More than 200,000 comment letters – among the strongest in the SEC’s history. According to the Wall Street Journal, the SEC appears likely to move forward with its semiannual reporting proposal despite the significant number of opposing letters it has received. Though the Commission itself has only said it received a large number of comments and was still posting them.

Few rulemakings in recent memory have arrived at their board-level decision point carrying this much friction, and this much consequence. Metrix Advisory submitted its own comment letter on the proposal. This briefing translates the considerations raised there into a practical framework for board and audit committee decision-making.

Many companies may soon face a genuinely consequential reporting decision if the SEC finalizes its semiannual reporting proposal substantially as issued. The question is no longer hypothetical, and it is no longer distant. The SEC’s public comment period on the proposal closed on July 6, 2026, and the Wall Street Journal has reported it drew more than 200,000 letters – among the strongest opposition in the SEC’s history, with the overwhelming majority opposed to the change. Despite that opposition, the Wall Street Journal has reported that the SEC appears likely to move forward with the proposal in some form.

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