On May 17, 2016, the Division of Corporation Finance of the US Securities and Exchange Commission (SEC) issued a dozen new and updated Compliance and Disclosure Interpretations (C&DIs) on the use of non-GAAP financial measures. These C&DIs were effective immediately. As a result, companies very quickly needed to reflect the new guidance in their upcoming financial presentations.
Since then, SEC comment letters addressing issues raised by the new and updated interpretations, as well as companies’ responses to those comments, have become publicly available on the SEC’s website. In addition, companies have made initial efforts to comply with the new guidance. Accordingly, it’s time for companies to take a second look at the disclosures surrounding their use of non-GAAP financial measures and consider whether to make changes going forward to better address the SEC’s guidance.
Please join Mayer Brown lawyers Michael Hermsen, Laura Richman and Jessica Waller as they:
- Explain key aspects of the new and updated non-GAAP C&DIs
- Discuss recent SEC comment letters regarding non-GAAP financial measures
- Provide practical suggestions for ongoing compliance with SEC rules and guidance on non-GAAP financial measures
For additional information, please contact
Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.