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. Fri, 24 Jul 2026 11:32:21 +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/2026/07/24/comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-6/?utm_source=rss&utm_medium=rss&utm_campaign=comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-6 https://corpgov.law.harvard.edu/2026/07/24/comment-letter-on-the-secs-proposal-to-replace-quarterly-reporting-with-semiannual-reporting-6/#respond Fri, 24 Jul 2026 11:32:21 +0000 https://corpgov.law.harvard.edu/?p=182855?d=20260723160557EDT Posted by Carine Smith Ihenacho and Snorre Gjerde, Norges Bank Investment Management, on Friday, July 24, 2026
Editor's Note:

Carine Smith Ihenacho is the Chief Governance and Compliance Officer and Snorre Gjerde is the Lead Investment Stewardship Manager at Norges Bank Investment Management. This post is based on their SEC comment letter.

We refer to the Securities and Exchange Commission (SEC)’s request for comment on the proposed amendments to allow companies to file semiannual reports on new Form 10-S in lieu of quarterly reports on Form 10-Q to meet their interim reporting obligations under the Securities Exchange Act of 1934. We appreciate the opportunity to contribute our perspective.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank that manages the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As of year-end 2025, we managed over 2 trillion USD in assets, with the United States representing our largest market at 53% of total investments. Within our equity portfolio, 822 billion USD was invested in shares of 1,306 U.S. public companies. We are a minority shareholder in U.S. public companies, with an average equity ownership of 1.18 percent.

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