This week's discussion centers around the #2 trend in 2022 SEC comment letters: non-GAAP measures.
In each episode of our 2022 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance.
This week, Heather Horn sat down with Kyle Moffatt, a partner in PwC’s National Office, to discuss the SEC staff’s continued focus on non-GAAP measures and trending comment letter themes.
In this episode you’ll hear discussion of:
  • 1:15 - What non-GAAP measures are and how registrants use them
  • 6:41 - The challenges and judgments associated with non-GAAP measures
  • 9:32 - How the focus of the current SEC administration impacts the type and volume of comment letters
  • 12:03 - The top non-GAAP comment letter trends and the importance of continuously reassessing these measures
  • 20:58 - The interaction of current macroeconomic events and non-GAAP measures
  • 27:34 - What companies should focus on when looking ahead to year-end reporting
  • 31:12 - Final advice when responding to SEC staff comments on non-GAAP measures
Want to learn more? Check out our analysis of SEC comment letter trends and stay tuned for more episodes in the series. For further information on non-GAAP measures with respect to business and market disruptions, take a look at the SEC Division of Corporate Finance’s guidance on disclosure considerations related to COVID-19.
About our guest
Kyle Moffatt is a partner in PwC's National Office where he consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.
About our host
Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.
Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to
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