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

S-3 S-11 8-K 10-Q 10-K In both 2022 and 2023, the majority of comments issued to non-listed REITs related to registration statements. In 2023, of the 54 comments issued to non-listed REITs, approximately 56%, or 30 comments, related to registration statements on Form S-11. The remaining 44%, or 24 comments, related to Forms 10-K, 10-Q and 8-K. In 2022, of the 11 comments issued to non-listed REITs, approximately 55%, or six comments, related to registration statements on Form S-11. The remaining 45%, or five comments, related to Form 10-K. Conversely, in both 2022 and 2023, the majority of comments issued to listed REITs were directed at periodic and current reports. In 2023, 58 of the 59 comments issued to listed REITs, or approximately 98.3%, were related to periodic and current reports. In 2022, all 45 comments issued to listed REITs, or 100%, were related to periodic and current reports. In both 2022 and 2023, Annual Reports on Form 10-K garnered the most comments. Unsurprisingly, for both 2022 and 2023, 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 in 2022 and 2023 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. 30 18 2023 Non-Listed 2023 1 5 6 5 2023 Non-Listed 2022 3 3 39 2023 Listed 2022 45 11 2 1 2023 Listed 2023 Comments by Filing Type A Comparative Analysis of 2022 and 2023 SEC Comments Issued to REITs | 6

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