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What’s next: expect more comment letters – and potentially enforcement action. Panelists observed that SEC comments to companies are available to the public via the SEC Edgar system after review (link). The first “wave” of comment letters were issued after the SEC updated the non-GAAP guidance in May. Panelists noted that many companies ‘self-corrected’ potential reporting issues during the 2nd quarter earnings process. Panelists also noted that another “wave” of comment letters is expected to be released within the next few months. Further, Chair White has indicated that the Commission may pursue enforcement, if appropriate (link).
Please note, all panelists participated in an individual capacity and their views and remarks do not necessarily represent the views of their member organizations.
Todd Castagno, U.S. CRUF Co-Chair
Zhen Deng, U.S. CRUF Co-Chair