... Knechel. 25 08 2021 23 04 2024 02 05 2024 2024 non-GAAP financial measures non-GAAP EPS denominator GAAP diluted EPS voluntary disclosure SEC comment letters This study examines the number of shares firms use in the denominator of non-GAAP earnings per share...

... for short sellers. Short sellers can gain similar profits, and bear less risk, if they put off increasing their short positions until after the disclosure. JEL Classifications: G32; M40. SEC comment letters short selling social connections We thank two anonymous reviewers, Jing Chen, Xia...

... audit quality auditor style financial-statement comparability SEC comment letters The merits of centralized and decentralized decision making have been discussed extensively in economics and management since Hayek (1945) . A noted feature of centralized decision making (CDM) is that it may...

... disclosure boilerplate litigation risk securities lawsuits SEC comment letters disclosure regulation Official guidance from regulators and the judiciary explicitly discourages boilerplate disclosures and indicates that risk factor disclosures should be concise and tailored to the specific risks...

... to receive a tax-related SEC comment letter. We also find that firms receiving a tax-related SEC comment letter, relative to firms receiving a non-tax comment letter, subsequently decrease their tax avoidance behavior consistent with an increase in expected tax costs. Additionally, we document evidence...

...Patricia M. Dechow; Alastair Lawrence; James P. Ryans ABSTRACT We document that insider trading is significantly higher than normal levels prior to the public disclosure of SEC comment letters relating to revenue recognition. Furthermore, insider trading is triple its normal level for firms...