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. Sun, 12 Jul 2026 11:30:45 +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/2026/07/12/comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-4/?utm_source=rss&utm_medium=rss&utm_campaign=comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-4 https://corpgov.law.harvard.edu/2026/07/12/comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-4/#respond Sun, 12 Jul 2026 11:30:45 +0000 https://corpgov.law.harvard.edu/?p=182544?d=20260710170504EDT Posted by Sarah Keohane Williamson, FCLTGlobal, on Sunday, July 12, 2026
Editor's Note:

Sarah Keohane Williamson is the CEO of FCLTGlobal. This post is based on her SEC comment letter.

FCLTGlobal respectfully submits this comment in response to the Securities and Exchange Commission’s proposed rule amendments that would permit public companies to elect semiannual reporting in lieu of quarterly reporting (Release No. 33-11414, File No. S7-2026-15).

FCLTGlobal is a nonprofit research organization whose mission is to mobilize companies and investors to focus capital on the long term. Our membership spans asset owners, asset managers, and corporations domiciled in countries around the world that support a longer-term framing in corporate and investment decision-making

This proposal is a meaningful step toward reducing structural short-termism in U.S. public capital markets — a problem FCLTGlobal has studied and documented over more than a decade. We offer the comments below to both affirm the proposal’s direction and to identify several considerations.

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