A Comparative Analysis of 2022 and 2023 SEC Comments Issued to REITs

In recent years, the Securities and Exchange Commission (SEC) has increased its scrutiny of disclosure in public filings, as evidenced by an increase in the number of comments issued to public reporting companies. This trend continued in 2023, with more SEC comments issued than in 2022. The SEC’s comments continue to focus predominantly on financial statements and metrics, including the calculation and presentation of non-GAAP measures. With REITs frequently making headlines in 2023 and early 2024, the SEC is expected to maintain close scrutiny of their disclosures.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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