Comments Based on Listing Status Comments Issued to Non-Listed REITs As is to be expected, the data from 2022 and 2023 indicates that non-listed REITs are more likely to receive comments regarding Compliance with Form Requirements, 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 accounting and non-GAAP. Non-Listed REITs’ Comments by Category 64% 9% 27% 2022 Financial Statements and Metrics Management and Governance Offering Information Valuation, Distribution Information and Share Repurchase Programs Compliance with Form Requirements 64% 9% 27% 2022 31% 15% 13% 35% 6% 2023 13 | A Comparative Analysis of 2022 and 2023 SEC Comments Issued to REITs
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