SEC Shutdown Aftermath: What Issuers Can Expect Now

With the government shutdown in the rearview mirror and the SEC back to full strength for about a month, many issuers are now confronting a predictable side effect: a backlog hangover. While the lights are back on at the Commission, things are not quite "business as usual" yet.

Filing Review Backlog

Review queues are longer. Registration statements and periodic reports submitted during and immediately after the shutdown are competing for staff attention. Expect elongated review timelines, especially for first-time registrants and complex offerings.

Comment letters may be delayed—but still thorough. The SEC staff may take longer to issue initial comment letters and to turn comments around. Once comments arrive, assume the same level of scrutiny you are used to, just on a slightly slower conveyor belt.