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Abstract: 

After more than 50 years of mandatory quarterly reporting, the SEC is considering reforms that would permit U.S. public companies to move away from quarterly disclosure. While the debate is often framed as a choice between quarterly and semiannual reporting — or between regulatory burden and investor protection — that framing is incomplete. Effective reform requires careful attention to market practices, capital formation dynamics, and the interconnected structure of the federal securities laws. This article evaluates the implications of reduced reporting frequency and outlines a calibrated reform framework built on six structural pillars, while also addressing liability considerations and the role of pilot programs in guiding rulemaking.

Keywords: Forms 10-K, 10-Q; “Fit for Purpose” Reporting; Tiered Disclosure; Current Reporting Requirements; Registration Statements; Standardized Voluntary Disclosure

Affiliations:  1: Goodwin Procter LLP.