1.4 Comment Letters per Review and Days to Complete a Review

For the past five years on average, 92 percent of all reviews were resolved after one or two comment letters. The SEC staff issued approximately 1.4 comment letters per review on average in the period from the beginning of review year 2020 through the end of review year 2024, whereas it issued approximately 1.5 comment letters per review on average in review year 2024. This slight increase in the average number of comment letters per review may be attributable to the SEC staff’s approach of issuing comments to elicit expanded disclosures related to emerging issues, as outlined in Section 1.3. Such an approach may lead to multiple rounds of comments as the staff asks additional questions or requests further details on emerging issues and the related impact on a registrant.

In the period from the beginning of review year 2020 through the end of review year 2024, it took approximately 49 days on average to complete a review. During the same period, approximately 77 percent of reviews on average were completed within 60 days; this trend has remained relatively consistent over the past five years. However, we did see an increase in the time to resolution in the current year, with the average increasing to 60 days, up 6 days from the prior year and 11 days from the five-year average. This increase is consistent with the additional rounds of comments noted in Section 1.4.1.

Quick resolution of the comment letter process is important. Applying our best practices for managing unresolved SEC comment letters, as discussed in Appendix B, may help registrants resolve staff comment letters in a timely manner.