Comments on Proposed Rule: Conditions for Use of Non-GAAP Financial Measures

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Date Received
Date Letter Type Commenter Name
Public Comment Clarine Nardi Riddle, Senior Vice President, National Multi Housing Council
Public Comment Erica H. Steinberger, Chair-Committee on Mergers, Acquisitions and Corporate Control Contests, Association of the Bar of the City of New York
Public Comment F. Patrick Hughes, President, Mid-Atlantic Realty Trust
Public Comment Howard M. Sipzner, Chief Financial Officer, Equity One, Inc.
Public Comment James B. Lootens, Assistant Secretary and Assistant General Counsel, Eli Lilly and Company on behalf of the Securities Law Committee of the American Society of Corporate Secretaries
Public Comment Karen L. Barr, General Counsel, Investment Counsel Association of America
Public Comment Paul M. Meurer, Executive Vice President, Chief Financial Officer & Treasurer, Realty Income Corporation
Public Comment R. Gregory Fox, Executive Vice President and CFO, Post Properties, Inc.
Public Comment Richard C. Henriques, Vice President, Controller, Merck & Co., Inc.
Public Comment Ritson Ferguson, anaging Director and Chief Investment Officer; Kenneth D. Campbell, Managing Director, Clarion CRA Securities, L.P.
Public Comment Todd S. Thomson, EVP Finance, CFO, Citigroup Inc.
Public Comment Christopher P. Marr, Senior Vice President & Chief Financial Officer, Brandywine Realty Trust
Public Comment Henry B. Schram, Senior Vice President and Chief Accounting Officer, Chubb Corporation
Public Comment Paul E. Huck, Vice President and Corporate Controller, Air Products and Chemicals, Inc.
Public Comment Thomas J. Kloc
Public Comment Wayne A. Mehlman, Director of Economic Issues, International Council of Shopping Centers
Public Comment BDO Seidman, LLP
Public Comment Mark R. Thresher, CPA, Senior Vice President - Chief Financial Officer, Nationwide Financial Services, Inc.
Public Comment David C. Fischer, Loeb & Loeb LLP
Public Comment Todd M. Malan, Executive Director, Organization for International Investment
Public Comment Matthew I. Brown, E*TRADE Brokerage Holdings, Inc.

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-43-02
Release Number
33-8145
34-46768
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