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

Letter Type E:

Dear SEC Officials, 
I am writing to oppose the proposed rule that would allow public companies to replace quarterly Form 10-Q reporting with semiannual reporting on Form 10-S.
I understand the concern that quarterly reporting can contribute to short-termism, managerial distraction, compliance costs, and an unhealthy culture of earnings theater. Those concerns should be taken seriously. I also recognize that not every company is situated identically. Smaller companies, pre-revenue companies, long-horizon companies, and companies in highly cyclical industries may experience quarterly reporting differently than large, mature issuers.

I would support a serious effort to reduce unnecessary reporting burden and short-term earnings pressure, especially for smaller issuers, so long as that effort preserves timely, standardized public information. But reducing standardized public disclosure from quarterly to semiannual reporting is too blunt a remedy.

The problem is not simply how often companies report. The deeper question is who has access to reliable information, when they receive it, and whether the public market remains a genuinely public field of visibility.

Quarterly reporting is not a perfect solution to the deeper problems of financialized capitalism. It does not by itself create justice, shared flourishing, or democratic accountability. But in a market system in which ordinary people’s retirement savings, pensions, public institutions, and communities are already deeply entangled, timely standardized disclosure remains an important accountability structure.

If required reporting moves from quarterly to semiannual, the period between official public financial updates doubles. During that longer gap, material business realities may develop well before ordinary investors receive a full public accounting. Insiders, large institutions, and professional market participants may still have access to alternative data, management access, analyst networks, industry intelligence, and other channels. Ordinary investors are more dependent on standardized public filings.

Reducing quarterly disclosure does not eliminate information. It risks redistributing informational advantage toward those already best positioned to obtain it.

The Commission should therefore distinguish between factual quarterly reporting and the unhealthy practices sometimes associated with quarterly capitalism. Quarterly earnings guidance, short-term compensation incentives, analyst pressure, and performative earnings management may all deserve scrutiny. But the remedy for those problems should not be to dim one of the few standardized sources of public information available to all investors at the same time.

If the Commission believes quarterly reporting is too burdensome, it should consider narrower reforms: simplifying Form 10-Q where appropriate, scaling requirements for smaller issuers, discouraging or regulating quarterly earnings guidance, improving material-event disclosure, or addressing incentive structures that reward short-termism. Those approaches would target the problem more directly while preserving the public transparency floor that ordinary investors rely on.

I am also concerned about comparability. If some companies report quarterly while others report semiannually, investors may find it harder to compare companies within the same sector, assess risk in real time, and distinguish genuine long-term strategy from avoidable opacity. Market discipline may not be sufficient to protect ordinary investors, because sophisticated actors can price and navigate reduced disclosure more effectively than retail investors can.

The burden should therefore rest on proponents of the proposed change to show that ordinary investors will not be harmed, that market transparency will not be meaningfully reduced, that liquidity and price discovery will not suffer, and that any compliance savings outweigh the public cost of less frequent standardized disclosure.

I urge the Commission not to adopt the proposed rule as written. At minimum, the Commission should preserve quarterly factual reporting as the default public transparency floor unless it can demonstrate, with strong evidence, that any alternative reporting regime will protect ordinary investors, preserve comparability, maintain timely access to material information, and avoid widening the gap between insiders and the public.

Transparency will not solve the deeper inequities of public markets. But reducing standardized public disclosure would increase the risk of informational domination. The Commission should not make public markets darker for the people least able to see through them.