Skip to Main Content

Keeping you informed

Practical Tips for Navigating SEC Comment Letters

Corporate Compliance Insights

  • February 27, 2020

]Doug Harmon co-authored an article in Corporate Compliance Insights on how to handle a critical aspect of Securities and Exchange Commission (SEC) compliance. 

"Receiving a comment letter from the SEC can be a daunting experience," Doug and the co-author wrote. "A comment letter, which is a letter sent by the Division of Corporation Finance staff containing comments on disclosures a company has made in an SEC filing, can come out of the blue, require a significant amount of work that includes executive and board involvement, and result in changes to disclosures and internal processes. At the completion of the comment letter review process, the correspondence between the SEC and the company is made public, so a poorly handled response can bring a company unwelcome attention and reveal missteps."

"Thorough preparation is critical to successfully navigating the comment letter process, from before the letter arrives to after the completion of a response," they continued. "From our collective experience on multiple sides of that process – sending out letters as a member of the SEC’s Division of Corporation Finance, responding in-house at a publicly traded company, and counseling public companies on their responses – here are a few practical tips."

You can find their tips in the full article. Corporate Compliance Insights is a leading publication serving the global compliance community.