Form 10-K
2020-06-24 to 2020-07-07 · 1 question
· 1 letter from the SEC, 1 from the company
Non-GAAP measures
Exhibit 99.1 · Use of Non-GAAP Financial Measures, page 27
SEC asked
We note your disclosures on pages 27-29 of various non-GAAP measures that are derived from Adjusted net income calculated on page 29, which exclude "Provision in excess of credit losses". It appears these performance measures, which exclude a portion of the provision for credit losses, substitute individually tailored recognition and measurement methods for those of GAAP and violate Rule 100(b) of Regulation G.Rest of the question
Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations, which is available on our website at: http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm. Please refrain from disclosing these performance measures, or any other similar non-GAAP performance measures that exclude all or a portion of the provision for credit losses.
FITB answered
Fifth Third acknowledges the staff’s comment and confirms that it will refrain from disclosing these measures, or any other similar non-GAAP performance measures that exclude all or a portion of the provision for credit losses in future filings.
If you should have any additional questions or require any further information, please do not hesitate to call me at (513) 534-5247 or Mark Hazel, Senior Vice President and Controller, at (513) 534-6702. Read in the reply ↗
In its next report
First report after the company's reply of 2020-07-02: 10-Q filed 2020-08-07 ↗, against the 10-Q filed 2020-05-08 ↗.
Tickdelta does not hold the text of both reports, so they are not compared here.
Also in this review: closing letter, 2020-07-07