CII submitted a 23‑page SEC comment letter defending quarterly reporting. We oppose replacing Form 10‑Q with semiannual 10‑S filings, warning that the proposal lacks evidence of cost savings and would weaken key investor protections: https://t.co/BBjnisSP0C

— Council of Institutional Investors (@CouncilInstInv) June 29, 2026

“The Council of Institutional Investors (CII)1 respectfully submits this letter in response to the Securities and Exchange Commission’s (SEC or Commission) request for comments on its proposed “amendments to allow companies to file semiannual reports on Form 10-S in lieu of quarterly reports on Form 10-Q to meet their interim reporting obligations under the Securities Exchange Act of 1934 (‘Exchange Act’)” (Proposed Rule).2 CII opposes the Proposed Rule.

CII is a nonprofit, nonpartisan association of U.S. public, corporate and union employee benefit funds, other employee benefit plans, state and local entities charged with investing public assets, and foundations and endowments with combined assets under management of approximately $5.2 trillion. Our member funds include major long-term shareowners with a duty to protect the retirement savings of millions of workers and their families, including public pension funds with more than 15 million participants – true and real “Main Street” investors through their pension funds. Our associate members include non-U.S. asset owners with about $5.8 trillion in assets, and a range of asset managers with more than $74 trillion in assets under management.

CII has long held the view that the requirement to file on a quarterly basis data-tagged financial statements and related footnotes on Form 10-Q and have those statements subject to an independent auditor review and management certification is a key element of the timely and accurate information flow that underpins the quality and efficiency of the U.S. capital markets. That requirement helps ensure that important information is promptly and transparently provided to the marketplace, allowing investors to assess concrete progress against strategic goals. In addition, CII believes that permitting less frequent reporting would lead to greater share price volatility, and more intense investor focus on short-term share price fluctuations, as investors expend effort guessing how well the company is performing. As such, requiring quarterly financial reports on Form 10-Q is an important reality check for investors on stock valuation.

Conversely, CII does not believe that requiring quarterly reporting on Form 10-Q materially reduces the number of U.S public companies or initial public offerings (IPO). The Proposed Rule does not provide an adequate basis for us to reach a different conclusion.

Read the full letter here 

Source: CII