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.