Jul. 28, 2026
Dear Sirs, Regarding the proposed substitution of quarterly reporting of public companies to the SEC for semester reporting, I hereby give my comments within the open comments period. Quarterly reporting should be retained because it is the foundation of the informational fairness on which U.S. capital markets are built. Regular, standardized disclosure narrows the gap between what insiders know and what ordinary investors know. Under a semiannual regime, material information would not cease to exist for six months - it would simply circulate selectively, through private channels available to large institutions and connected parties, while retail investors trade in the dark. The result would be wider information asymmetry, more rumor-driven volatility, and an erosion of the trust premium that makes U.S. markets the deepest and most liquid in the world. The cost argument is weak: well-run companies already produce this financial data internally every month for their own management. Publishing what already exists is a marginal burden, not a structural one. And the short-termism critique confuses reporting with guidance - companies concerned about quarterly pressure can stop issuing earnings guidance, a voluntary practice, without dismantling mandatory transparency that protects all investors equally. In short: quarterly reporting costs little, informs everyone, and disciplines management. Reducing it would save companies a rounding error while transferring a real informational advantage from the public to the privileged. I am a small investor and truly feel that this will certainly damage my options to properly allocate my investments. Nestor Guillen, CPA Independent Public Accountant Nestor L. Guillen, MBA, CPA