SEC Non-GAAP Measures and Metrics Comments

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Upon the successful completion of this program, the participant will be able to:

·      Recall the SEC’s guidance for the use of non-GAAP financial measures, key performance indicators and metrics contained in Regulation G, Regulation S-K Item 10(e), Compliance and Disclosure Interpretations (C&DIs), the CorpFin Financial Reporting Manual, and Financial Release 87.

·      Apply the SEC’s non-GAAP measure guidance by reviewing actual SEC comment letters and company responses.

·      Use the list of most frequent SEC non-GAAP financial measure comments to help avoid receiving SEC comments on non-GAAP measures.

Course Overview:

This program will focus on:

• Review of the SEC’s guidance for the use of non-GAAP measures and metrics:
  • Regulation G
  • Regulation S-K Item 10(e)
  • Compliance and Disclosure Interpretations
  • CorpFin Financial Reporting Manual
  • Financial Release 87 – key performance indicators and metrics
• Enumeration of frequent comment issues for non-GAAP measures
• Review and discussion of detailed real-world examples
  • Company disclosures
  • Subsequent SEC comments
  • Company responses and SEC follow-on comments
• Summary of overall considerations and conclusions from examples
• Discussion of how to avoid non-GAAP measures and metrics comments

CPE Program Level: Update 

Intended Audience: CPAs, accountants, attorneys, and other allied professionals who deal with SEC reporting and disclosure and related accounting issues, including chief financial officers (CFOs), controllers and their staff, internal auditors, partners of public accounting firms and their staff, in-house counsel, and outside attorneys.

Prerequisites:  A basic understanding of the SEC’s non-GAAP requirements.

Advanced Preparation: None

Instructional Method: QAS Self-Study

Updated: November 2024

Credit Information: 1 CPE credit is available upon completion of this program’s 3 content-review questions and a minimum passing score of 70% on the 5-question final exam.