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On the SEC and CIT…

Though it’s been awhile since we last footnoted CIT Group (CIT), given the news over the past few days, it seemed like a good idea to take a closer look at their filings.

One of the things that immediately jumped out was the relatively long string of comment letters between the company and the SEC, some of which just appear to be made public relatively recently. First, a reminder on comment letters: corresp are the letters that the SEC send to companies; uploads are the companies’ responses and uploads are the letters that the SEC sends. (Ed note: I don’t know why I can’t keep this straight in my own head!Grrrrr!) For some reason, Edgar always handles corresps as PDF files and uploads as links. And while the letters become eligible for public release 45 days after the issue has been deemed resolved, it doesn’t always work that way, which makes finding comment letters a bit tricky since you really have to be looking for them.

Now, the letters, the most recent of which was dated March 26 which is focused on disclosures in CIT’s proxy statement. Three days earlier, there was this longer letter which raised questions about CIT’s participation in Treasury’s Capital Purchase Program. Be sure to have a cup of coffee in hand before sitting down with this one!

All told, there’s been 13 letters back and forth between the SEC and CIT over the past year, which, trust me on this one, is a fair amount of correspondence, given everything else the SEC has on its plate. Still, until the SEC improves the way it handles comment letters, these incredibly useful documents will remain largely a historical exercise to look at after things start to go wrong, instead of a helpful tool for spotting problems in the past.