SEC Professionals Groups

We partnered with MyLogIQ to share thought leadership on non-GAAP reporting compliance.

Below is a summary of their two recent non-GAAP comment letter reports.

MyLogIQ’s first report examines comment letters on 18 non-GAAP issues released January 2022-May 2023.

MyLogIQ’s second report drills down into Question 100.04 individually tailored accounting measures.

MyLogIQ’s key findings from the two reports were that:

• Three of the five issues updated in the 2022 guidance made up nearly two-thirds of all non-GAAP comment letters. The top three were:

• Prominence of non-GAAP measures.

• Recurring expenses.

• Question 100.04 individually tailored accounting measures rounded out the top three.

• The top three sectors receiving Question 100.04 letters were:

• Technology & Communications

• Financials

• Services.

• Question 100.04 comment letters revealed that revenue was the top item cited in questions about individually tailored accounting measures.
  
  

Download the reports:

• A Survey of Non-GAAP Comment Letters 

• Non-GAAP Question 100.04 Comment Letters: Individually Tailored Accounting Measures.