PROTECTING SMALL BUSINESS, PROMOTING ENTREPRENEURSHIP

Coalition Comments to SEC in Support of Proposed Rule on Semiannual Reporting

By at 6 July, 2026, 5:54 pm

The Honorable Paul S. Atkins
Chairman
U.S. Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549

Dear Chairman Atkins:

As leaders of conservative and free-market organizations interested in reducing red tape that
limits opportunities for middle-class investors and entrepreneurs, we applaud the SEC for this
proposed rule to give public companies the option of semi-annual reporting.

We believe that easing the reporting mandate to semiannual from quarterly is long overdue, as
most other countries have moved away from or never implemented requirements for public firms to report to investors this frequently. Thus, the current mandate puts American companies and their shareholders at a competitive disadvantage.

The costs of the quarterly reporting mandate are substantial, and giving companies the
semiannual option would result in significant savings for many firms. As noted in this rule from
the SEC’s economic analysis, a company that took advantage of the option to move from
quarterly to semiannual reporting would save on average $198,000 per year. This savings could
be used to pursue growth opportunities for the company that could benefit its employees and
shareholders.

As the rule notes, the reduced costs of semiannual reporting “could also be a positive factor in
encouraging additional companies to raise capital through registered securities offerings or to
become or remain a public company.” It is important to also note that this rule does nothing to
change the SEC’s numerous anti-fraud rules and requirements that public companies
immediately disclose material events that could affect financial performance.

This rule is ultimately about advancing investor choice. If investors really like quarterly financial reports, they could find companies that still issue them. But investors who would rather companies use the cost savings to enhance their bottom line should not be denied the benefits of the semiannual option.

Thank you for your consideration on this important matter.

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