Yen, T. W., Lo, S. Y., Liu, C. C., and Yu, L. H. 2024. The Effect of SEC’s Comment Letters on the Comparability of Non-GAAP Earnings. NTU Management Review, 34 (1): 173-218. https://doi.org/10.6226/NTUMR.202404_34(1).0005
Ting-Wei Yen, Deloitte & Touche
Sheng-Yi Lo, Department of Finance, National Sun Yat-sen university
Chi-Chun Liu, Department of Accounting, National Taiwan University
Lin-Hui Yu, Department of Accounting, National Taiwan University
Abstract
As non-GAAP earnings are widely used, the SEC and IASB have expressed concerns about this phenomenon in recent years. They believe that the non-GAAP earnings may lack of comparability because of the unclear definition of non-GAAP disclosure. These vagueness can also influence the communication between information users and companies. Since the SEC uses comment letters to monitor the registrants’ filing reports and whether these reports are compliant with SEC disclosure requirements, our research investigates whether those receiving the SEC comment letters would improve their comparability of non-GAAP earnings. Our empirical results suggest that after the company received non-GAAP related comment letters, the comparability of its non-GAAP earnings increases while the analysts’ earnings forecast error and dispersion decrease.
Keywords
non-GAAP earningsSECcomment letterscomparability