This site uses cookies to provide you with a more responsive and personalised service. By using this site you agree to our use of cookies. Please read our cookie notice (http://www2.deloitte.com/ca/en/legal/cookies.html) for more information on the cookies we use and how to delete or block them.
The full functionality of our site is not supported on your browser version, or you may have 'compatibility mode' selected. Please turn off compatibility mode, upgrade your browser to at least Internet Explorer 9, or try using another browser such as Google Chrome or Mozilla Firefox.

Trends in SEC Non-GAAP Comment Letters 2016-2018

  • United States Image

Oct 16, 2018

On October 16, 2018, Audit Analytics published an article looking at the trends of comment letters issued referencing form types 10-K, 10-K/A 10-Q, 10-Q/A and 8-K filings from January 2010 through June 2018. Their research shows an inverse relationship in the overall number of comment letters issued and the percent of letters referencing non-GAAP issues.

Here are the key findings:

  • The overall number of comment letters issued by the SEC has decreased since 2010
  • The percentage of comment letters referencing a non-GAAP metric increased through 2017, but has been trending downward in the first 6 months of 2018
  • The number and percentage of non-GAAP comment letters declined in 2018, while remaining above the 2015 level
  • The ratio of non-GAAP letters that focus on tailored accounting increased from 6.5% in the last 6 months of 2016 to 12.3% in the first 6 months of 2018, while the total number of comment letters in the same periods decreased from 2,876 to 1,475

Review the full article on Audit Analytics' website.

Correction list for hyphenation

These words serve as exceptions. Once entered, they are only hyphenated at the specified hyphenation points. Each word should be on a separate line.