In recent years, the Staff of the Securities and Exchange Commission (the “SEC”) has been providing comments regarding companies’ presentations of non-GAAP financial measures in public filings.  Working with Audit Analytics, we surveyed SEC Staff comment letters provided to mortgage real estate investment trusts (“REITs”) in 2018 and 2017 and observed a significant increase in the Staff’s focus on the use of non-GAAP financial measures by mortgage REITs.  The comments issued relate largely to the improper labeling of non-GAAP financial measures (such as core earnings) and the failure to reconcile a non-GAAP financial measure used with its GAAP counterpart.  See an illustration of the survey’s findings below.