SBAI Response to SEC Semiannual Reporting Rule (S7-2026-15)

In our response, we set out the key reasons why the SEC should retain quarterly reporting requirements for public companies and oppose the proposed introduction of semi-annual reporting on new Form 10-S.

Our key positions on the proposal:

• Quarterly reporting provides investors with timely, comparable information, supporting better investment decisions, and more efficient capital allocation.
• Regular public disclosure promotes equal access to information, reducing information asymmetries between different types of market participants.
• Frequent reporting strengthens market transparency, supports price discovery, and helps identify potential financial misconduct and emerging risks.
• Reduced disclosure would weaken market discipline, increase uncompensated risks for investors, and could discourage active participation in public markets.
• The SEC has not demonstrated that the proposal's potential benefits outweigh the significant costs to market transparency and investor protection.

If the SEC wishes to reduce the costs of being a public company, it should pursue targeted reforms rather than weaken a disclosure framework that underpins confidence in public markets. Evidence from similar reforms in the European Union's removal of mandatory quarterly reporting suggests that reduced disclosure can negatively affect analyst coverage, market liquidity, and the cost of capital which would be counterintuitive to the SEC's stated goals.