CBIZ CPAs recently submitted a formal comment letter to the Securities and Exchange Commission (SEC) in response to its proposal on optional semiannual reporting. The proposal explores whether public companies should be permitted to file reports on interim financial statements semiannually rather than quarterly, with the goal of simplifying reporting requirements and promoting broader access to public markets.
In its response, CBIZ CPAs draws on its experience as an auditor of public companies to provide perspective on the potential implications of introducing greater flexibility into the reporting framework. While not taking a position on whether companies should adopt semiannual reporting in place of quarterly filings, CBIZ CPAs highlights considerations that could impact audit quality, investor transparency and overall financial reporting discipline.
A central theme in the letter is the value of maintaining a consistent reporting cadence. CBIZ CPAs notes that routine reporting helps instill discipline in financial reporting processes, encourages continuous attention to accounting judgments and internal controls, and enables auditors to perform ongoing risk assessments that enhance audit quality over the course of the year.
The firm also raises practical considerations around how semiannual reporting could affect interim disclosures, audit procedures and investor understanding. For example, CBIZ CPAs recommends that the SEC consider clarifying how companies present quarterly information if they opt into semiannual reporting, including whether new mechanisms should distinguish between GAAP-compliant interim financial statements and other forms of financial information.
Additionally, the letter addresses how changes to reporting frequency could influence internal controls, audit timing and the comparability of financial information, particularly in situations involving accounting changes, acquisitions or other significant events. CBIZ CPAs emphasizes the importance of clear guidance to help companies, auditors and investors navigate these scenarios effectively.
Overall, CBIZ CPAs expresses an understanding of the SEC’s objective of reducing unnecessary complexity while encouraging thoughtful consideration of the operational, audit and investor impacts associated with any changes to the reporting framework.
If you have any questions regarding our letter, contact us.
Frequently Asked Questions
The SEC is considering allowing public companies to optionally file reports semiannually instead of quarterly to reduce complexity and expand access to public markets.
CBIZ CPAs does not take a position on adoption but provides audit-focused insights based on its experience with public company reporting.
Consistent reporting supports disciplined financial processes, continuous evaluation of accounting judgments and controls, and stronger audit quality through ongoing risk assessment.
The firm points to the need for clear guidance on interim disclosures, audit procedures, internal controls and how companies present GAAP-compliant versus non-GAAP interim information.
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