The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Sat, 11 Jul 2026 11:30:17 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Comment Letter on the SEC’s Proposal to Replace Quarterly Reporting with Semiannual Reporting – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Comment Letter on the SEC’s Proposal to Replace Quarterly Reporting with Semiannual Reporting https://corpgov.law.harvard.edu/2026/07/11/comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-3/?utm_source=rss&utm_medium=rss&utm_campaign=comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-3 https://corpgov.law.harvard.edu/2026/07/11/comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-3/#respond Sat, 11 Jul 2026 11:30:17 +0000 https://corpgov.law.harvard.edu/?p=182553?d=20260710170433EDT Posted by Kris Ramesh (Rice University), on Saturday, July 11, 2026
Editor's Note:

Kris Ramesh is the Herbert S. Autrey Professor of Accounting, Jones Graduate School of Business at Rice University. This post is based on an SEC comment letter by Donal Byard, Irving Weinstein Professorship in Accountancy & Chair, Stan Ross Department of Accountancy, Baruch College, CUNY; Edward Li, Professor of Accounting, Stan Ross Department of Accountancy, Baruch College, CUNY; Kris Ramesh; and Min Shen, Associate Professor of Accounting, Philip G. Buchanan Fellow, Costello College of Business, George Mason University.

We welcome the opportunity to comment on the Securities and Exchange Commission’s proposed amendments that would allow Exchange Act reporting companies to elect semiannual reporting on a new Form 10-S in lieu of quarterly reports on Form 10-Q (“the proposal”). We write as academics with extensive experience conducting research that examines SEC periodic reports, earnings announcements, information intermediaries, and the dissemination and processing of public company disclosures. We appreciate the proposal’s careful economic analysis of the potential costs and benefits of the proposed rule change. Drawing on our experience as active researchers in this field, we aim to clarify relevant findings from the academic literature and to highlight important operational considerations that may arise in implementing the proposed rule change.

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