Are statements of cash flows non-GAAP statements and do they require explicit reconciliation to GAAP?
• It may be useful to require that any non-GAAP information, not just accompanying detail, be posted on the company’s website. This website should be registered with the SEC and any change of the website address should be immediately notifiable. The SEC should maintain a current registry of all website addresses. The website address should be provided with any released financial information. Since storage space is so inexpensive today, an SEC site for releases as well as periodic required filings would provide a convenient central repository. Hence when any release is made it must be released by upload to the SEC repository. It is recommended that indexing information be included (company name, release date, type of filing, defined importance rating, responsible party, etc.). It is also recommended that some common format be adopted such as PDF, plain text, MS Word of XBRL. Searchable text is preferred to scanned or image files. • It is noteworthy that “If the GAAP financial measure is