SRSEC Reporting Desk

HOULIHAN LOKEY, INC. (HLI) – SEC staff letter

2026-01-30 · Re: Form 10-K for the Fiscal Year Ended March 31, 2025 Form 8-K filed January 29, 2026 · Accession 0000000000-26-001109 · 2 staff comment(s) issued

Company response(s): 2026-02-13

Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessKPIs, Metrics & Earnings Calls

2026-01-30 · Form 10-K for the Fiscal Year Ended March 31, 2025 Form 8-K filed January 29, 2026 · Comment 1 · Non-GAAP Financial Measures, page 5 Agreed to revise
Staff comment: Please revise your disclosures in future filings to further discuss the reasons why you believe that presentation of these non-GAAP financial measures provide useful information to investors and describe each of the adjusting items. Refer to paragraph (e)(1)(i)(C) of Item 10 of Regulation S-K. letter →
Company response: The Company respectfully acknowledges the Staff’s comment. In future filings, the Company will revise its disclosures to further discuss the reasons why it believes that presentation of its non-GAAP financial measures provides useful information to investors and will describe each of the adjusting items in accordance with paragraph (e)(1)(i)(C) of Item 10 of Regulation S-K. The Company’s revised disclosure will read as follows: “Non-GAAP Financial Measures As a supplement to our financial measures presented in accordance with U.S. Generally Accepted Accounting Principles (“GAAP”), the Company presents certain adjusted (non-GAAP) measures of financial performance. These non-GAAP financial… response letter →
Non-GAAP: Reconciliation & Usefulness
2026-01-30 · Form 10-K for the Fiscal Year Ended March 31, 2025 Form 8-K filed January 29, 2026 · Comment 2 · Reconciliation of GAAP to Adjusted Financial Information, page 8 Responded
Staff comment: We note the adjustments for "acquisition related compensation and benefits" in each of your non-GAAP measures appear to include deferred retention payments related to certain acquisitions. Please tell us and quantify the components comprising each of this adjustment for each period presented and clarify whether these payments are settled in cash and require continued employment. As part of your response, please explain how you determined that these were not normal, recurring, cash operating expenses of your business. Refer to Question 100.01 of the non-GAAP C&DIs. letter →
Company response: , please explain how you determined that these were not normal, recurring, cash operating expenses of your business. Refer to Question 100.01 of the non-GAAP C&DIs. Response : The Company respectfully acknowledges the Staff’s comment and has considered the guidance set forth in Question 100.01 of the Compliance and Disclosure Interpretations related to non-GAAP measures (“ C&DI 100.01 ”). The Company believes that making adjustments to exclude acquisition related compensation and benefits is appropriate and consistent with the guidance provided in C&DI 100.01 and further believes that such adjustments enhance the clarity and usefulness of the Company’s non-GAAP financial measures for its… response letter →
Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessKPIs, Metrics & Earnings Calls

Full letter on EDGAR → · Filing index · All HOULIHAN LOKEY, INC. (HLI) correspondence

Non-GAAP: Adjustments & Labels – what to check: Do not exclude normal, recurring cash operating expenses or use individually tailored recognition methods; label measures clearly (C&DI 100.01–100.04).

Non-GAAP: Reconciliation & Usefulness – what to check: Reconcile every non-GAAP measure (including segment-level measures presented outside the ASC 280 note) to the most directly comparable GAAP measure, and explain why it is useful.

KPIs, Metrics & Earnings Calls – what to check:

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