The comments are rolling in on the SEC’s semiannual reporting proposal – so far, many of the submissions are from individual investors who oppose (or strongly oppose!) the proposal. This tracker from Professor Tzachi Zach at The Ohio State University Fisher College of Business categorizes the letters so that you can see at a glance the number that oppose, support, or conditionally support the proposal.

Although the overwhelming majority of commentors currently oppose the proposal, it’s worth noting that not all of the feedback is in quite yet – more on that below – and also that trade organizations often submit letters on behalf of all their members. That means the feedback may not translate neatly to a “one vote per letter” type of tally at the end of the day. But it’s still useful to see how different groups of market participants are reacting, and it will be up to the SEC to decide what’s persuasive. For extra credit, Professor Zach also built a comment tracker for the 2018 proposal on this topic – that proposal ultimately generated mixed feedback.

Many market participants have not yet submitted letters – and as this letter from MFA, AIMA and SIFMA Asset Management notes, it’s a bit challenging to have the deadline fall on the first business day after Independence Day (where we will be celebrating the 250th anniversary of the US Declaration of Independence, no less)! That 5-page letter essentially says, “Please sir, may we have until September 4th?”

As someone who has worked on comment letters for SEC rulemaking and knows how much effort goes into them – not the one-paragraph submissions that seem to be most common on this proposal to-date, but the more thorough variety – an extension sounds great to me! Whether that’s realistic or not in terms of the SEC accomplishing agenda items, might be another story.

– Liz Dunshee