SEC Suspensions & Revocations

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I believe a company's failure to respond to the SEC letter gets a negative action from the SEC more often in the revocation area than the suspension area

Maybe. The SEC does send delinquency letters to most delinquent issuers, though it's not an absolute requirement. If a company fails to do anything about a letter it receives, suspension and an administrative proceeding to revoke registration may follow about six months late. Sometimes more quickly. But on the other hand, sometimes the SEC sends the letter and then apparently forgets all about it, only to act years later.