If you track any of the “daily digests” for Staff comments, you might have noticed that the volume of Staff comments seems lower lately. It’s not always straightforward to estimate changes to comment letter practices, but Olga Usvyatsky recently took a stab at it in her “Deep Quarry” newsletter – and it appears the decrease for disclosure review comments wasn’t just in our imaginations. Here’s what she found:

Based on my analysis of the Audit Analytics data, 263 SEC reviews of periodic filings were released on EDGAR between January and April 2025 – a decline of 20% and 26% compared to the first four months of 2023 and 2024, respectively. However, it is unclear whether the decrease compared to the 2023-2024 level reflects a shift in SEC priorities or if this is merely a mechanical decline related to a lower number of reviews initiated in the second half of 2024.

The former explanation implies that the number of reviews is likely to revert to the 2020-2021 level, while the latter suggests we may see an even sharper decline on a full-year basis.

To arrive at these numbers, Olga compared the number of conversations with a closing letter on EDGAR during the applicable periods. Olga also shared data that shows a longer-term decline:

Over the past decade, the total number of SEC comment letter conversations referencing periodic filings has generally declined, with a peak in 2015 and a low in 2021, followed by a brief rebound through 2022 before declining again in 2024, according to a report by Ideagen Audit Analytics.

For the scoop on the comment letter process for both ’33 Act registration statements and ’34 Act reports, check out our 52-page handbook…

– Liz Dunshee