The following Letter Type D, or variations thereof, was submitted by individuals or entities.Letter Type D:Dear Secretary, I am writing to express my strong opposition to the Securities and Exchange Commission’s proposed rule that would allow public companies to opt out of quarterly reporting (Form 10-Q) in favor of semiannual reporting on the proposed Form 10-S. While the Commission frames this as a measure to reduce regulatory burdens and curb corporate "short-termism," the actual consequence will be a severe erosion of market transparency that disproportionately harms retail investors while providing an unfair advantage to institutional "big fish." The proposed rule undermines the core mission of the SEC—to protect investors and maintain fair, orderly, and efficient markets—in the following ways: ### 1. Widening the Information Asymmetry Gap The public markets are supposed to operate on the principle of a level playing field. Moving from a 90-day reporting cadence to a 180-day cadence creates a massive data vacuum. Six months is an eternity in the modern economy; supply chain disruptions, shifts in consumer demand, and sudden fiscal pressures can fundamentally alter a company’s financial health in a fraction of that time. While everyday investors rely heavily on public periodic filings to evaluate their holdings, institutional investors, hedge funds, and large private equity firms do not. "Big fish" possess the capital and resources to bridge a six-month information gap by purchasing alternative data streams, hiring private research firms, utilizing satellite tracking, and maintaining direct lines of communication with corporate management. Retail investors will be left entirely in the dark, forced to make decisions using stale financial data while Wall Street operates with near-real-time insights. ### 2. Over-Reliance on Form 8-K and the Failure of Regulation FD The proposal suggests that event-driven disclosures (Form 8-K) and Regulation FD will adequately protect investors between semiannual reports. This is a flawed assumption. Form 8-K is triggered by specific, discrete material events (e.g., bankruptcy, executive turnover, major acquisitions). It does not capture the slow, cumulative erosion of profit margins, rising inventory costs, or deteriorating cash flows that are meticulously detailed in a Form 10-Q. Without granular quarterly financial statements, retail investors will lack the tools to diagnose structural corporate decline until it is too late. ### 3. Increased Market Volatility and Risk Fewer reporting intervals mean that when financial data is finally disclosed every six months, the market reactions will be significantly more volatile. Instead of adjusting stock prices incrementally based on quarterly performance, the market will endure massive, unpredictable swings as six months of accumulated, unpriced operational realities are dumped onto the public at once. Retail investors, who generally lack the sophisticated hedging strategies and algorithmic execution speeds of institutional traders, will bear the brunt of this heightened volatility. ### Conclusion Reducing corporate compliance costs should never come at the expense of market integrity and investor protection. If adopted, this rule will effectively re-privatize public market information, pricing out the everyday investor and turning back the clock on decades of transparency reforms. I strongly urge the Commission to withdraw this proposal and maintain mandatory quarterly reporting on Form 10-Q. The health of our public markets depends on equal, timely access to information for all participants, not just the wealthiest institutions. Sincerely,
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