The Public Company Accounting Oversight Board (PCAOB) recently closed the comment period for its proposal (the Proposal) to significantly increase the responsibility of audit firms to evaluate and disclose a subject public company’s noncompliance with laws and regulations (commonly referred to as NOCLAR).Continue Reading The PCAOB Closes Comment Period on Controversial Proposal to Expand Auditor Responsibility for Legal Compliance
September 2023
SEC Comment Letters on Non-GAAP Measures
By Tatjana Paterno on
Posted in Disclosure, SEC Guidance
In a recent article for Agenda, I commented on the comment letters from the Securities and Exchange Commission (SEC) related to non-GAAP measures and what this focus could mean for audit committees. Continue Reading SEC Comment Letters on Non-GAAP Measures
Non-GAAP Comment Letters: SEC Areas of Focus
By Justin Hay, Logan McCallie & Tatjana Paterno on
Posted in Disclosure, SEC Guidance
On December 13, 2022, the Securities and Exchange Commission (SEC) issued seven new or revised Compliance and Disclosure Interpretations (C&DIs) on topics regarding the use of non-GAAP financial measures in SEC filings. Typically, the release of C&DIs, whether new or revised, indicates that a certain subject will be an area of heightened focus in SEC comment letters and enforcement actions.Continue Reading Non-GAAP Comment Letters: SEC Areas of Focus