Hero Alimchandani, national office, managing director at Deloitte & Touche LLP, sat down for a video interview at Nareit's REITwise: 2025 Law, Accounting & Finance Conference® in San Antonio, Texas.
Alimchandani discussed the current priorities and trends within the SEC, as well as best practices for companies navigating SEC comment letters. The SEC’s core mission remains the same: to protect investors, facilitate capital formation, and maintain fair markets, he noted. However, the implementation of these goals may vary with each SEC chair.
He highlighted recent SEC priorities, including the delay of the climate rule, ongoing legal considerations surrounding it, and the shift in crypto regulations following the rescindment of staff accounting bulletin (SAB) 121. He also noted the SEC’s focus on the effectiveness of public company oversight.
Alimchandani also discussed trends in SEC reviews, noting that the average time and number of comment letters per review cycle had decreased until 2021, when the surge of SPAC IPOs led to an increase in reviews. He advised companies to maintain thorough documentation and respond in writing to SEC queries, ensuring they address all aspects of a comment letter carefully and respectfully.
Lastly, he addressed common topics of SEC comment letters across industries, with a focus on Management’s Discussion and Analysis (MD&A), non-GAAP measures, and material uncertainties. For the real estate sector, he mentioned heightened scrutiny of commercial real estate, particularly in the wake of COVID-19, with a focus on liquidity, leasing, and risk in banking portfolios. Non-GAAP measures also remain a key concern for SEC reviewers.