SEC Comment Letters on Firms' Use of Non-GAAP Measures: The Determinants and Firms' Responses

2019 ◽  
Vol 34 (2) ◽  
pp. 167-184 ◽  
Author(s):  
Koren M. Jo ◽  
Shuo Yang
Keyword(s):  
Securities And Exchange Commission ◽  
Earnings Differentials ◽  
Generally Accepted Accounting Principles ◽  
Accounting Principles ◽  
Earnings Releases ◽  
Comment Letters ◽  
To Receive ◽  
Jel Classifications

SYNOPSIS This paper explores Securities and Exchange Commission comment letters that address firms' use of non-Generally Accepted Accounting Principles (GAAP) measures in 10-Ks, 10-Qs, and earnings releases. We investigate the determinants of firms' receiving non-GAAP comments and the revisions to non-GAAP reporting undertaken by these recipients. Firms that experience poor GAAP performance and emphasize non-GAAP measures are more likely to receive non-GAAP comments. Recipients of non-GAAP comments are more likely than other reviewed firms to abandon non-GAAP measures in future filings. When recipients of non-GAAP comments continue to report non-GAAP measures, they provide more justifications for the use and reduce the prominence of these measures. However, higher non-GAAP earnings and GAAP earnings differentials do not appear to attract non-GAAP comments. In addition, the amount of non-GAAP exclusions does not decrease after the receipt of non-GAAP comments. Overall, our findings suggest that non-GAAP comments are effective in deemphasizing non-GAAP measures. JEL Classifications: M41, M48.

Bringing order to non-GAAP financial measures: SEC sues to enforce “equal-or-greater-prominence” requirement

2019 ◽  
Vol 20 (4) ◽  
pp. 51-57
Author(s):  
Richard J. Parrino
Keyword(s):  
Design Methodology ◽  
Securities And Exchange Commission ◽  
Content Type ◽  
Financial Measures ◽  
Generally Accepted Accounting Principles ◽  
Enforcement Action ◽  
Accounting Principles ◽  
Depth Analysis ◽  
The Us ◽  
Earnings Releases

Purpose This article examines the first action by the US Securities and Exchange Commission to enforce the “equal-or-greater-prominence” requirement of its rules governing the presentation by SEC-reporting companies, in their SEC filings and earnings releases, of financial measures not prepared in accordance with generally accepted accounting principles (GAAP). Design/methodology/approach This article provides an in-depth analysis of the equal-or-greater-prominence rule and the SEC’s enforcement posture in the context of the SEC’s concern that some companies present non-GAAP financial measures in a manner that inappropriately gives the non-GAAP measures greater authority than the comparable GAAP financial measures. Findings Although the appropriate use of non-GAAP financial measures can enhance investor understanding of a company’s business and operating results, investors could be misled about the company’s GAAP results by disclosures that unduly highlight non-GAAP measures. The SEC’s enforcement action signals a focus on the manner in which companies present non-GAAP financial measures as well as on how they calculate the measures. Originality/value This article provides expert guidance on a major SEC disclosure requirement from an experienced securities lawyer.

scholarly journals US GAAP en de jaarrekening van Nederlandse ondernemingen

2004 ◽  
Vol 78 (11) ◽  
pp. 489-496
Author(s):  
R. W. Bakker ◽  
Ruud Vergoossen
Keyword(s):  
United States ◽  
Securities And Exchange Commission ◽  
Generally Accepted Accounting Principles ◽  
Accounting Principles ◽  
Onderzoek Naar ◽  
Verenigde Staten ◽  
Mate Waarin ◽  
Us Gaap

