[WA]

What does drawndown have to do with ATH? The SPX is ~50 points (1.3%) from its ATH right now (3663 as of Friday close) vs ATH of 3715 on 12/9. It's reasonable to say "close to ATH".

Edit: Corrected points and added percentage.

[MR4D]

Depends on your tolerance band. If it’s zero, then only on days when you hit a new ATH can you count as “at ATH”.

If you set a 10% threshold, then you’ll have many more days “at ATH”.

My point is that actual ATH (versus “near ATH”) are comparably rare.