The Issue

The SEC is proposing a rule change that would permit companies to choose between continuing the quarterly review reporting schedule or switching to a semiannual reporting system. This proposal is intended to streamline financial reporting and reduce regulatory burdens.

Our position

To help inform our response to the Commission's proposal, PICPA surveyed members representing a broad cross-section of the profession, including corporate finance and accounting professionals, public accounting practitioners across audit, tax, and advisory, academics, government professionals, and retired CPAs. Respondents also represented organizations of varying sizes—from privately held companies with less than $100 million in annual revenue to large accelerated filers and private companies with more than $1 billion in revenue. The survey was designed to capture both the diversity of perspectives within the profession and the practical implications of the proposed reporting flexibility.

The results reveal a profession that recognizes the potential operational benefits of reducing reporting frequency but remains concerned that those benefits may come at the expense of investor transparency and confidence.

Comment letters

• Comment letter submitted to the SEC - July 6, 2026