FWIW, I've had a couple modules of Acctg a while back and this was way above that, but many here me included, do not trust what GM has done. It is a gut feel thing. And how in the Frank-Dodd / Sarbanes Oxley world do they live without being GAAP? We know how they got away with the carry forward of 45 billion in losses in the non-bankruptcy, but their hidden liabilities are the VEBA liabilities that while not their paper, they in essense are still on the hook for IMHO. They tried to buy out old employee pensions, and that is done, But the Union Pension(s) are who's liability at this point? I still stand on my prediction, this entity may have to go Chapter 11 again, something doesn't pass the smell test.
Tell me where I am wrong here....
SEC rules state that Non-GAAP measures cannot be presented without a reconciliation from GAAP to Non-GAAP. Additionally you cannot present the Non-GAAP measure "more prominently" than the GAAP measures.
In our public filings we have safe harbor language on Non-GAAP financial measures that states in part, "The Company presents adjusted operating income (loss), adjusted operating margin, adjusted EBITDA and adjusted EBITDA margin because these are measures management believes are frequently used by securities analysts, investors and other interested parties in the evaluation of financial performance."
Additionally we state, "These non-GAAP measures have limitations as analytical tools, and securities analysts, investors and other interested parties should not consider any of these non-GAAP measures in isolation or as a substitute for analysis of the Company's results as reported under accounting principles generally accepted in the United States ("GAAP"). These non-GAAP measures may not be comparable to similarly titled measures used by other companies."
Finally we say, "A reconciliation of non-GAAP to GAAP results is included..." with the presentation, press release, what have you.