Subject: Comment on S7-2026-15
From: James R. Madden
Affiliation:

Jun. 22, 2026

Prior to the Sarbanes-Oxley Act of 2002, too many CEOs and CFOs did not take personal accountability for the accuracy of their quarterly and annual financial filings, often relying on "plausible deniability" if discrepancies or fraudulent activities were later uncovered. 

While federal laws already mandated that public companies provide accurate disclosures to shareholders, top executives could legally delegate compliance responsibilities and often distance themselves from the day-to-day accounting processes. Because they were not required to personally guarantee the figures, executives were primarily incentivized by quarterly profit targets and stock performance. 

This corporate environment fostered significant management fraud and lax reporting, culminating in massive accounting scandals at corporations like Enron. The Sarbanes-Oxley Act completely overhauled these dynamics by permanently altering executive accountability. 

Keep It Quarterly! No changes to reporting intervals! 

James R. Madden 
Chemical Engineer, IT Consultant 
7515 Sheringham Ave 
Baton Rouge, LA 70808-5762 
225.266.6196 mobile