In dit artikel wordt verslag gedaan van een onderzoek naar de mate waarin Nederlandse ondernemingen met een beursnotering in de Verenigde Staten de United States Generally Accepted Accounting Principles (US GAAP) toepassen in hun in Nederland gepubliceerde jaarrekening. Daartoe is onderzocht in hoeverre deze ondernemingen in de periode 1995-2002 grondslagwijzigingen hebben doorgevoerd die leiden tot het (meer) toepassen van US GAAP en is nagegaan wat de belangrijkste verschillen tussen US GAAP en de Nederlandse verslaggevingsregels zijn zoals die blijken uit de jaarrekening 2002. Bovendien omvat het onderzoek een vergelijking van de additionele informatieverschaffing in de in Nederland gepubliceerde jaarrekening 2002 en de jaarrekening 2002 zoals opgenomen in het Form 20-F dat bij de Securities and Exchange Commission is gedeponeerd. De onderzoeksresultaten worden vergeleken met eerder soortgelijk onderzoek. Hoewel de in het onderzoek betrokken ondernemingen meer en meer waarderings- en resultaatbepalingsgrondslagen toepassen die in overeenstemming zijn met US GAAP, wordt het aantal in de aansluitingsoverzichten opgenomen afwijkingen tussen de cijfers op basis van US GAAP en die op basis van de Nederlandse verslaggevingsregels niet kleiner, maar juist groter. Daarnaast blijkt dat veel additionele informatie die in de Verenigde Staten verplicht is, ook steeds vaker terechtkomt in de in Nederland gepubliceerde jaarrekening.

Analyst Following and Forecast Accuracy After Eliminating the 20-F Reconciliation Between IFRS and U.S. GAAP

2020 ◽  
pp. 0148558X2094464
Author(s):  
Wen Li ◽  
Huai Zhang
Keyword(s):  
Financial Reporting ◽  
Financial Analysts ◽  
Forecast Accuracy ◽  
Financial Statements ◽  
Securities And Exchange Commission ◽  
Analyst Following ◽  
Analyst Coverage ◽  
Generally Accepted Accounting Principles ◽  
Financial Reporting Standards ◽  
Accounting Principles

In 2007, the U.S. Securities and Exchange Commission (SEC) decided to allow foreign private issuers to file financial statements prepared according to International Financial Reporting Standards (IFRS) without reconciliation to U.S. Generally Accepted Accounting Principles (GAAP). Using a sample of foreign private issuers from 35 countries/regions during the period of 2005 to 2008, this article investigates how the elimination of the 20-F reconciliation affects financial analysts. We find that it significantly reduces analyst coverage but has no impact on forecast accuracy. We show that analysts who are greatly affected are more likely to terminate their coverage of IFRS firms after the SEC’s rule than other analysts. In addition, we hypothesize and find that eliminating the 20-F reconciliation has a greater impact on firms whose 20-F reconciliation is more useful to analysts. For these firms, the elimination of the 20-F reconciliation significantly reduces both analyst coverage and forecast accuracy. Overall, our results suggest that the elimination of the 20-F reconciliation imposes costs on financial analysts.

scholarly journals Ajustes aos US-GAAPS: estudo empírico sobre sua relevância para empresas brasileiras com ADRs negociados na bolsa de Nova Iorque

2007 ◽  
Vol 18 (spe) ◽  
pp. 45-57 ◽  
Author(s):  
Fábio Moraes da Costa ◽  
Alexsandro Broedel Lopes
Keyword(s):  
United States ◽  
Securities And Exchange Commission ◽  
Generally Accepted Accounting Principles ◽  
Accounting Principles ◽  
Us Gaap

A relevância das informações disponibilizadas ao mercado por empresas brasileiras com American Depositary Recepts (ADRs) negociados na Bolsa de Nova Iorque foi avaliada neste trabalho. Essas empresas devem atender à exigência da Securities and Exchange Commission e elaborar suas demonstrações contábeis de acordo com os United States Generally Accepted Accounting Principles (US-GAAP) até 30 de junho, anualmente. Diante desse fato, dois conjuntos de informações estão disponíveis, promovendo a base de dados para o estudo da relevância das variáveis lucro líquido e patrimônio líquido para o período entre 1999 e 2003. Após a utilização do modelo desenvolvido por Ohlson (1995) e de seus desdobramentos posteriores, os resultados evidenciam que (1) as informações elaboradas segundo os princípios de contabilidade geralmente aceitos no Brasil são relevantes; (2) as informações em US-GAAP disponibilizadas em junho possuem menor ou igual relevância do que as divulgadas em abril e (3) os ajustes aos US-GAAP efetuados no patrimônio líquido são relevantes para o mercado de capitais brasileiro.

