General Motors Company (GM) has addressed several comments from the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (SEC) regarding its Form 10-K for the fiscal year ended December 31, 2022. The SEC's letter, dated December 20, 2023, prompted GM to clarify its financial disclosures, particularly concerning non-GAAP measures and cash flow presentations. GM has agreed to present GAAP measures with equal or greater prominence than non-GAAP measures in future filings and to adjust the placement of the Non-GAAP Measures subsection within its Management's Discussion and Analysis (MD&A). The company also defended its approach to presenting cash flows separately for its Automotive, GM Financial, and Cruise segments, arguing that it provides...Show More

General Motors Company (GM) has addressed several comments from the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (SEC) regarding its Form 10-K for the fiscal year ended December 31, 2022. The SEC's letter, dated December 20, 2023, prompted GM to clarify its financial disclosures, particularly concerning non-GAAP measures and cash flow presentations. GM has agreed to present GAAP measures with equal or greater prominence than non-GAAP measures in future filings and to adjust the placement of the Non-GAAP Measures subsection within its Management's Discussion and Analysis (MD&A). The company also defended its approach to presenting cash flows separately for its Automotive, GM Financial, and Cruise segments, arguing that it provides a clearer understanding of the company's liquidity and cash flow activities. Additionally, GM will revise future filings to remove the word 'net' from certain line items for clarity and has provided detailed explanations of its revenue recognition practices, particularly in relation to its dealings with rental car companies. GM also plans to disclose that its inventory cost is determined on a FIFO basis and has clarified its accounting for stock incentive plans in line with ASC 718. The company maintains that its current revenue disclosures are adequate, with the majority of its revenue streams being accounted for under ASC 606.