Deloitte Touche Tohmatsu Limited has responded to the International Organization of Securities Commissions' Consultation 'Proposed Statement on Non-GAAP Financial Measures'. We support addressing the issue of non-GAAP financial measures at a global level as it is pervasive, and believe it is in the best interests of global securities markets if the proposed statement applied consistently in all IOSCO jurisdictions and is not overlaid with local guidance.
The comment letter makes a number of additional points, including:
· For the proposed statement to have maximum effect, we encourage IOSCO to develop a common definition of 'non-GAAP financial measure' and to determine which such measures should be subject to the common discipline
· It is important for the efficient operation of global capital markets that national and regional guidance is consistent and does not contradict the requirements of globally-recognised financial reporting frameworks
· We agree that the proposed statement should apply to 'any non-GAAP financial measure wherever the measure is disclosed outside of the financial statements' as it recognises standard-setters' responsibility in relation to financial statements, and is a way of achieving consistency in the use of non-GAAP financial measures across the annual report as a whole, but suggest that IOSCO works with the IASB to clarify what is considered to be an 'IFRS measure'
· We encourage IOSCO to determine a consistent scope, application and enforcement of the proposed statement, as it is assumed that it would encompass information on websites and other non-regulated information, and some securities market regulators regulate press releases and web-based material, but others do not.