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On the Radar

SEC Comment Letter Considerations, Including Industry Insights

November 2021
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On the Radar
SEC Comment Letter Considerations, Including Industry Insights

Despite the global pandemic that has continued to affect markets worldwide over the past two years, the SEC remained steadfast throughout 2021 to provide investors continued support and oversight during such challenging times. In addition to acquiring new leadership with the appointment of Gary Gensler as chair of the SEC in April 2021, the Commission oversaw exponential growth in the capital markets through traditional initial public offerings (IPOs) and special-purpose acquisition companies (SPACs), significant growth in crypto assets, and the rise of financial technology and data analytics.


Unless noted otherwise, comment letter trend information in this publication:
  • Was derived from data provided by Audit Analytics.
  • Is related to reviews conducted by the Division of Forms 10-K, 10-K/A, 10-Q, and 10-Q/A (which are referred to generally as “filings”).
  • Is based on SEC uploads (i.e., comment letters that the SEC issued to registrants) and does not include registrant responses.
  • Does not include the SEC’s “closing letter” communicating that its review is complete.
  • Includes only information related to reviews that have been closed and subsequently posted to EDGAR. Accordingly, the statistics presented in the tables and charts below may be affected by reviews that are still ongoing or have recently been closed.
  • Pertains to 12-month periods ended July 31 (“review years”).