The Securities and Exchange Commission's proposal to let U.S. public companies file financial reports twice a year instead of quarterly is drawing scrutiny from wealth managers who rely on those disclosures for investment decisions. Under the plan, announced May 5, 2026, issuers could elect to file a single semi-annual report on a new Form 10-S, replacing the three quarterly Form 10-Q filings that have been mandatory since 1970. Public comments are due by July 6, 2026.
SEC Chairman Paul Atkins framed the initiative as part of his "Make IPOs Great Again" agenda, stating that "public companies have an obligation under the federal securities laws to provide information that is material to investors." He described materiality as the disclosure regime's "north star." However, for registered investment advisors, the proposal shifts additional responsibilities for analysis and documentation onto their shoulders.
Sarah Razaq Sallis, a partner in the financial services and capital markets group at Husch Blackwell in Washington, D.C., and a former Financial Industry Regulatory Authority regulation attorney, emphasized a crucial distinction: what the proposal changes versus what it does not. "The quarterly-filing requirement has always been the mechanism that forces the materiality application, and forces it onto a schedule," Sallis said. "Making that mechanism optional does not necessarily remove the obligation. It just kind of changes the cadence."
In securities enforcement, Sallis noted that "the timeline is everything." Every inquiry into insider trading, accounting fraud, or material omission brings the question: "what did they know, and when did they know it?" Quarterly filings have long anchored that timeline. Widening the interval, she warned, creates "opportunity – and not for investors." The companies most likely to elect semi-annual reporting are small-to-mid-cap issuers, which are "precisely the type of companies that are harder to value in the first place." A six-month reporting gap forces advisors to choose between holding a position based on stale data or building alternative data sourcing, both of which carry risk and cost.
Advisors must document their interim review processes to satisfy SEC examiners. Sallis cited a common FINRA adage: "If it's not documented, it's not done." A defensible process includes documenting reviews of earnings calls, press releases, social media posts, Form 8-K disclosures for material events, and independent market intelligence on thinly traded issuers. Advisors should also maintain a written record of their analytical reasoning for continuing to hold or recommend a security. "A review that happened but that wasn't written down, that doesn't exist for the SEC's purposes," she said.
The phrase examiners will return to is "reasonable basis," Sallis said. Advisors must be able to point to records showing "what was the basis, and was it reevaluated during the gap, but not just … reconstructed after the fact." That discipline is becoming part of how firms compete, alongside efforts like weaving tax planning into wealth management and serving a generation of investors shaped by 2008. Competition has always tilted toward larger firms with greater resources or informal information networks, Sallis acknowledged. A thinner filing schedule sharpens that divide. "Competitively, yes, I do think [it] can disadvantage … the smaller firms that don't necessarily have [competitive] access," she said. However, the SEC examines advisors against their own business, so "a reasonable basis for a very large RIA may look different for a smaller RIA," leveling expectations somewhat.
Sallis outlined a wish list for the SEC. First, a clear definition of what constitutes a "reasonable basis" for holding a semi-annual filer through its interim period. Second, mandatory triggers for interim disclosure to ensure material developments surface between filings, as Form 8-K's current scope may leave gaps. Third, clarification on how Regulation Fair Disclosure (Reg FD) applies when earnings calls continue quarterly but formal filings are only semi-annual. "The SEC needs to say how that applies in a world where you've got earnings calls that continue quarterly, but your formal filings are only happening semi-annually," Sallis said, noting the gap creates a live Reg FD question.
For advisors, the proposal adds to an industry already wrestling with deepening appetite for investment risk. As firms compete, the ability to maintain rigorous documentation and analysis may become a differentiator. The SEC's comment period remains open until July 6, 2026, and industry participants are weighing in. Reddit's WallStreetBets has already submitted a formal comment opposing the proposal, while advisors continue to assess the impact on research and transparency.
