Revised Compliance and Disclosure Interpretations on Non-GAAP Financial Measures

January 2010
Ronald S. Brody, Colin J. Diamond, Gary Kashar, Jin K. Kim, Kenneth Suh, Nazim Zilkha

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On January 11, 2010, the staff of the Division of Corporation Finance of the Securities and Exchange Commission issued new Compliance and Disclosure Interpretations relating to Regulation G and Item 10(e) of Regulation S-K. The interpretations include new and revised interpretations on the use of non-GAAP financial measures and provide registrants with more flexibility to disclose non-GAAP financial measures in filings with the SEC.