An analysis of SEC comment letters and IFRS

2017 ◽  
Vol 15 (2) ◽  
pp. 226-244 ◽  
Author(s):  
Cheryl L. Linthicum ◽  
Andrew J. McLelland ◽  
Michael A. Schuldt
Keyword(s):  
Financial Reporting ◽  
Accounting Standards ◽  
Securities And Exchange Commission ◽  
Annual Reports ◽  
Financial Accounting Standards Board ◽  
Content Type ◽  
Generally Accepted Accounting Principles ◽  
Financial Reporting Standards ◽  
The Usa ◽  
Comment Letters

Purpose This study investigates the influence of the Securities and Exchange Commission (SEC) on the interpretation and application of International Financial Reporting Standards (IFRS) by examining a group of SEC-selected foreign private issuers filing 2005 annual reports in the USA and reporting using IFRS for the first time. Design/methodology/approach This paper uses hand-collected information from SEC comment letters to analyze IFRS topics and documents the ultimate resolution of each SEC comment (no change to filing, current change to filing or prospective change to future filing). The authors use descriptive statistical analyses, as well as a logistic regression model involving the resolution of each SEC comment, to examine the SEC’s influence on the interpretation of IFRS. Findings The study finds both higher comment totals, and higher numbers of required filing modifications, for those IFRS pronouncements which were identified as needing improvement during the 2006-2008 convergence efforts by the International Accounting Standards Board (IASB) and the US Financial Accounting Standards Board (FASB). Additionally, the study documents a decreasing likelihood of a filing modification when US generally accepted accounting principles (US GAAP) guidance is referenced in comment letter correspondence involving IFRS topics. Originality/value The study extends the IFRS literature and the SEC comment letter literature by focusing on the resolution of comments directed at IFRS disclosures, as well as exploring the factors which influence whether a comment ultimately requires a filing modification.

New compliance guidance by SEC staff signals increased scrutiny of non-GAAP financial measures

2016 ◽  
Vol 17 (4) ◽  
pp. 23-33 ◽  
Author(s):  
Richard J. Parrino
Keyword(s):  
Design Methodology ◽  
Operating Performance ◽  
Securities And Exchange Commission ◽  
Appropriate Use ◽  
Content Type ◽  
Financial Measures ◽  
Generally Accepted Accounting Principles ◽  
Accounting Principles ◽  
Depth Analysis ◽  
Disclosure Requirement

Purpose This article examines compliance and disclosure interpretations issued by the staff of the Securities and Exchange Commission in May 2016 that provide guidance to SEC-reporting companies on how they can use financial measures not prepared in accordance with generally accepted accounting principles in a manner that complies with SEC rules governing the presentation of non-GAAP measures in SEC filings and other public communications. Design/methodology/approach This article provides an in-depth analysis of the new interpretive guidance in the context of the increasing use of non-GAAP financial measures by SEC-reporting companies and the SEC’s concern that some companies have been using non-GAAP measures inappropriately to present a materially different picture of their operating performance than investors can discern from financial measures prepared in accordance with GAAP. Findings Although the appropriate use of non-GAAP financial measures can enhance investor understanding of a company’s business and operating results, a relatively permissive SEC attitude towards the use of non-GAAP measures in recent years has emboldened some companies to increase their reliance on non-GAAP measures in a manner the SEC views as inconsistent with its rules. The SEC staff’s new guidance signals a renewed focus by the SEC on compliance with its requirements concerning the nature of permissible non-GAAP measures and the ways in which companies should present those measures. Originality/value This article provides expert guidance on a major new SEC disclosure requirement from experienced securities lawyers.

