The SEC request for comment on the "nature, content and timing" of quarterly reports submitted by reporting companies was published in the Federal Register. Comments must be received by March 21, 2019.

As previously covered, the SEC is specifically seeking feedback on:

  • the relationship between the quarterly reports that Exchange Act reporting companies are required to provide on Form 10-Q and the earnings releases they voluntarily provide on Form 8-K;
  • whether SEC rules should "provide reporting companies, or certain classes of reporting companies, with flexibility as to the frequency of their periodic reporting"; and
  • how the reporting system including earnings releases and earnings guidance, "alone or in combination with other factors, may foster an overly short-term focus by managers and other market participants."

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