March 16 2018
The Center for Audit Quailty has released a new publication offering considerations for audit committee members to help with oversight of non-GAAP measures.
The publication, Non-GAAP Measures: A Roadmap for Audit Committees, outlines considerations for audit committees, including how to assess whether a company’s non-GAAP metrics offer a balanced representation of their organization’s performance.
“GAAP information serves as a foundation for confidence in financial statements, but financial statement users also value non-GAAP financial measures, when presented appropriately,” said CAQ executive director Cindy Fornelli in a statement. “Our roadmap can help audit committees improve and advance their oversight of and involvement with non-GAAP measures, to the benefit of companies and investors.”
The CAQ suggests that the audit committee:
– Put itself in the shoes of investors when evaluating if the presented non-GAAP measures and related disclosures align with the company’s overall strategy and performance.
– Ask management whether it has an internal policy that provides guidelines for determining how non-GAAP measures are generated, calculated, and presented.
– Discuss with management how the company makes changes to the non-GAAP measures it presents, and the rationale for why it would or would not make changes.
– Ask the organization to compare or benchmark its non-GAAP measures alongside its peers.
– Use outside auditors as a resource when evaluating non-GAAP measures.
– Discuss with investors directly or through investor relations to ensure that the presented non-GAAP measures aid investors’ understanding of the company’s performance.
Along with a roadmap, the CAQ has a posted a video on YouTube with interviews with audit committee chairs that offer more context and real-life examples of how audit committees are considering and monitoring non-GAAP measures.
The recommendations are based on a series of roundtables that the CAQ held last year on the topic of non-GAAP measures, in which audit committee members, management, investors, securities lawyers, and public company auditors participated.