Semi-annual reporting for SEC-registered companies?

Coming soon (in my opinion). The President is not the first to suggest that SEC-registered companies be permitted to choose semi-annual instead of quarterly reporting. The idea has been periodically floated since I was an SEC Staffer back in the Dark Ages (less than a generation after quarterly reporting was adopted in the first place).

But SEC Chair Paul Atkins says he’s fast-tracking the President’s proposal. What does he mean by this? There are various ways of making a change like this. The SEC could put out a Concept Release, followed by a series of roundtables where the great and the good present opposing positions, followed by a summary of comments received, followed by a Proposing Release, a Reproposing Release reflecting comments received, and then an Adopting Release. That could take several years (and I’ve worked on rule changes that followed that pattern). Or the Staff could be directed to start working on a proposal this week,* with a Proposing Release to be voted on by Halloween, a 60-day comment period (which would require taking a robust approach to the impact on smaller registrants), a vote on adoption by New Year’s Eve, and effectiveness before the first quarter 2026 has even ended. Will that happen? No, never has. But if I had to put money on this issue, I would be betting that it will happen, and that it will happen in a matter of months.

Is it a good idea? We can discuss that more when we see the actual proposal. But I do know that we have several smaller-than-micro registrants among our client base who will be delighted if this happens.

*Assuming the government stays open.

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