6.4 Consideration of SEC Guidance on Non-GAAP Measures
A registrant should also be mindful of the SEC’s guidance on non-GAAP measures applicable to the
financial information presented in its filing. Financial measures that a registrant must disclose under
U.S. GAAP are not considered non-GAAP measures under the SEC’s guidance. The most common
examples of such measures are related to segment financial information such as revenue, profit or
loss, and total assets for each reportable segment. (See the discussion in Section 4.2.1 of reporting considerations for entities with a single reportable segment and the discussion in Section 4.4 of the basis for
presentation of segment measures.) However, a registrant should ensure that reported amounts are
consistent with the measures required to be reported under ASC 280. Any aggregation of individual
segment amounts or other segment information voluntarily provided outside the footnotes (e.g., in
MD&A) would be within the scope of the SEC’s guidance on non-GAAP measures.
Also see Section
2.5 of Deloitte’s Roadmap Non-GAAP Financial Measures and Metrics
for further considerations.