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On the Radar

SEC Comment Letter Considerations, Including Industry Insights

November 2023
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On the Radar
SEC Comment Letter Considerations, Including Industry Insights

The global business landscape has been changing rapidly, with higher interest rates, tightening credit, inflation, supply-chain and labor issues, geopolitical conflicts, and concerns about the real estate and banking sectors affecting markets worldwide over the past few years. As these trends persist, the transformative effects of generative artificial intelligence (often referred to as “gen AI”) may also have a significant impact on financial markets. The SEC continues to undertake rulemaking and provide registrants with proactive guidance as needed to respond to recent market developments while conducting ongoing reviews and oversight to protect investors. Under the leadership of Chair Gary Gensler, who took office in April 2021, the Commission has pursued a comprehensive rulemaking agenda embodying three key themes: efficiency and competition, integrity and disclosure, and resiliency of the markets. In the past year, the SEC has issued final rules on disclosure topics such as cybersecurity, share repurchases, and “clawback” policies and has continued to consider feedback received on proposed rules related to climate-change disclosures and special-purpose acquisition companies (SPACs).1 At the same time, the SEC has been addressing other issues in the marketplace, including significant growth in crypto assets and the rise of gen AI and data analytics.


A SPAC is a newly formed company that raises cash in an initial public offering (IPO) and uses that cash, the equity of the SPAC, or both to fund the acquisition of a private operating company.
The number of reviews with a comment in 2023 may be subject to change as more 2023 reviews with comment letters are posted to EDGAR.
Sample Letter to Companies Regarding Climate Change Disclosures.