Deloitte recently posted an excellent study regarding SEC comment letter trends.
The Deloitte study highlights the significant increase in 2016 in SEC comments regarding non-GAAP financial measures, which is no surprise in light of the SEC's public comments regarding this issue and the new SEC guidance (C&DIs) released in May 2016, and is consistent with trends we have been seeing. Registrants should continue to be mindful of the focus of the SEC (both the Division of Corporation Finance in relation to the SEC comment letter process and the Division of Enforcement) on this issue.
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