Does the proposed definition of “non-GAAP financial measure” capture non-GAAP information where enhanced disclosure is appropriate?
Does the proposed definition capture the pro forma financial information that the Sarbanes-Oxley Act targets? Should Regulation G apply to disclosures of material information including any financial measure calculated and presented otherwise than in accordance with GAAP? Is the proposed definition otherwise too narrow or too broad? If so, how should it be changed? We believe that the basic definition of “non-GAAP financial measures” is appropriate. We do not agree with Item 10 proposal which would restrict a registrant from adjusting a non-GAAP performance measure to eliminate or smooth items identified as non-recurring, infrequent or unusual, when the nature of the charge or gain is such that it is reasonable likely to recur. If management looks to view an operation on the basis of “core earnings” and therefore wishes to eliminate those items which are not part of their regular business, we believe that it is appropriate that investors are able to obtain this information and be able t
Related Questions
- Have we appropriately tailored the proposed definition of the term "off-balance sheet arrangement" and the proposed disclosure to filter out disclosure that is unimportant to investors?
- Does the proposed definition of "non-GAAP financial measure" capture non-GAAP information where enhanced disclosure is appropriate?
- What will the Board do if the proposed definition of fair value is not appropriate in a particular situation?
