SEC Comment Letters on Firms’ Use of Non-GAAP Measures: The Determinants and Firms’ Responses
41 Pages Posted: 27 Apr 2020 Last revised: 4 May 2020
Date Written: November 1, 2019
Abstract
This paper explores Securities and Exchange Commission comment letters that address firms’ use of non-Generally Accepted Accounting Principles (GAAP) measures in 10-Ks, 10-Qs, and earnings releases. We investigate the determinants of firms’ receiving non-GAAP comments and the revisions to non-GAAP reporting undertaken by these recipients. Firms that experience poor GAAP performance and emphasize non-GAAP measures are more likely to receive non-GAAP comments. Recipients of non-GAAP comments are more likely than other reviewed firms to abandon non-GAAP measures in future filings. When recipients of non-GAAP comments continue to report non-GAAP measures, they provide more justifications for the use and reduce the prominence of these measures. However, higher non-GAAP earnings and GAAP earnings differentials do not appear to attract non-GAAP comments. In addition, the amount of non-GAAP exclusions does not decrease after the receipt of non-GAAP comments. Overall, our findings suggest that non-GAAP comments are effective in deemphasizing non-GAAP measures.
Keywords: Comment Letter, Non-GAAP, Earnings Release
JEL Classification: M41, M48
Suggested Citation: Suggested Citation