The SEC’s Division of Corporation Finance recently released updates to several Compliance & Disclosure Interpretations ("C&DIs") related to the use of non-GAAP measures. The revised C&DIs generally cover:
- The types of adjustments and presentations that may result in a non-GAAP measure being misleading; and
- The types of presentations that would be deemed to give undue prominence to a non-GAAP measure, in violation of Item 10(e)(1)(i)(A) of Regulation S-K.
The affected C&DIs are 100.01, 100.04, 100.05, 100.06, and 102.10.