An Analysis of 2021 and 2022 SEC Comments Issued to REITs

Non-Listed REITs’ Comments by Category Financial Statements and Metrics Management and Governance Portfolio Information Macroeconomic Offering Information Valuation, Distribution Information and Share Repurchase Programs Compliance with Form Requirements 22% 1% 15% 11% 4% 36% 11% Comments Issued to Non-Listed REITs As is to be expected, the data indicates that non-listed REITs are more likely to receive comments regarding Management and Governance, Offering Information and Valuation, Distribution Information and Share Repurchase Programs than listed REITs. Financial statements and metrics remained one of the top categories of comments by number, with the most frequent topic related to property acquisitions and the requirements under Regulation S-X. Comments Based on Listing Status 15 | An Analysis of 2021 and 2022 SEC Comments Issued to REITs