In his remarks this week at the 34th Annual Current Financial Reporting Issues Conference, SEC Commissioner Michael S. Piwowar took another wisecrack at the way the SEC measures the effectiveness of its enforcement efforts. Speaking to an audience of primarily non-lawyers who prepare financial statements, Piwowar asked them to
imagine a world where GAAP or other reporting standards did not exist – where management could develop its own numbers based on its own poorly-defined criteria. Management might be tempted to create numbers that provide the illusion of performance but in reality are largely irrelevant to measuring the actual performance of that organization. Reported numbers might be distributed for public consumption without clear disclosure as to how they were derived. These numbers could also be touted in press releases and other public statements by management in order to paint a flawed view of the organization’s productivity and effectiveness. But enough about the SEC’s enforcement statistics.[3]
