1.4 Comment Letters per Review and Days to Complete a Review

In the period from review year 2019 through review year 2023, the SEC staff issued approximately 1.4 comment letters per review on average. For the past five years, over 90 percent of all reviews were resolved after one or two comment letters. This consistent trend in the number of comment letters per review may be partly attributable to outreach to registrants by phone to facilitate timely closure of an ongoing SEC staff review.

However, we did see a slight increase in the average number of comment letters per review in the current year to 1.5. This uptick may be attributable to the SEC staff’s approach of using 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 review year 2019 through review year 2023, it took approximately 48 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 a slight increase in the time to resolution this year, with the average increasing to 54 days. This increase is consistent with the additional rounds of comments noted in Section 1.4.

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.