In the above table, turnaround time was measured in two different ways. In each method, only the amount of time that the document is being worked on by NFA staff is counted. The time spent by the firm making revisions and sending the revisions to NFA is not included in either method. The first method employed above measures the total "review life" of a disclosure document. The "review life" begins the day that NFA receives the disclosure document and ends the day the disclosure document is accepted. Each step in a document�s "review life" is added together to arrive at a turn around time. The second method measures how long it took for NFA to respond to each "discrete event." A "discrete event" can be the time between the receipt of the disclosure document and its acceptance with no comments; it can also be the time between the receipt of the disclosure document and a comment letter. Finally, it can be the time between the receipt of revisions to a comment letter and acceptance by NFA.Division staff believes that the first method is a more complete representation of turnaround time, but both methods have been calculated and presented in the table.