SEC Proposed Rule: Opt in (or Out!) of Semiannual Reporting
On May 5, 2026, the SEC issued its long-anticipated proposed rule that would allow publicly reporting companies to elect semiannual reporting on a new Form 10-S in lieu of quarterly reports on Form 10-Q. According to the SEC, the amendments would “provide greater flexibility to reporting companies to select the interim reporting frequency that best serves the company and its investors.” Comments are due in 60 days.
Find the SEC’s full proposal here.
Authors
Melanie Ruthrauff Levy
Member
Melanie Ruthrauff Levy is a Mintz attorney who counsels venture and private equity funds and public and private companies in corporate governance, public company reporting, and transactional matters. She represents issuers and financing sources in the life sciences, health care, and tech fields.
John T. Rudy
Member / Co-chair, Securities & Capital Markets Practice
John T. Rudy is a Mintz Member who represents clients in capital markets transactions, securities, equity debt financings, and mergers and acquisitions. John's clients include public and private companies and investment banks. Before joining Mintz, he was an associate in a New York law firm.
Anne L. Bruno
Member
Anne L. Bruno is a Member at Mintz who advises clients ranging from start-ups to multinational public companies on issues related to corporate and employment law, including executive compensation, employee benefits, securities law, and corporate governance. She is also a key member of the firm’s multidisciplinary ESG practice, helping corporate boards, companies, and their investors navigate a broad range of environmental, social, and governance considerations.
Daniel A. Bagliebter
Member / Co-chair, Securities & Capital Markets Practice
Daniel A. Bagliebter practices corporate and securities law at Mintz. He focuses his practice on securities offerings and mergers and acquisitions. Dan has represented both issuers and investment banking firms in capital market transactions, including public offerings.