SEC Staff Continues to Put Pressure on Non-GAAP Adjustments That It Views As Normal Operating Expenses

In December 2022, the Securities and Exchange Commission (SEC)’s Division of Corporation Finance staff updated its Compliance and Disclosure Interpretations on several disclosure issues involving non-GAAP financial measures. One of these updates is related to Question 100.01 of the Non-GAAP C&DIs, which covers the situation in which certain adjustments could be viewed as misleading, particularly when a non-GAAP performance measure excludes normal, recurring, cash operating expenses.