Comment letter risk assessment identifies which sections of your draft 10-K or 10-Q are most likely to attract SEC staff scrutiny before filing. Finrep ranks each section using sector-specific comment patterns and post-comment peer language, showing how peers revised after similar comments. The committee sees the risk surface, not just the filing.
Last updated: 2026-04-23















































See what a Finrep comment letter risk assessment looks like on real public company filings. Download and review the full output.
SEC Reporting · Pre-Filing
The SEC Division of Corporation Finance reviews filings on a cycle. The topics they focus on are sector-specific and they repeat: revenue recognition granularity in SaaS companies, lease modification disclosures in REITs, goodwill impairment assumptions in serial acquirers.
The patterns are knowable. Assembling the evidence takes days the close cycle does not have. So the assessment does not happen. The filing routes without a risk view. The team learns about disclosure weaknesses after the filing is public.
Manual process
Automated workflow
Drop your 10-K or 10-Q. Finrep parses all items, footnotes, tables, and policy disclosures.
Confirm SIC or GICS code. Finrep retrieves sector-specific comment patterns: which topics drew scrutiny and how frequently.
Each section ranked high, elevated, or baseline. High-risk sections show the specific comment patterns that apply and post-comment peer revisions.
Address high-risk sections while the draft is in progress. Export the risk assessment for committee review.
Section-by-section risk ranking with comment patterns and post-comment peer language
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Rankings built from comment letter history specific to your sector: which ASC topics drew questions, which sections attracted scrutiny, how frequency has shifted. A SaaS company sees ASC 606 disaggregation patterns. A REIT sees ASC 842 modification patterns. Three-year lookback, weighted toward the most recent four quarters.
For every high-risk topic, the output includes how peers revised their disclosures after receiving similar comments. The actual language filed in the subsequent period, not a summary of the comment. Shows what the SEC staff considered an adequate response.
Each section classified as high risk (matches active sector patterns with high frequency), elevated (intermittent or trending upward), or baseline (no significant pattern match). Calibrated per sector: high risk in biotech differs from high risk in retail.
For high and elevated sections, the specific SEC staff comment language shown alongside your draft for the same topic. Not "the SEC has asked about revenue recognition." The actual question, verbatim, from the EDGAR comment letter archive.
Section-by-section risk view grounded in your sector's comment history, before the draft reaches committee.
Comment patterns and post-comment peer language before the letter arrives. Preparation replaces reaction.
Historical SEC comment letters from EDGAR, filtered by sector and weighted by recency. Three-year lookback, higher weight on the most recent four quarters.
Other use cases Finrep handles for SEC Reporting teams.




