Appendix J — Roadmap Updates for 2023
The table below summarizes the
substantive changes made in the 2023 edition of this Roadmap.
|
Section
|
Title
|
Description
|
|---|---|---|
|
Added
discussion related to the revisions made to the SECs
interpretive guidance (C&DIs) in December 2022 and
updated discussions related to prominence and misleading
measures in line with these updates.
| ||
|
Overview and
History of the SEC’s Guidance on Non-GAAP Measures and
Metrics
|
Added
discussion related to the new and updated C&DIs issued
in December 2022.
| |
|
Overview and General
Requirements of Regulation G and Item 10(e)
|
Added a
Changing Lanes that
addresses the application of non-GAAP rules when a glossy
annual report or 10-K wrap is furnished with the SEC in
accordance with the SEC's updated requirement in its June
2022 final rule.
| |
|
Presentation
of Equal or Greater Prominence Most Directly Comparable
Measure
|
Added a
Changing Lanes
that explains the updates to C&DI Question 102.10.
Updated the discussion to reflect these changes.
| |
|
3.5
|
Labeling
Non-GAAP Measures and Reconciling Items
|
Deleted and
moved the discussion to Section 4.3.4.
Renumbered subsequent sections.
|
|
4.2.1
|
Presentation
in MD&A of Comparable Periods Under ASC 606
|
Section
deleted because of obsolescence, since ASC 606 is effective
for all periods that are included in the financial
statements. Renumbered subsequent section.
|
|
What Is a
Potentially Misleading Non-GAAP Measure?
|
Added a
Changing Lanes
that explains the SEC’s December 2022 updates to C&DI
questions on potentially misleading non-GAAP measures.
Updated for
C&DI Questions 100.01 and 100.04 and added information
on new C&DI Questions 100.05 and 100.06 on the basis of
these updates.
| |
|
Normal,
Recurring Cash Operating Expenses
|
Updated for
the changes made to C&DI Question 100.01 in the SEC’s
December 2022 updates.
| |
|
Labeling
Non-GAAP Measures and Reconciling Items
|
New section
that incorporates content from previous Sections 3.5
(Labeling Non-GAAP Measures and Reconciling Items) and 4.9
(Considerations Related to Labeling Non-GAAP Measures).
Updates the discussion for the issuance of C&DI Question
100.05 in December 2022.
| |
|
4.9
|
Considerations Related to Labeling Non-GAAP Measures
|
Deleted and
moved to Section
4.3.4. Previous Section 4.9.1 renumbered as new
Section 4.9,
Non-GAAP Measures That Exclude Depreciation and Amortization
From Cost of Sales.
|
|
Compliance
and Disclosure Interpretations — Non-GAAP Financial
Measures
|
C&DI
Questions 100.01, 100.04, and 102.10 were updated, and
C&DI Questions 100.05 and 100.06 were added to reflect
the changes the SEC made in December 2022.
|