After the involved research and solution building related to disclosure issues have been completed, there remains the risks and uncertainty of the SEC staff's treatment. As all companies having experience with the staff are aware, there is an interpretive bias that exists over the body of the staff and its hierarchy. A similar disclosure solution can be ruled on quite differently by various members of the staff. When navigated properly, reasonable and equitable full-disclosure solutions, consistent with industry peers, can be achieved.

Accomplishing this requires an understanding that there is a unique process for resolving disclosure issues at the SEC. In order to resolve them as quickly as possible, in the full interests of investors and without undue penalty to the client, it is essential to understand the solution model used by the staff and to be aware of the dialogue and interaction that exists between review staff, their managers and the senior offices such as the Chief Accountant of the Division of Corporation Finance, as well as the involvement of external offices such as the Office of the Chief Accountant to the Commission. Treating these relationships properly enables expedient and valid disclosure solutions.