The SEC has issued guidance that provides disclosure considerations and reminds registrants to maintain effective disclosure controls and procedures when disclosing metrics in MD&A.
The SEC has issued guidance highlighting disclosure considerations when discussing key performance indicators and other metrics in MD&A.
The SEC generally expects disclosures to include:
Companies should also consider whether disclosure of the estimates or assumptions related to the metric or its calculation is necessary for the metric not to be materially misleading. If the method of calculating or presenting the metric changes, the company should consider the need to disclose:
The guidance also reminds registrants of the requirement to maintain effective disclosure controls and procedures when disclosing material KPIs or metrics in MD&A.