Nationwide Financial Services, Inc.Mark R. Thresher, CPA
December 3, 2002 Mr. Jonathan G. Katz, Secretary
Dear Mr. Katz: Nationwide Financial Services, Inc. appreciates the opportunity to comment on the Securities and Exchange Commission's (the Commission) proposed rule regarding the conditions for use of non-GAAP financial measures. The stated objectives of the proposed rule are to implement Section 401(b) of the Sarbanes-Oxley Act, improve the transparency and quality of disclosure of non-GAAP financial measures and enhance the current reporting of earnings information. We applaud the Commission and the federal government in their efforts to find effective and efficient ways to enhance investors’ understanding of the financial disclosures of public companies. We agree that the proposed rule will play an important role in this process. Therefore, we support the Commission’s proposal requiring public companies that disclose non-GAAP financial measures to also include in their disclosure (1) a presentation of the most comparable GAAP financial measure and (2) a reconciliation of the differences between the non-GAAP financial measure and the comparable GAAP financial measure. However, we believe public companies should be permitted to present non-GAAP measures on a per share basis, provided the most comparable GAAP financial measure and a reconciliation of the GAAP measure and the non-GAAP measure are also presented. From our experience, per share information is the most relevant to investors and analysts and excluding such information actually reduces the usefulness of financial information published by public companies. We understand that the disclosure of non-GAAP per share information in filings with the Commission is currently prohibited by Financial Reporting Codification Section 202.04. However, we request that the Commission reconsider its permissibility in an effort to improve the transparency and quality of disclosure of non-GAAP financial measures and enhance the current reporting of earnings information. Thank you for this opportunity to comment on the proposed rule, and for taking these important steps toward restoring investor confidence in the markets. We hope that you will give our suggestion careful consideration.
One Nationwide Plaza 1-12-09 Tel 614 249 6950 Nationwide Insurance
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