SEC comment letters trends in three charts: fewer releases and longer delays

What the data shows about oversight shifts and why dissemination lags matter for investors.

In August 2025, the SEC’s Office of Inspector General (OIG) released a report on the Division of Corporation Finance’s Disclosure Review Program (DRP), which oversees reviews of public company filings. While the report acknowledged that the DRP continues to meet statutory oversight requirements, it highlighted vulnerabilities tied to staffing levels. With the program operating at under 300 employees and experiencing roughly 10% attrition, the OIG warned that reduced headcount poses risks to retaining institutional knowledge and to the program’s ability to keep pace with emerging disclosure issues, such as crypto assets and increased nonpublic company registration submissions.

Comment letters are important to investors because they flag disclosure deficiencies that are material to understanding a company’s business trends and accounting practices, and making an informed investment decision. According to the report, materiality to investors is the key determination in the decision to iss…