, including audit committee oversight and related documentation, to determine whether they may warrant tweaking.

          See also these prior reports: "AICPA Conference: SEC & PCAOB Developments Round-Up," "AICPA Conference: PCAOB Speaks!", "AICPA Conference: SEC Speaks!", and additional information & resources on our Financial Reporting page. This post first appeared in the weekly Society Alert!

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