Abstract

This study investigates whether the change in the U.S. SEC’s regulation of non-GAAP reporting in 2010 affects firms’ earnings management through the recognition of opportunistic special items. The SEC released Compliance and Disclosure Interpretations (hereafter C&DIs) in 2010 to relax the exclusion restrictions imposed by an earlier regulation (i.e., Regulation G) and to give companies more flexibility in excluding other items in the calculation of non-GAAP earnings. Using a difference-in-differences design, we find that, relative to firms that do not report non-GAAP earnings, firms disclosing non-GAAP earnings reduce the recognition of opportunistic special items after the implementation of C&DIs. We also find that the incidence of using opportunistic special items to meet or beat analysts’ earnings forecasts by non-GAAP firms significantly decreases in the post-C&DIs period. Our results are robust to a variety of alternative research design. An additional analysis suggests that the reduction in the recognition of opportunistic special items is more pronounced in firms that report a loss under GAAP. Our findings complement prior research suggesting that a less stringent regulation on non-GAAP earnings disclosures will reduce firms’ incentives to pursue aggressive earnings management.  

Keywords

non-GAAP reportingrecurring itemsspecial itemsearnings managementcompliance and disclosure interpretations