Top 10 Practice Tips: Responding to SEC Comment Letters

Summary

This practice note outlines 10 practice points for public companies to consider when responding to comment letters from the Securities and Exchange Commission (SEC). The SEC is required to review the SEC filings of public companies at least every 3 years and sometimes does so more frequently. The SEC staff also conducts targeted reviews on specific issues or industries at times. Companies with large market capitalizations, material restatements, or market volatility may be reviewed annually or even continuously. It is also almost automatic to receive comments in an initial public offering (IPO) or in connection with the merger or sale of a publicly traded company.