The following Letter Type B, or variations thereof, was submitted by individuals or entities.

Letter Type B:

To the Securities and Exchange Commission:

I am writing to express my strong opposition to the Commission’s proposed rule, File No. S7-2026-15, which would eliminate the mandatory quarterly reporting framework (Form 10-Q) in favor of a semiannual reporting model via the proposed Form 10-S.

While the stated objective of reducing administrative compliance burdens for public issuers is understandable, the proposed rule introduces severe structural risks to market efficiency, price discovery, and investor protection. Eliminating quarterly updates fundamentally compromises the data density required for accurate market evaluation and introduces several critical vulnerabilities into our financial ecosystem:

1. Distortion of Price Discovery and Increased Market Volatility

Efficient price discovery relies on a continuous, predictable flow of high-quality, verified financial data. Extending the reporting interval from three months to six months creates an information vacuum. In a fast-moving economic environment, a 180-day gap is long enough for material changes—such as shifts in operational margins, debt accumulation, or supply chain disruptions—to compound unnoticed.
When material data is finally disclosed after a six-month silence, the market will force abrupt, violent price corrections rather than the incremental adjustments facilitated by quarterly reporting. This structural volatility harms long-term investors and increases capital costs for issuers due to the heightened risk premium demanded by the market.

2. Exacerbation of Information Asymmetry

The elimination of Form 10-Q will not stop information from moving; it will simply change who gets it first. Institutional investors, market makers, and large buy-side firms possess the resources to utilize alternative data streams—such as private channel checks, proprietary satellite imagery, and direct executive access—to bridge a six-month disclosure gap.
Retail investors, independent analysts, and self-directed retirement savers (managing long-term IRA and 401(k) allocations) depend heavily on standardized, audited public filings to maintain a level playing field. Removing the 10-Q framework systematically disenfranchises retail market participants, widening the information asymmetry gap and undermining the SEC’s core mandate to maintain fair, orderly, and efficient markets.

3. Delayed Detection of Corporate Distress and Fraud

The quarterly reporting discipline acts as a critical operational check and balance. Regular, standardized disclosure deters financial manipulation and forces early recognition of structural failures. Under a semiannual framework, struggling corporate management teams are granted an extended runway to obscure operational distress, ballooning liabilities, or material litigation risks. By the time a Form 10-S is filed, the damage to investor capital may be irreversible, rendering early-warning indicators useless.

Conclusion

The existing quarterly reporting framework has been the bedrock of capital allocation efficiency in the United States for over half a century. The compliance cost savings achieved by eliminating Form 10-Q are vastly outweighed by the systemic costs of increased market volatility, reduced transparency, and diminished investor confidence.

For these reasons, I urge the Commission to withdraw Proposal S7-2026-15 and retain the mandatory quarterly reporting framework to preserve the integrity of our public markets.

Thank you for your time and consideration of these comments.