Methodology
What the numbers on this site mean, how they are produced, and what they cannot support. Read this before quoting anything here.
Sources
Everything comes from the SEC's EDGAR system. Two form types matter: UPLOAD, the
staff's comment letter to a company, and CORRESP, the company's reply. This build is
based on CORRESP, because a response letter conventionally reproduces each staff comment
verbatim before answering it — putting the comment, the response, and the outcome in one document.
Extraction
Comments and responses are separated by deterministic parsing — regular expressions anchored on response headings and numbered comment openers. No language model produces any text, number, name or date on this site. Each stored comment keeps its character offsets into the cleaned source document, and a verifier re-reads every source and asserts that the text at those offsets still matches what is stored. That check currently passes on every quotation in the corpus.
Counting
Filing counts come from EDGAR's quarterly form.idx index files.
They are not taken from EDGAR full-text search, which caps result totals at 10,000 and
reports the cap as though it were a count — a trap that silently corrupts any long-run series built on
it.
What is in the corpus right now
Measured on the corpus as it stands: 4,297 staff comments drawn from 552 substantive comment-response letters (1,348 CORRESP filings examined, 2023-01-03 to 2025-12-17).
| Letter kind | Filings | Share |
|---|---|---|
| substantive | 552 | 40.9% |
| acceleration_request | 494 | 36.6% |
| short_cover_letter | 147 | 10.9% |
| unclassified | 142 | 10.5% |
| supplemental_materials | 6 | 0.4% |
| transmittal_letter | 5 | 0.4% |
| unlabelled | 1 | 0.1% |
| withdrawal | 1 | 0.1% |
Most CORRESP filings are not comment responses at all — a large share are Rule 461
acceleration requests and similar procedural cover letters containing no staff comments. They are
identified and excluded rather than counted, which is why the substantive figure is far below the raw
form count.
Topic matching
Issue pages are assembled by matching regular expressions against the verbatim comment text. This is transparent and reproducible, and it is coarse: it will group a passing mention with a substantive objection, and a comment raising several issues appears under each. Span-justified classification is the next piece of work. Until it lands, treat topic counts as an index, not a statistic.
What these numbers cannot support
- They are not SEC-wide totals. They describe this corpus, which does not yet cover every published letter. A share here is a share of what has been ingested.
- They are not a basis for annual projections. Extrapolating a full-year figure from a partial corpus produces a number that looks authoritative and is not.
- They say nothing about any company. Receiving a comment is an ordinary part of SEC review, not a finding of wrongdoing.
- They are unsuitable for trading. Comment letters are published roughly 20 business days after a review concludes.