nd animals. For 2001, total revenues and assets exceeded $32 billion
and $39 billion, re
spectively.
Pfizer is a research-based global pharmaceutical company that discovers, develops, manufactures,yand markets innovative medicines for humans nd animals. For 2001, total revenues and assets exceeded $32 billion and $39 billion, respectively.
Pfizer recognizes the timeliness of the U.S. Securitiesand Exchange Commission's (SEC or Commission) proposal to increase investor confidence, which has been dampened by a number of recent accounting and disclosure scandals, rand we commend the Commission for
its efforts to propose meaningful solutions.
We believe that Release No. 33-8145d forms the basis for an important improvement in the quality and transparency of corporate disclosure.
Specifically,
We agree that non-GAAP financial measures should not be given greater prominence than comparable GAAP financial measures.
We agree that non-GAAP financial measures should be reconciled to the comparable GAAP financial measures.
We believe that an exception for prospective measures should be permitted when the necessary information cannot be obtained without unreasonable effort.
We disagree with the suggestion that non-GAAP financial measures should be limited to historical financial measures.
We do not support a requirement that auditors audit or review all non-GAAP financial measures.
We urge the SEC to resist prohibiting non-GAAP per share measures prior to undertaking a study to ascertain the usefulness of these measures to the investor community.
We urge the SEC to resist prohibiting the presentation of any non-GAAP financial measures that management deems necessary for the fair presentation of its results or prospects. We believe that it is the reconciliation aspect of the proposal that makes it the most powerful in achieving transparency rather than a mandating of what should or should not be an adjustment to non-GAAP measures. With that reconciliation, users have information available which they can assess and can either choose to agree or disagree with how management views the non-GAAP measure. When management determines that such information is needed to assist the user in understanding the present operating results, financial condition or future opportunities or risks, known or estimated, then restricting the content of such information could inadvertently prevent users from obtaining valuable insight into management's perspective on the results of operations or financial condition of the company.
We share the same purpose of the SEC - - that of maintaining and strengthening the integrity, quality and transparency of financial statements - - even as we challenge some of the suggestions in the SEC's proposal.
Our more specific comments to several of the items in the proposal are set forth in the attachment.
We appreciate your consideration of these comments. We would be happy to discuss these matters further or to meet with you if it would be helpful.
Sincerely,
Loretta V. Cangialosi
Loretta V. Cangialosi
Vice President and Controller
Pfizer Inc.
Enclosure (1)
cc:
David L. Shedlarz
Executive Vice President and Chief Financial Officer
Alan G. Levin
Vice President - Finance
Attachment
Detailed Responses to the Proposed Rules on
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