... 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 (EPS) and whether denominator choices...

... 12 12 2022 2023 SEC comment letters short selling social connections Section 408 of the Sarbanes-Oxley Act of 2002 (SOX) mandates that the Securities and Exchange Commission (SEC) review public companies’ filings to ensure compliance with disclosure and accounting requirements...

... 2023 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 assessed as adequate in judicial review, industry peers borrow that language more frequently, and that judicial assessments of risk factor disclosures prompt industry peers to lengthen their risk factor disclosures. JEL Classifications: D8; G38; M4. Turning to the SEC comment letter sample, we find...

... 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...