Firm Memoranda

SEC Updates Guidance on Non-GAAP Financial Measures

Date: 01/29/10

On January 11, 2010, the Securities and Exchange Commission ("SEC" or "Commission") released Compliance and Disclosure Interpretations ("C&DIs") regarding the use of non-GAAP financial measures, replacing the frequently asked questions released in 2003 ("2003 FAQs"). The C&DIs provide additional guidance and clarification, and encourage registrants to include non-GAAP financial information in public disclosures and SEC filings that are in compliance with Regulation G2 and Item 10(e)3 of Regulation S-K.

SEC Updates Guidance on Non-GAAP Financial Measures.pdf (pdf | 118.16 KB )