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Using the Comment Letters database
Who is this article for?
Users who want to learn about the Comment Letters database.
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The Audit Analytics Comment Letters database includes SEC staff reviews and company responses.Letters are indexed by 2,800 proprietary accounting issues.
The database is searchable by company, location, industry, and market cap.Filters available for US GAAP, IFRS, and federal securities laws.
It covers all '33 and '34 Act filers as required by the SEC.
1. Common uses
- Monitor SEC reviews and company responses
- Analyse responses to similar SEC comments focusing on key financial disclosures
- Identify and track SEC concerns to enhance filing reviews
- Monitor individuals (SEC staff, lawyers, executives) involved in SEC comments
- Benchmark comment letter issues by industry
- Search comment letters by issue, auditor, type, or filings
The Comment Letters database is available online, through WRDS, and as data feeds [Feed25 – Comment Letters and Feed26 – Comment Letter Conversations] with the relevant subscription.
- Saved Search Alert: Yes
- Daily Summary Email: No
2. Collection methodology
- The Comment Letters Data
- Sourced from comment letter types: UPLOAD, CORRESP, and COVER
- Collection prioritised by market capitalisation and comment type.
- Larger companies and relevant comments are prioritised over registration statements and proxy disclosures.
- Sourced from comment letter types: UPLOAD, CORRESP, and COVER
3. Searching
- The Comment Letters search page provides two search methods.
- Company Search includes these filters:
| Name | Description | Data Dictionary Field(s) | Sort By? |
|---|---|---|---|
| Filter by Auditor | Filter for a specific auditor or group of auditors. | Auditor | No |
| Search by Ticker or CIK Code | Filter results to a specific population. (Paste either Tickers or CIK Codes into box.) | CIK Code Ticker | Yes |
| Market Index | Filter for Market Index | Market | No |
| Search by Keyword | Search for letter containing keyword | N/A | No |
| Filter by Issue Taxonomy | Filter by taxonomy | Comment Letters Issues | No |
| Selected search items | Shows all selected search items from filters above | N/A | No |
| When searching referenced filings/taxonomies: | Match any criteria Match all criteria | N/A | No |
| Market Cap | Filter by a range of companies’ market caps. | Market Cap ($) | Yes |
| Revenue | Filter by a range of companies’ revenue. | Revenue ($) | Yes |
| Letter Date | Filter by the comment letter’s file date | Letter date | No |
| Dissemination Date | Filter by the file’s dissemination date | Dissemination date | No |
| Letter Type | Filter by EDGAR form type | Form type | No |
| Search Industries | Filter by companies’ industry(s) | SIC Code NAICS Code | No |
| Company Location | Filter by current business address location(s) | State Name Region County | No |
| Referenced filings | Filter by common filings | N/A | No |
People Search has the following filters:
| Name | Description | Data Dictionary Field(s) | Sort By? |
|---|---|---|---|
| People / People by Organization / Organization | Filter by people, organizations, or people by organizations | N/A | Yes |
| Filter visible (below) | Select letter for below filter | N/A | No |
| Filter visible (above) | Search in above filter | N/A | No |
| Search by Keyword | Search for letter containing keyword | N/A | No |
| Filter by Issue Taxonomy | Filter by taxonomy | Comment Letter Issues | No |
| When searching referenced filings/taxonomies: | Match any criteria Match all criteria | N/A | No |
| Selected search items | Shows all selected search items from filters above | N/A | No |
| Market Cap | Filter by a range of companies’ market caps. | Market Cap ($) | Yes |
| Revenues | Filter by a range of companies’ revenue. | Revenue ($) | Yes |
| Letter Date | Filter by the comment letter’s file date | Letter date | Yes |
| Dissemination Date | Filter by the file’s dissemination date | Dissemination date | Yes |
| Letter type | Filter by EDGAR form type | Form type | No |
| Search Industries | Filter by companies’ industry(s) | SIC Code NAICS Code | No |
| Company Location | Filter by current business address location(s) | State Name Region County | Yes |
| Referenced filings | Filter by common filings | N/A | No |
4. Results
4.1. Company Search
- View results at the bottom of the page.
- Access the following via hyperlinks:
- Download Comment Letters Data Dictionary
- CSV file downloads of results
- Download Letter Info or People data
- All CSV fields defined in the Data Dictionary
- Benchmark Comment Letter Issues
- Download results as ZIP file
- Company profile overview
- Overview of the comment letter on SEC website
4.2. People Search
- View results at the bottom of the page.
- Access the following via hyperlinks:
- Download Comment Letters Data Dictionary
- CSV file downloads of results
- All CSV fields are defined in the Data Dictionary
- Benchmark Comment Letter Issues
- Download ZIP file of results
- Overview of individual company profiles
- Overview of comment letter analyst
- Overview of comment letter on SEC website