September 16, 2025
Is Form 10-Q Going the Way of the Dinosaur? The President Weighs In
I do not believe that public company reporting matters often find their way into President Trump’s posts on the Truth Social platform, but yesterday the President posted a message indicating that “Companies and Corporations” should no longer “Report” on a quarterly basis, but rather report on a six-month basis. As this Reuters article notes, President Trump called for an end to quarterly reporting of financial results by U.S. public companies (subject to SEC approval), noting “[t]his will save money, and allow managers to focus on properly running their companies.” The post goes on to note: “Did you ever hear the statement that, ‘China has a 50 to 100 year view on management of a company, whereas we run our companies on a quarterly basis??? Not good!!!”
If this post somehow feels to you like “déjà vu all over again,” your hunch is correct, because back in August 2018, President Trump (during his first term) announced via Twitter that he had asked the SEC to study the possibility of moving from quarterly to semi-annual reporting for public companies. As we noted in this blog, in November 2018 the SEC included an agenda item in the Sunshine Act Notice for a Commission open meeting that contemplated a request for comment on the nature and content of quarterly reports and earnings releases. The SEC ended up being closed on the day of the open meeting due to a national day of mourning for George H.W. Bush, but the Commission later issued a 31-page request for comment in December 2018. The request for comment was broader than just addressing a change in frequency of periodic reports, raising questions about the relationship between Form 10-Q and earnings releases in addition to questions about changing the frequency of periodic reports. In July 2019, the SEC held a roundtable on short-term/long-term management of public companies, the periodic reporting system and regulatory requirements. The SEC’s efforts did not result in any rule proposal during the first Trump administration, but the topic of the frequency of periodic reporting remained on the SEC’s Reg Flex Agenda even after the end of the first Trump Administration until, as this Thomson Reuters article notes, the rulemaking plans were quietly dropped in the June 2021 version of the SEC’s Reg Flex Agenda.
The SEC’s Spring 2025 Reg Flex Agenda that John blogged about earlier this month does not include a rulemaking line item specifically addressing changes to the frequency of periodic reports, but it does list a proposed rulemaking titled “Rationalization of Disclosure Practices,” which is described as follows: “[t]he Division is considering recommending that the Commission propose rule amendments to rationalize disclosure practices to facilitate material disclosure by companies and shareholders’ access to that information.” It certainly seems that potential changes to the frequency of periodic reporting would fit within that rulemaking framework. The Staff and the Commission already have a strong base of comments and other information to work with as they prepare a proposal, given the 2018 request for comment and the 2019 roundtable. Nonetheless, any changes may ultimately take a while to implement, because the agency will have to vote on a proposal, solicit comments on that proposal, and ultimately consider final rule amendments, all against a backdrop of opposition that will inevitably come from the investor community. With all that said, I would advise to start collecting those Form 10-Qs now, because this time around they may become a rare historical relic!
– Dave Lynn
Blog Preferences: Subscribe, unsubscribe, or change the frequency of email notifications for this blog.
UPDATE EMAIL PREFERENCESTry Out The Full Member Experience: Not a member of TheCorporateCounsel.net? Start a free trial to explore the benefits of membership.
START MY FREE TRIAL