When the SEC reviews a 10-K, S-1 or proxy, it writes a comment letter and the company answers. EDGAR publishes both, the staff letter as form UPLOAD and the response as CORRESP, at least 20 business days after the review closes. They're a free window into what regulators are pushing on right now.
Where the letters live
- Daily form index:
https://www.sec.gov/Archives/edgar/daily-index/2026/QTR4/form.20261103.idx. Grep theUPLOAD/CORRESPlines. - Per company:
https://data.sec.gov/submissions/CIK0001045810.json. Filterformin (UPLOAD, CORRESP). - Full-text search:
https://efts.sec.gov/LATEST/search-index?q="non-GAAP"&forms=UPLOAD - Always send a User-Agent with a contact email, and stay under 10 requests/second (SEC fair-access policy).
A real example: NVIDIA, July 2025
The staff letter on NVIDIA's FY2025 10-K (released 2026-01-13) has 4 comments. The first one asks why non-GAAP margin excludes the $4.5B inventory charge. NVIDIA answered on 2025-07-31, and the review closed on 2025-09-10.
Doing it without code
We packaged this as an Apify Actor (SEC Comment Letter Scraper). Give it tickers, keywords or a date range. You get one row per letter with comment count, rule-based topics (non-GAAP, revenue recognition, segments, China/VIE, crypto…), the filing under review and links. Each letter costs $0.01, and a free sample mode returns 5 letters.
{ "keywords": ["non-GAAP"], "forms": ["UPLOAD"], "letterTypes": ["sec_staff_comment"], "startDate": "2026-01-01" }
In our test this returned 25 staff letters from 63 full-text hits, including Avantor, Choice Hotels and the draft S-1 of Madison Air Solutions (19 comments).
Who uses it: SEC reporting teams benchmarking peers, analysts watching for red-flag reviews, and securities lawyers looking for companies in active review.
Not affiliated with the U.S. SEC.
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