For 2005 through 2010, we examine the extent to which S&P 100 companies provide non-GAAP income measures in their annual earnings releases. Our findings provide insight into the evolving nature and magnitude of the adjusting items characteristic of non-GAAP income measures during the post-Reg G period. We find that the number of S&P 100 companies disclosing a non-GAAP income measure increases significantly from 44% to 60% during our period of study.

Based on Gray’s (1980) index of materiality, we find that for each year between 2005 and 2010, the excess of non-GAAP income compared to GAAP income is 18%, 19%, 43%, 61%, 54%, and 45%, respectively. For approximately half of the S&P 100 disclosing non-GAAP income measures, we identify repetitive adjustments for the same item (e.g. restructuring) in multiple years. While none of these companies specifically refer to repetitive adjustments as non-recurring, infrequent or unusual, several include terminology alluding to the use of non-GAAP earnings to evaluate ‘ongoing’ operating trends.

Thus, our findings suggest that a change in tone at the SEC has lead to the reappearance of the disclosure of non-GAAP performance measures that the Commission previously considered to be potentially misleading. In January 2010, the SEC relaxed its position on non-GAAP disclosures clarifying that the recurring item prohibition for SEC filings is based on the description of the item adjusted, not its nature.

Finally, while most of the S&P 100 providing such disclosures indicate why management believes presentation of a non-GAAP financial measure is useful to investors, the rationales are typically general and broad and accordingly not informative.