Are the proposed additional disclosures required in filings necessary in light of proposed Regulation G?
Much of the coverage of the proposed amendments to Item 10 of Regulation S-K, Item 10 of Regulation S-B, and Form 20-F is duplicative of the proposed Regulation G. However, if the Commission wishes to incorporate the more extensive and detailed disclosures and prohibitions not required by Regulation G, then the proposed amendments to Regulations S-K and S-B and Form 20-F are necessary. Alternately, we recommend that Regulation G require management discussion and analysis of the additional information provided by the non-GAAP measures and the ways in which the company uses the non-GAAP measures. • Consistent with current staff policy, our proposal would prohibit the use of non-GAAP per-share measures. Is such a prohibition necessary, or would it suffice to reconcile both the numerator and denominator of the non-GAAP per-share measure with comparable GAAP measures, respectively? It would suffice to reconcile both the numerator and denominator of the non-GAAP per-share measure with compar
