Subject: Comment on S7-2026-15
From: Michael Smith
Affiliation:

Jun. 20, 2026

I am private investor, within literally days of retirement, with all my stock and other investments held by mutual funds in an account managed by a financial advisor. This is a time for increased corporate transparency and accountability to shareholders, not less. The difference in cost between semi-annual and quarterly reporting is well justified. 

The oft-repeated criticism that companies manage their businesses quarter-to-quarter at the expense of a longer range view is not specious, but it is misplaced. To use that as an argument for less frequent reporting is, frankly, insulting to investors. It is up to investors and prospective investors, with the assistance of the many sources of analytical information available today, to decide for themselves how to use the information. I want my financial advisor and the managers of the mutual funds I hold to have as much information available to them as possible so they can, as quickly as possible, identify companies that manage to quarterly earnings reports to the detriment of long term results. A company that, today, manages its business with an eye only on the next 10-Q is unlikely to improve its performance by managing with an eye to the next 10-S, but cutting the frequency of reporting in half will make it more difficult to identify them. 


Thank you for considering these comments. 
______________________
Michael Ray Smith