Comparing Non-GAAP EPS in Earnings Announcements and Proxy Statements

We examine the relation between compensation incentives and non-GAAP earnings disclosures. Specifically, we focus on the extent to which bonus plan incentives and long-term performance plan incentives are associated with the aggressiveness of non-GAAP reporting, controlling for CEO sensitivity to stock price. Using a large hand-collected sample of non-GAAP earnings disclosures, we find that long-term plan incentives are negatively associated with the likelihood and magnitude of aggressive non-GAAP reporting, suggesting that they act as a deterrent to potentially opportunistic behavior. For a sub-sample of firms for which compensation contracts in proxy filings explicitly state that managers will be evaluated based on non-GAAP metrics, we find less opportunistic non-GAAP reporting, consistent with boards defining adjusted performance metrics in compensation contracts in order to limit CEOs’ ability to define their own non-GAAP numbers. However, when boards of directors have discretion to use non-GAAP metrics when evaluating managers, we find more opportunistic non-GAAP earnings reporting, consistent with managers using the flexibility in contracts to influence their performance evaluations.