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To GAAP or to non-GAAP? That is the question. And we share insights to help you decide. We’re launching into November with some new content, most notably, a publication on non-GAAP measures summarizing the guidance and SEC staff comments. Be sure to check it out along with our other insights this week.
Ahead of year-end reporting, we share a helpful summary of the latest thinking on non-GAAP measures. Our publication summarizes the guidance applicable to non-GAAP measures, why they are relevant, and the focus of SEC staff comments on them.

Non-GAAP measures are not the only focus area of the SEC staff. We have updated our SEC comment letter trends series with comments issued through September 30. See what else the SEC staff may be looking for in your filings.

Appeals court sends share repurchase disclosure rule back to SEC
This week, an appeals court sent the SEC share repurchase disclosure rule originally adopted in May back to the SEC, giving it 30 days to remedy the deficiencies in the rule. The rule remains in effect until the SEC’s response is evaluated by the court. We’ve updated our summary of the final rule for the latest developments.
What is the financial reporting ecosystem, you may ask? Host Heather Horn was joined by Tom Barbieri, PwC US chief accountant; Kevin Vaughn, PwC National Office partner; and Ying Compton, PwC managing director, to unpack it. They address its importance to the capital markets and how preparers can stay engaged.

Continuing our podcast miniseries spotlighting the Corporate Sustainability Reporting Directive, or CSRD, we discuss options a company may have in its approach to reporting under the EU’s sustainability reporting standards. In this episode, host Heather Horn welcomes back Emily Kirsch, director in PwC’s sustainability practice, to share practical considerations in a company’s determination of the most effective reporting approach for its organization.
"It's not a small undertaking; making the reporting decision as soon as possible will give companies more time to design and determine the systems and processes and controls that need to be put in place." - Emily Kirsch, PwC sustainability services director
For additional resources on CSRD, our Netherlands firm has created a series of videos. This video looks at the scope of CSRD and discusses situations that illustrate the complexity of the regulations.

PwC generally supports the proposed amendments but recommends clarifications and suggests alternatives in certain areas.
For more on the “DISE” project, read our summary, Don't roll the DISE on the FASB's expense disaggregation project.

We've updated the chapter on net periodic benefit cost in our Pensions and employee benefits guide to clarify the definition of an "inactive" plan participant. Access it on Viewpoint or download the full guide PDF.

White House mobilizes push for responsible adoption of AI
The Biden administration issued a directive on artificial intelligence, a big step towards defining how the fast-moving technology will be used and regulated. Companies should understand the potential impacts, assess the risks and opportunities, and prepare for compliance.

PwC’s CPE-eligible webcasts
Join us beginning next week for National Office webcasts:
  • Q4 2023 Quarterly sustainability webcast—11/9 or 11/15
    With sustainability reporting becoming mandatory in a growing number of countries, we help you stay current on the latest ESG accounting and reporting developments in the US and abroad. Joining us as keynote speaker is Katie McGinty, VP & Chief Sustainability, External Relations Officer at Johnson Controls, sharing insights on the importance of a sustainability-focused business strategy. We’ll also discuss accounting for environmental credits, updates on IRS guidance for utilization of Inflation Reduction Act energy incentives, and developments in US and global sustainability disclosure requirements. Register to earn up to 1.5 CPE credits.
  • Q4 2023 Quarterly accounting webcast—12/13, 12/15, or 12/19
    Join our quarterly webcast to hear key accounting and reporting reminders, including those discussed at the AICPA & CIMA Conference on Current SEC and PCAOB Developments, as companies close out the year. Register to earn up to 1.5 CPE credits.
Other PwC webcasts
  • Tax transparency and sustainability reporting in 2023—11/30
    A recently published study provides a comprehensive overview of the trends and challenges in tax transparency and sustainability reporting across 8 countries. Our upcoming webcast addresses how the study can help you benchmark your performance, identify best practices, and anticipate future developments in this rapidly evolving field. Register here.
Recent releases
In case you missed it – top October content
Here’s what we’re following
GAO concludes that SAB 121 is a “rule” under the Congressional Review Act
This week, the Government Accountability Office (GAO) concluded that SEC Staff Accounting Bulletin 121 (SAB 121) represents a “rule” for purposes of the Congressional Review Act (CRA). Under the CRA, rules from federal agencies are subject to a 60-day period during which Congress may disapprove the rule. SAB 121 was issued in March 2022 by staff in the Division of Corporation Finance and the Office of the Chief Accountant to address the accounting for obligations to safeguard crypto assets that an entity holds for platform users. According to the GAO decision, the SEC believed that the staff guidance did not qualify as a rule under the CRA.
In accordance with procedures in the CRA, certain members of Congress have indicated that they plan to initiate proceedings in Congress in hopes of overturning SAB 121. In the interim, however, the guidance in SAB 121 remains applicable.
For more on SAB 121, read our summary, Perspectives on SAB 121 and safeguarding crypto assets.

Key dates
November 3
Deadline to comment on the PCAOB’s proposal, Responsibility Not to Knowingly or Recklessly Contribute to Violations
November 7
2023 Current Developments for Insurance Companies webcast (CPE eligible)
Register here
November 9 or 15
Q4 2023 Quarterly sustainability webcast (CPE eligible)
Register here
November 10
Public roundtable on FASB’s Post-Implementation Review of Topic 606, Revenue from Contracts with Customers
Register here
November 30
Tax transparency and sustainability reporting in 2023 webcast
Register here
December 13, 15, or 19
Q4 2023 Quarterly accounting webcast (CPE eligible)
Register here
December 13
Public roundtable on FASB’s proposed Accounting Standards Update, Disaggregation of Income Statement Expenses
Register here
December 14
Year-end audit committee webcast (CPE eligible)
Register here
December 14
Health industries accounting hot topics webcast (CPE eligible)
Register here
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