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I oppose the proposed amendments that would allow public companies to replace quarterly reporting with semi-annual reporting.
I submit this comment in my personal capacity as an individual trader and investor and as a securities and investment banking professional active in the private and public capital markets. I am the founder and owner of Tobin & Company Securities LLC (TOBIN), a boutique broker-dealer that serves clients and investors throughout the financial services industry, including as a managing broker-dealer for Reg D private placement offerings. In our work, TOBIN advocates for and complies with SEC and FINRA rules requiring clearer disclosure, better investor communication and greater transparency in markets that are already less transparent than the public markets.
For that reason, I find proposal S7-2026-15 directionally wrong. Public companies have access to public capital. Regular public reporting is part of that bargain.
As the Chief Compliance Officer of an SEC-registered and FINRA-member broker-dealer, I support reducing unnecessary compliance burdens. There are many SEC compliance obligations that are costly, duplicative or poorly designed. Those should be fixed. Quarterly financial reporting is not one of them.
All financial markets rely on timely information. Retail investors, including me, rely on quarterly reports because we do not have the same access to management, proprietary research, alternative data, industry consultants or analytic tools available to institutional investors. If required reporting becomes less frequent, the information gap between ordinary investors and larger market participants will widen.
A six-month reporting cycle is too long in modern markets. In a world where share price is recorded to the cent, rather than an eighth, and trading, market commentary and pricing information are available nearly around the clock, material changes in liquidity, margins, debt, cash flow, inventory, credit
Member FINRA/SIPC conditions and business momentum can emerge quickly. Investors should not have to wait half a year for financial statements from a public company.
A change to semi-annual reporting will not meaningfully increase the number of companies that choose to go public. Companies do not avoid the public markets simply because they must prepare quarterly reports. The obligations of being public include scrutiny, accountability and regular communication with owners. The costs of being public are real, but quarterly reporting is not the burden that keeps sound companies from accessing public capital. A company that seeks public capital should be prepared to report to the public on a quarterly basis.
If proponents’ concern is short-termism, less disclosure is not the remedy. Short-termism is addressed through board discipline, management communication, long-term capital allocation and the fortitude to follow a strategic plan even when earnings fluctuate and share prices are volatile. Public companies should explain their long-term plans clearly and manage to those plans. Investors can be educated by consistent communication. They should not be educated by silence.
The Commission should focus instead on making reporting easier for issuers to complete and less daunting for investors to use. The SEC has already recognized the need to modernize legacy systems such as EDGAR. That is the right direction to take. Even TOBIN, as a small broker-dealer, must access and use EDGAR, and our experience has been unnecessarily difficult. In a prior comment letter, we described practical problems with EDGAR Next, including unclear instructions, opaque error messages, file-format problems and design issues that impeded compliance rather than improved transparency.
The Commission should reduce needless reporting friction, not the amount of reporting available to investors.
Quarterly reporting supports investor protection, market discipline and sound corporate governance. The public markets need more transparency, not less. I respectfully urge the Commission to not adopt the proposed semi-annual reporting framework.
Thank you for the opportunity to comment on this proposal.
Respectfully submitted,
Justine Tobin
Executive Representative and Founder