Jay Dubow, a partner and co-leader of Troutman Pepper Locke’s Securities Investigations + Enforcement Practice Group, was quoted in the May 6, 2026, Corporate Compliance Insights article, “SEC Formally Proposes Making Quarterly Reporting Optional for Public Companies.”

  • Jay Dubow, a partner and co-lead of Troutman Pepper Locke’s securities investigations and enforcement practice group and a former branch chief of the SEC’s Enforcement Division, flagged one potential structural consequence of the voluntary approach: a fragmented disclosure landscape.
  • “The optional nature of the proposal could result in some companies switching to semi-annual reporting while others maintain the quarterly format,” he said. “Unusual to have two different disclosure calendars.”
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  • Larger companies could elect semiannual reporting as well, both Harder and Dubow noted. For smaller filers specifically, Dubow flagged a risk that cuts against the cost-savings argument: companies with less rigorous control environments could find that problems grow larger before they surface than would be the case under a quarterly filing schedule.
  • Companies should also be sounding out peers, large shareholders and analysts before committing to any change, Dubow said. Trading windows will need attention as well: Companies that tie permissible insider trading periods to quarterly earnings announcements will need to rethink how those windows are structured under a semiannual calendar.
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