Form CORRESP is an EDGAR form type that registrants can use to submit non-public information (generally correspondence) to SEC staff. The information in Form CORRESP is not disseminated immediately but may be released in part or in whole by the SEC, if the documents within the filing relate to the SEC’s review process.

You can prepare Form CORRESP like other EDGAR filings. The document for the form must be prepared in an EDGAR format such as plain text (ASCII) or HTML, in accordance with the EDGAR Filer Manual. You can then attach that document to the CORRESP submission type. A PDF copy of the document can also be included with the filing.

The public can search directly for Form CORRESP filings made after August 1, 2004 that pertain to disclosure filings and that were reviewed by the Division of Corporation Finance and the Division of Investment Management and released by the SEC. To search for Form CORRESP filings, you can use the Historical Archive Search (enter “type=corresp” into the search field to narrow the results to Form CORRESP filings; you can also include additional search terms to further refine your results). You can search similarly for CORRESP filings using the EDGAR Full-Text Search.

The other method of providing correspondence to the SEC is to include the correspondence as a document on another filing. To do this, you create the other submission and add all other documents (the primary document and any exhibits). Then you can prepare a document for the correspondence in text or HTML and attach it to the submission using the CORRESP document type. Submissions can have multiple CORRESP documents attached to them. Using the CORRESP document type means that the document(s) marked as correspondence will not be immediately disseminated to the public; the remainder of the submission that contains the CORRESP document(s) will be publicly disseminated as normal. However, it is worth noting that any graphics used within an HTML CORRESP document will be disseminated as part of the regular submission. This means that, if you include a chart or other sensitive data within an image, it may be viewed by the public before the corresponding document is available, so you should exercise caution when using the CORRESP document type as an attachment to a filing when that document contains images.

When a correspondence is attached to another submission type, it is not as easy for EDGAR users to search for and retrieve that information. However, all filings that include correspondence released by the SEC contain “[Cover]” in the document description list. You can view and read the full thread of correspondence between SEC staff and a registrant by viewing a company’s filings and looking for the submission type UPLOAD (for SEC staff comments) and the submission type CORRESP and the “[Cover]” term in other submissions (for registrant correspondence and responses).

The GoFiler software has all the tools needed to create both the correspondence document and the Form CORRESP submission type. GoFiler can also submit your Form CORRESP filings directly to the SEC. If you’d like more information about GoFiler or about correspondence filings, please contact our team at support@novaworkssoftware.com.

Additional Reading:

http://www.sec.gov/answers/edgarletters.htm

http://www.sec.gov/news/press/2004-89.htm

http://www.sec.gov/info/edgar/edgarfm-vol2-v33.pdf