December 18, 2002
Jonathan G. Katz, Secretary
RE: File No. S7-43-02
Dear Mr. Katz:
CIGNA Corporation appreciates the opportunity to comment on the Commission's proposals regarding the use of non-GAAP financial measures and the required filing of certain press releases on Form 8-K. We are supportive of the Commission's efforts to improve financial reporting through the development of standards requiring enhanced disclosure about non-GAAP financial information by public companies.
We support the following rules included in the Commission's proposal:
However, we have concerns regarding certain of these proposals. We believe that:
Failure to present adjusted per share information in earnings releases or adjusted non-GAAP amounts in management's analysis of results will require investors to prepare such analyses themselves. As noted above, we support the Commission's objective of promoting transparency in financial reporting by requiring a reconciliation of non-GAAP financial data to GAAP amounts. By requiring reconciliations of such data, each company's assessment of financial information should be clear and investors can properly draw comparisons between companies.
Presentation of adjusted per share or adjusted non-GAAP amounts helps management focus on true operating performance and assists in period-to-period comparability. Disclosure of these adjusted amounts, in the proper context, furthers the Commission's goal of allowing investors an opportunity to look at company performance "through the eyes of management."
We appreciate this opportunity to respond to the Commission's proposed rules and your consideration of our comments. Should the Commission or its Staff have questions concerning the comments in this letter or desire additional information to assist in preparing the adopting release, please do not hesitate to contact me at 215-761-2327.