Is segment information presented in conformity with FASB Statement 131 a non-GAAP financial measure under Regulation G and Item 10(e) of Regulation S-K?
Answer 18: No. Non-GAAP financial measures do not include financial measures that are required to be disclosed by GAAP. Section II.A.2.b of the adopting release lists “measures of profit or loss and total assets for each segment required to be disclosed in accordance with GAAP” as an example of such a measure. The measure of segment profit or loss and segment total assets under FASB Statement 131 is the measure reported to the chief operating decision maker for purposes of making decisions about allocating resources to the segment and assessing its performance. The example in the adopting release was not intended to be all-inclusive. As an additional example, because FASB Statement 131 requires or expressly permits the footnotes to the company’s consolidated financial statements to include specific additional financial information for each segment, that information also would be excluded from the definition of non-GAAP financial measures.
