Jul. 2, 2026
Re: File Number S7 2026 15 — Semiannual Reporting Proposal I am submitting this comment as an investor with a professional background in information technology, data architecture, and market data analytics. After reviewing the proposal, I strongly oppose allowing public companies to replace quarterly 10 Q reporting with optional semiannual reporting. Reducing disclosure frequency would materially weaken market transparency, impair data quality, and increase systemic risk across the financial ecosystem. Modern markets operate as interconnected data systems. Market data providers, analytics platforms, quantitative models, risk engines, and compliance systems all rely on structured quarterly disclosures to maintain accuracy and stability. These systems ingest financial statements, footnotes, segment data, and cash flow information as part of their core datasets. Extending reporting intervals to six months would create significant data voids that degrade signal reliability, increase noise, and reduce the effectiveness of risk detection across the entire market. From a market data perspective, semiannual reporting introduces three major risks: 1. Data Latency: Six month gaps force models to rely on stale fundamentals, increasing the probability of mispricing and volatility driven by information scarcity rather than actual performance. 2. Data Integrity: Longer intervals increase the likelihood that errors, misstatements, or adverse developments propagate undetected. Quarterly reporting provides a short feedback loop; doubling that window increases the risk of both accidental and intentional distortions. 3. Information Asymmetry: Companies already generate internal monthly and quarterly financials for operational decision making. Semiannual public reporting does not reduce the underlying workload—it simply restricts access to information that already exists. Insiders and sophisticated actors retain visibility while ordinary investors and smaller firms operate with incomplete datasets, undermining fair market principles. If the Commission is evaluating reporting frequency, the direction should be toward greater transparency, not less. Monthly reporting would better align with how modern market data systems operate. It would reduce information latency, improve model accuracy, strengthen risk controls, and enhance market integrity. Monthly reporting would materially improve investor protection; semiannual reporting would erode it. For these reasons, I urge the Commission to maintain quarterly reporting requirements and reject the shift to semiannual reporting. Reliable markets require reliable data, and reducing disclosure frequency would harm investors, distort market signals, and increase systemic risk. Thank you for considering this comment. Patti Held President/Consultant, Software Touch Corp.