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
Counsel Brian Hirshberg examines some of the issues raised in comment letters issued by the SEC staff to real estate investment trusts regarding their use of financial measures not presented in accordance with generally...more
On October 16, the SEC Division of Investment Management granted no-action relief in response to a request by Orrick on behalf of Redwood Trust. The Redwood request and the SEC staff response impact the way in which...more