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Trends in SEC Non-GAAP Comment Letters 2016-2018

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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.

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