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SEC Comment Letter Process Non-GAAP Financial Measures

Troutman Pepper

SEC Comment Letter Update

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Overview - This article highlights comment letters publicly issued by the Securities and Exchange Commission (SEC) to Real Estate Investment Trusts (REITs) during 2022. The SEC issues comment letters in connection with...more

Bass, Berry & Sims PLC

Adjusting for Litigation Expenses in a Non-GAAP Financial Measure

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It should come as no surprise to readers of our blog that public companies often expend significant resources each year on managing litigation matters. As a result, perhaps it is natural that some companies might want to...more

Bass, Berry & Sims PLC

Recent SEC Comment Letters Of Interest Regarding COVID-19 Adjustments, SAB 99 And South Korea

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Subscribers to our blog know that we monitor EDGAR for new SEC comment letters and enjoy bringing attention to the more interesting ones. In today’s blog post, we bring you three new SEC comment letter exchanges. •In the...more

A&O Shearman

It Is Annual Report Time—Recent Developments and Trends for the Preparation of Form 20-F

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It is now time for foreign private issuers to prepare their annual reports on Form 20-F. For companies with a calendar year-end, the Form 20-F must be filed with the U.S. Securities and Exchange Commission (the SEC) by April...more

Bass, Berry & Sims PLC

5 Interesting Takeaways from Uber Technologies’ IPO SEC Comments

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While monitoring SEC comment letters, we recently came across the batch of SEC comment letters issued to Uber Technologies, Inc. in connection with its IPO registration statement that was declared effective on May 9, 2019. ...more

Mayer Brown Free Writings + Perspectives

Survey of Recent SEC Comment Letters to Mortgage REITs

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. ...more

A&O Shearman

It’s Annual Report Time—Recent Developments and Trends for the Preparation of Form 20-F - 2019

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It is now time for foreign private issuers to prepare their annual reports on Form 20-F. For companies with a calendar year-end, the Form 20-F must be filed with the U.S. Securities and Exchange Commission (the SEC) by 30...more

Opportune LLP

2018 SEC Comment Letter Trends & Disclosure Best Practices

Opportune LLP on

As we wind down the third quarter of 2018 and turn our attention toward year-end disclosures, it is helpful to review U.S Securities and Exchange Commission (SEC) comment letter trends to improve financial statement...more

Parker Poe Adams & Bernstein LLP

Recent SEC Comment Letter Trends

In January, I passed along a list of 12 review and comment priorities distributed at the 48th Annual Institute on Securities Regulation in New York by a panel of speakers that included SEC Chief Accountant Wesley Bricker and...more

Morrison & Foerster LLP

Practice Pointers: Anticipating and Addressing SEC Comments on Non-GAAP Financial Measures - February 2017

The use of non-GAAP financial measures by public companies continues to be an area of growing concern for the Securities and Exchange Commission (“SEC”). Since the staff of the SEC’s Division of Corporation Finance (the...more

A&O Shearman

Updated Non-GAAP Guidance: The First 150 Comment Letters

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In May of this year, the staff of the SEC’s Division of Corporation Finance updated its C&DIs regarding the use of non-GAAP financial measures. We summarized the May 2016 update in an earlier client publication. Since the...more

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