1.4 Comment Letters per Review and Days to Complete a Review

For the past five years on average, 91 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 2021 through the end of review year 2025, whereas it issued approximately 1.5 comment letters per review on average in review year 2025.

In the period from the beginning of review year 2021 through the end of review year 2025, it took approximately 54 days on average to complete a review. During the same period, approximately 75 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 69 days, up 9 days from the prior year and 15 days from the five-year average. This may be due to increased market activity as well as reduced overall resource levels of the SEC staff.

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.