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SEC Compliance and Disclosure Interpretations on Non-GAAP Financial Measures

SEC staff interpretations of Regulation G and Item 10 e of Regulation S K, including the treatment of free cash flow.

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Publisher
U.S. Securities and Exchange Commission
Standing
Primary authority
Version
Non-GAAP Financial Measures C&DIs, accessed 2026-08-08
Relevant parts
Questions 102.05 through 102.07
Currency
current · checked Aug 8, 2026

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Question 102.07 explains that a common free-cash-flow presentation starts with GAAP operating cash flow and subtracts capital expenditures, but has no uniform definition and requires a clear calculation description and reconciliation when used in the covered filings.