About this episode
In each episode of our 2023 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance. This week, host Heather Horn sat down with PwC National Office partner Kevin Vaughn to discuss the SEC staff’s continued focus on non-GAAP measures, the area with the highest number of comments. In this episode, you’ll hear: 3:06 - The significance of non-GAAP measures and why they continue to be a focus area for the SEC 7:50 - Updates on new and amended compliance and disclosure interpretations (C&DIs) related to non-GAAP measures and their impact on comment letters 18:19 - Advice for preparers when responding to SEC staff comments 20:08 - Insights on pervasive comment letter themes, including: 20:27 - Undue prominence of non-GAAP measures 21:40 - Reconciliation of non-GAAP measures and the differentiation between recurring and non-recurring expenses 27:10 - Other top comment letter themes in non-GAAP comments, including nature of non-GAAP adjustments, disclosure requirements for non-GAAP measures, and labeling and identification of non-GAAP measures 35:23 - Recent enforcement actions related to non-GAAP measures 37:52 - Final advice on non-GAAP measures ahead to year-end reporting Want to learn more? Check out our analysis of SEC comments on non-GAAP measures and our publication on non-GAAP , which includes links to the updated C&DIs. Kevin Vaughn is a partner in PwC’s National Office. Prior to joining PwC, Kevin was senior associate chief accountant in the Office of the Chief Accountant (OCA) at the SEC where he spent almost 20 years focusing on complex financial reporting and technical accounting issues. Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting. Follow PwC’s accounting podcast on your favorite podcast app for future episodes in this SEC comment letters series, and subscribe to our weekly newsletter to get all of our thought leadership. Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com . Did you enjoy this episode? Text us your thoughts and be sure to include the episode name.