Thousands wrote to the SEC about quarterly reporting. A detailed letter came from Exxon’s CFO

Good morning. Earnings season is about to kick off, just as the U.S. Securities and Exchange Commission weighs whether companies should keep reporting quarterly or have the option to shift to semiannual disclosures.

In May, the SEC announced a proposed rule and form amendments that would allow semiannual reports to satisfy interim reporting obligations under federal securities laws. The comment period closed Monday. The SEC declined to comment on the amount of letters received.

I had a conversation with Ohio State University accounting professor Tzachi Zach who used AI to create a database which indexes public comment letters the SEC receives on the proposal including the sentiment of comments. As of Tuesday evening, the database reflected 8,080 comment letters. Regarding sentiment, 7,994 opposed, 34 supported, and 52 were conditional.Of that dataset, there were 33 public comment letters of which Zach classified them as submitted by an individual active corporate role such as CFO, audit chair, financial reporting manager, COO, CTO. Of that group 25 opposed, two supported the proposal and six of the comments were classified as conditional. But Zach mentioned he expects that many more letters that will continue to flow into his database. “The deadline was yesterday to submit, but there is a lag between the time the person submits until the time that the SEC puts it in the docket,” he told me.What public-company CFOs told the SEC

In the dataset there were comments from four current public CFOs. One of the most extensive submissions came from energy giant ExxonMobil, one of the world’s largest public companies. Neil Hansen, senior vice president and CFO, filed an 11-page comment letter dated June 24 supporting the SEC’s proposal to allow companies to choose semiannual reporting instead of quarterly SEC filings.ExxonMobil’s position is not that quarterly disclosure should end, but that companies should have flexibility over whether to provide those disclosures through quarterly Form 10-Q filings. Hansen argued that the information ecosystem has changed while SEC reporting rules have not.........

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