FUNDS STATEMENTS: THE ACCOUNTING PRINCIPLES BOARD WAS TWICE BEHIND THE CURVE

2015 ◽  
Vol 42 (2) ◽  
pp. 91-102 ◽  
Author(s):  
Stephen A. Zeff
Keyword(s):  
New York ◽  
Stock Exchange ◽  
Securities And Exchange Commission ◽  
New York Stock Exchange ◽  
Accounting Principles ◽  
York Stock Exchange

This paper discusses the circumstances in which the Accounting Principles Board (APB) issued Opinions 3 and 19, in 1963 and 1971, respectively, when the Board encouraged and then required companies to publish a statement of source and application of funds, known as the funds statement. In doing so, the Board both times lagged behind company practice and the views of influential organizations, including the New York Stock Exchange and the Securities and Exchange Commission.

THE SEC PREEMPTS THE ACCOUNTING PRINCIPLES BOARD IN 1965: THE CLASSIFICATION OF THE DEFERRED TAX CREDIT RELATING TO INSTALLMENT SALES

2007 ◽  
Vol 34 (1) ◽  
pp. 1-23 ◽  
Author(s):  
Stephen A. Zeff
Keyword(s):  
Securities And Exchange Commission ◽  
Accounting Practice ◽  
Slow Pace ◽  
Accounting Principles ◽  
Private And Public ◽  
Deferred Tax ◽  
Accounting Procedure ◽  
The U.S ◽  
Do So

In 1959, the Accounting Principles Board (APB) replaced the Committee on Accounting Procedure because the latter was unable to deal forthrightly with a series of important issues. But during the APB's first half-dozen years, its record of achievement was no more impressive than its predecessor's. The chairman of the Securities and Exchange Commission (SEC), Manuel F. Cohen, criticized the APB's slow pace and unwillingness to tackle difficult issues. This article discusses the circumstances attending the SEC's issuance of an Accounting Series Release in late 1965 to demonstrate forcefully to the APB that, when it is unable to carry out its responsibility to “narrow the areas of difference” in accounting practice, the SEC is prepared to step in and do so itself. In this sense, the article deals with the tensions between the private and public sectors in the establishment of accounting principles in the U.S. during the mid-1960s. The article makes extensive use of primary resource materials in the author's personal archive, which have not been used previously in published work.

An Exploratory Study of the Valuation Properties of Cross-Listed Firms' IAS and U.S. GAAP Earnings and Book Values

2002 ◽  
Vol 77 (1) ◽  
pp. 107-126 ◽  
Author(s):  
Hollis Ashbaugh ◽  
Per Olsson
Keyword(s):  
Exploratory Study ◽  
Accounting Standards ◽  
Equity Market ◽  
Residual Income ◽  
International Accounting Standards ◽  
Generally Accepted Accounting Principles ◽  
Listed Firms ◽  
Valuation Model ◽  
Accounting Principles ◽  
Book Values

Despite the increasing integration of global capital markets, there is little evidence on the valuation properties of cross-listed, non-U.S. firms' accounting variables. We use the relative performance of the earnings capitalization, the book value, and the residual income valuation models to explore the valuation properties of International Accounting Standards and U.S. Generally Accepted Accounting Principles earnings and book values reported by non-U.S., cross-listed firms trading in a common equity market. Using non-U.S./non-U.K. firms whose shares trade on the International Stock Exchange Automated Quotation system in London, we find that the earnings capitalization model is the dominant accounting-based valuation model when crosslisted firms report under International Accounting Standards. In contrast, we find that when cross-listed firms report under U.S. Generally Accepted Accounting Principles, the residual income model is the dominant accountingbased valuation model. Our exploratory study provides insights into the valuation implications of allowing a dual reporting system for foreign registrants trading in a common equity market.

scholarly journals We Are Not Publicly Traded And So The Rules Dont Apply Or Do They Should They?

2011 ◽  
Vol 8 (1) ◽  
pp. 103-106
Author(s):  
Kelly Noe
Keyword(s):  
Publicly Traded ◽  
Generally Accepted Accounting Principles ◽  
Accounting Principles ◽  
A Company ◽  
Privately Held

This paper presents a case study of the accounting practices of a company that is privately held. The company follows Generally Accepted Accounting Principles (GAAP) but has some questionable transactions. The paper then follows up with a discussion of baby-GAAP and possible consequences of two different GAAP options.

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