Tesla Motors Inc. got the memos, but the Securities and Exchange Commission told the company more than once that it was not getting the message.

Tesla has been talking with the SEC about its accounting since Aug. 31, when it filed a joint proxy statement and prospectus announcing the company’s proposed acquisition of Solar City Corp MX:SCTY. It took four letters from the SEC, three letters from Tesla’s TSLA, -10.34% lawyers for the deal, Wachtell, Lipton, Rosen & Katz, five amendments to the original August registration filing and at least one conference call, on Sept. 27, before the SEC approved the registration statement for the acquisition and closed the matter on Oct. 12.

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“ ‘Based on your response, it is not clear whether you intend to revise your disclosure as requested in our prior comment.’ ” — SEC letter to Tesla

The SEC didn’t post all the letters it sent to Jason Wheeler, Tesla’s chief financial officer, until the day before Thanksgiving. The SEC had pages of questions and comments about the Solar City deal, the company’s disclosures about that deal and suggestions for improvement to future earnings releases and annual reports. Unlike most SEC comment letters, which are made public about 20 days after the matter is closed, Tesla’s were not made public until Nov. 23, about 40 days after the SEC was finally satisfied.

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Correspondence with 12 other companies that had satisfied the SEC’s concerns about their use of non-GAAP metrics more recently were also made public on Nov. 23, according to Olga Usvyetsky of the research firm Audit Analytics.

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Last year only one case of correspondence with the SEC was published on Thanksgiving’s eve — a day ahead of a markets holiday. In 2014 there were four, said Usvyetsky. The SEC established a task force this past May to tackle the use and abuse of nonstandard numbers, after issuing updated guidelines for companies in May.

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Tesla CFO Wheeler, who is ultimately responsible for the company’s accounting and disclosures to investors and the SEC, joined in November 2015 from Google, where he led the finance function for 13 years. Wheeler started his career as a financial analyst at Hewlett-Packard HPQ, -0.65% , according to his LinkedIn profile.

Until a few weeks ago, Wheeler, who has a Harvard MBA but is not an accountant by training, was also Tesla’s principal accounting officer. The company announced on Oct. 24 that it had hired Eric Branderiz, a certified public accountant who was most recently the corporate controller and chief accounting officer for SunPower Corp. SPWR, +0.39% . Branderiz will lead the company’s technical accounting group, reporting to Wheeler.

SunPower’s joint venture with First Solar Inc. FSLR, +0.76% was the first entity to receive a comment letter from the SEC task force over the use of unusual metrics in a filing relating to a secondary share offering, as MarketWatch reported in October.

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On Sept. 16, the SEC noted four specific concerns it had with Tesla’s use and presentation of non-GAAP measures. In two cases the SEC pointed directly to its updated guidance, including chastising the company for creating an “individually tailored measurement.” That is not allowed. The SEC also pointed to unacceptable “boilerplate” language about how the non-GAAP information is used.

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The SEC expected its questions to be answered and, in several cases, wanted acknowledgment in writing that the changes it was suggesting would be made. Tesla’s initial responses — that it was either still reviewing the new guidance or would make a change later — did not satisfy the regulator. In language that might be described as a regulatory passive-aggressive tone, the SEC tells the company, “Based on your response, it is not clear whether you intend to revise your disclosure as requested in our prior comment.”

Tesla’s second response to the SEC on Sept. 29 does provide a stronger commitment to revising its language, such as retitling “cash flow from core operations” — which includes significant financing cash flows — to something that differentiates it from a measure of operating cash flows. The company also agreed to label it a non-GAAP measure.

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How Tesla measures and tells investors about its cash flow is important since the company has not generated positive operating cash flows in the past two fiscal years. In fact, the SEC told Tesla, in its first letter on Sept. 16, to “please clearly state that you have not generated positive operating cash flows in the past two fiscal years and when you anticipate that you will generate positive operating cash flows, if at all.”

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In its Sept. 29 letter to the SEC, Tesla included an entire paragraph describing its reconciliation of GAAP to non-GAAP net income, with additions and strikeouts for the SEC staff to review and approve.

A spokeswoman for Tesla provided MarketWatch with this statement:

“Tesla responded promptly to the SEC’s May guidance. When Tesla announced its Q2 earnings, it stated that it was evaluating the SEC’s guidance and was determining whether any changes should be made.

“When the SEC then asked Tesla about this as part of its review of the SolarCity acquisition, Tesla told the SEC that it had decided to make changes. These changes were reflected in its Q3 earnings, which was just one quarter after the SEC provided its new guidance.”