This summer, more than 200,000 Americans filed comments on the SEC proposal to let public companies go dark for 6 months at a time, by reporting results twice a year instead of every quarter. It was the largest public response in the agency's 92-year history, and an independent Ohio State tracker read the letters: 99% opposed. The chairman's takeaway? That the letters reflect “a misunderstanding” of the proposal. Now the SEC is trying to move forward anyway.
Tell the SEC: We're Not Confused →May 2026. The SEC proposes letting public companies report financials twice a year instead of every quarter. Framed as harmless, because switching is optional.
The public answers. 200,000+ comments, the most in SEC history, and 99% opposed: six-month blind spots, a bigger insider edge, more room for fraud to grow.
July 30. The chairman brushes it off. The letters reflect “a misunderstanding,” he says, since quarterly reporting stays optional.
Now. Optional is the pretext: once the giants switch, cost pressure makes it everyone's standard. Exxon is already on record backing the switch, and Eli Lilly has announced it anticipates dropping the 10-Q.
Optional is exactly what we oppose. Once reporting less is allowed, cost and competitive pressure make it the standard: in a CFA Institute survey, fewer than a third of investment professionals expect companies to keep reporting quarterly once it becomes voluntary. The few supportive letters in the docket came from Exxon Mobil, insurance brokerage Gallagher, and a coalition of large pharmaceutical companies, and Eli Lilly has already signaled it anticipates switching. The likely day-one adopters are lining up. The election is made by management, with no vote by the public, or by the shareholders who actually own the company.
Meanwhile, The Wall Street Journal reports the SEC is expected to move forward with the rule regardless, through a Commission currently operating with just three members. A regulator who hears no from 99% of the people he serves and concludes they are all confused isn't listening. So we'll say it again, on the record.
“As a childhood cancer nonprofit, we rely on transparent and timely quarterly reporting to help assess the trajectory, stability, and scientific progress of biopharma companies developing promising therapies or contributing to the development of treatment.
Without this information, we would have misplaced donations, and wasted time that kids with cancer don't have.
There's more than just money on the line.”
“Quarterly reports are the single most important leveling mechanism between retail and institutional investors in U.S. equity markets. Institutional investors have expert networks, channel checks, alternative data, satellite imagery of retailer parking lots, credit card panel data, and direct management access through conferences and one-on-one meetings that cost more than most of our portfolios. We have the quarterly report.”
“I strongly agree that this is a bad move for individual investors — it creates opacity and undermines trust.”
A public school teacher reminded the Commission that she is required to report grades every quarter so parents can track their child's progress, and that by the SEC's own logic it “wouldn't mind if your child's teachers only reported out twice a year.”
Executives always know how the business is doing. The only question is how long the rest of us wait to find out. This rule stretches that gap from three months to six, and investment professionals surveyed by CFA Institute ranked the longer insider-information window among their most serious concerns. Plenty of time to quietly sell their shares to you (or your ETF) before the bad news lands.
The pitch is ending short-termism. The UK ran this exact experiment, dropping mandatory quarterly reporting in 2014, and researchers found no change in long-term corporate investment, while analyst coverage and forecast accuracy suffered. Short-termism lives in executive pay, not the filing calendar; a company chasing the next report will simply chase it every six months instead. The benefit is a mirage. The lost transparency is real.
Since Enron, every CEO and CFO must personally certify each 10-Q, swearing to the numbers and the company's internal controls, with federal prison on the line for certifying a lie. Press releases and earnings calls carry none of that: no certification, no auditor review. Cutting the 10-Q cuts from four to two the yearly moments when someone at the top stakes their freedom on the books. The "savings" aren't just financial - they're a get out of jail free card to execs.
This is the chairman's entire defense: nobody has to switch. But in a CFA Institute survey, fewer than a third of investment professionals expect quarterly reporting to survive once it becomes voluntary. The supportive letters came from giants like Exxon Mobil, and Eli Lilly already anticipates switching. Management makes the election; shareholders get no vote. Once the biggest companies file less, cost pressure drags the rest down with them. A choice for them, a new normal for you.
The formal deadline passed, but the docket doesn't shut until the Commission acts. The SEC continues to accept late comments into the same public file while the rule is pending, and the record it votes on, the one any court will review, includes them. Right now, a second wave of letters does something the first couldn't: it answers the chairman's claim that the first 200,000 were confused.
Say it plainly: you read the proposal, you understand it makes quarterly reporting optional rather than abolishing it, and optional is exactly what you oppose. Then add your own words about why it matters to you, your retirement savings, the insider advantage, the room it gives fraud. A record full of "I understood it, and I still oppose it" letters takes away the only public defense he has offered.
Optional is the trap. The election is made by management, with no vote by shareholders or the public. Fewer than a third of investment professionals surveyed by CFA Institute expect quarterly reporting to survive once it becomes voluntary; Exxon is on record backing the switch and Eli Lilly already anticipates dropping the 10-Q. Once the giants file less, cost and competitive pressure pull everyone else down to the new floor. And the companies most eager to go dark are precisely the ones whose investors most need the light.
That's the SEC's main argument for the change, but the evidence doesn't really support it. The UK and EU studied the move to semiannual reporting and found no meaningful improvement in long-term investment behavior. They did find more stock-price volatility and overreaction when reports finally arrived. "Short-termism" is really about how CEOs are paid and how boards measure success, not how often companies file paperwork. Hiding the data doesn't fix the underlying problem; it just hides the consequences.
The SEC keeps citing the "global standard," but that standard isn't doing well in the places it was tried. The EU's lighter regime is where Wirecard's €1.9 billion fraud hid in plain sight for years before the company collapsed in 2020. The UK's 2014 shift stripped analyst coverage from mid-cap stocks, and London has been bleeding IPOs ever since. Singapore moved to semiannual reporting in 2020 and is now reconsidering, because trading volumes fell and disclosure quality dropped. The "global standard" the SEC is invoking isn't standard, isn't working, and is being walked back where it was tried.
Yes. Agencies are legally required to grapple with the substance of the record before them, and courts have overturned final rules when they failed to. The size and clarity of this record, already the largest in SEC history, is exactly what any review of the final rule will examine. A comment that says "I understood the proposal and I oppose it" makes that record impossible to wave away as confusion.
No. Plain-English comments from ordinary investors are exactly what the SEC needs to hear. You don't need to cite securities law. Saying something like "I'm a retail investor, I read the proposal, and I rely on quarterly reports to make decisions about my retirement savings" is genuinely valuable on the record.
Late comments still go in the public file while the rule is pending. Make yours impossible to misread.
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