Appendix J — Roadmap Updates for 2021 | DART – Deloitte Accounting Research Tool

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Appendix J — Roadmap Updates for 2023

The table below summarizes the substantive changes made in the 2023 edition of this Roadmap.

Section	Title	Description
On the Radar		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.
1.1	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.
3.1	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.
3.3	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.
4.3	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.
4.3.1	Normal, Recurring Cash Operating Expenses	Updated for the changes made to C&DI Question 100.01 in the SEC’s December 2022 updates.
4.3.4	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.
Appendix G	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.

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This SEC Reporting Interpretations manual provides comprehensive guidance; however, the manual does not address all possible fact patterns, and the guidance is subject to change. Consult a Deloitte & Touche LLP professional regarding your specific issues and questions.