Pwc's Cfodirect Podcast

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 SEC7:50 - Updates on new and amended compliance and disclosure interpretations (C&DIs) related to non-GAAP measures and their impact on comment letters18:19 - Advice for preparers when responding to SEC staff comments20:08 - Insights on pervasive comment letter themes, including:20:27 - Undue prominence of non-GAAP measures21:40 - Reconciliation of non-GAAP measures and the differentiation between recurring and non-recurring expenses27:10 - Other top comment letter themes in non-GAAP comments, including nature of non-GAAP adjustme