An Analysis of 2021 and 2022 SEC Comments Issued to REITs

4 18 11 6 74 Listed 65 6 1 1 Non-Listed Comments by Filing Type S-3 S-11 8-K 10-Q 10-K The majority of comments issued to non-listed REITs related to registration statements. Of the 73 comments issued to non-listed REITs, approximately 89%, or 65 comments, related to registration statements on Form S-11. The remaining 11%, or eight comments, related to Forms 10-K, 10-Q and 8-K. Conversely, the majority of the 113 comments issued to listed REITs, 91 comments, or approximately 80.5%, were directed at periodic reports, with Annual Reports on Form 10-K garnering the most comments. Unsurprisingly, non-listed REITs received the most comments regarding valuation and calculation of net asset value as well as their share repurchase and redemption programs. The majority of comments issued to listed REITs related to financial statements and metrics. See below for a further breakdown of comment categories and for a deeper dive into comment trends for both listed and non-listed REITs. An Analysis of 2021 and 2022 SEC Comments Issued to REITs | 6