Appendix C — Tips for Searching the SEC’s Database for Comment Letters

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The SEC adds comment letters (and responses from registrants) to its EDGAR database no earlier than 20 days after its review of a filing is complete. Registrants can refer to such comments as part of their financial statement review process and to improve their own accounting and overall disclosure.

Although the SEC has updated the EDGAR search engine to simplify searches of corporate filings, users may still wish to use the “full-text” search feature to find the text of specific comment letters and to further narrow their search results. The process of performing a full-text search is discussed below.

C.1 Full-Text Searching

To perform a full-text search, first go to the SEC’s home page (www.sec.gov) and click on the “SEARCH EDGAR” link in the “Quick Links” menu:

On the EDGAR full-text search page, select “+ more search options”:

This brings up the following form:

In the form, limit the search results to SEC comment letters by clicking “Browse filing types” and choosing “UPLOAD” (or select “CORRESP” to include registrant responses as well) or by selecting “Filing review correspondence” from the filing category (“View all”) drop-down menu:

Then, enter search terms in the “Document word or phrase” field. The documents found will contain at least one of the words entered as well as variations of the keyword(s). To search for specific phrases, enclose the phrase in quotation marks (e.g., “management’s discussion and analysis”). Results will include documents that contain the quoted phrase as well as conceptually related phrases, such as “managerial discussion & analysis.”

C.1.1 Enhancing Search Results

“EDGAR Full Text Search” uses an implied AND Boolean operator between query terms, so there is no need to enter AND in the query. To narrow your search by telling the search system that all terms must be contained anywhere in a document and in any order in the document (but not necessarily in the same sentence or paragraph), enter the terms in the search field (e.g., software hardware). All resulting documents will contain software and hardware anywhere in the document content.

To further refine searches, terms can be excluded from the results documents by using a - (hyphen or dash) or a capitalized “NOT” immediately preceding a query term (e.g., software -hardware; software NOT hardware). All resulting documents will contain software, but not hardware, anywhere in the document content. In addition, to identify at least one of the search terms or phrases, a capitalized “OR” can be used between the terms or phrases.

To perform a wildcard search, append an * (asterisk) to the end of a keyword (e.g., cyber*) — all resulting documents will contain cyber or cybersecurity or other words beginning with cyber. The wildcard cannot be used at the beginning or in the middle of a word and is not supported in exact phrase matches or in Boolean searches.

Note that natural language search capabilities are not currently supported.

C.1.2 Sorting by Dates and Other Specific Criteria

On the full-text search form, selections (individually or in combination) can also be made to limit results to a specified:

Company name.
Ticker.
Central index key (CIK) number.1
Individual’s name.
Date range.
State, province, country, or territory in which a company’s principal executive offices are located or in which a company is incorporated (i.e., the primary location associated with a filing).

Any of these can be combined in a single search.

C.1.3 Example of the Benefits of Using Full-Text Search Features

Assume that a user is interested in SEC comments issued over the past two years that are related to results of operations in the hotel industry. By searching for the words “results” and “operations” with “All Forms” selected and no dates specified, the user would obtain 10,000 results, many of which are not relevant.

However, if the user narrowed his or her search by (1) selecting the form type UPLOAD, (2) entering the search term “results of operations” in quotation marks, and (3) providing a date range spanning the last two years, the number of results would be more relevant and manageable.

C.1.4 Additional Information

For more information about full-text searching, click on the FAQ link in the search form:

Footnotes

According to the SEC’s Web site, a “CIK is the unique number that the SEC’s computer system assigns to individuals and corporations [that] file disclosure documents with the SEC. All new electronic and paper filers, foreign and domestic, receive a CIK number.”