Survey of Recent SEC Comment Letters to Mortgage REITs

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In recent years, the Staff of the Securities and Exchange Commission (the “SEC”) has been providing comments regarding companies’ presentations of non-GAAP financial measures in public filings.  Working with Audit Analytics, we surveyed SEC Staff comment letters provided to mortgage real estate investment trusts (“REITs”) in 2018 and 2017 and observed a significant increase in the Staff’s focus on the use of non-GAAP financial measures by mortgage REITs.  The comments issued relate largely to the improper labeling of non-GAAP financial measures (such as core earnings) and the failure to reconcile a non-GAAP financial measure used with its GAAP counterpart.  See an illustration of the survey’s findings below.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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