As recent proposals from the Long-Term Stock Exchange and renewed prompts by the White House once again bring this issue to the forefront, FCLTGlobal believes this is an opportune moment for the SEC to reexamine the current standard to ensure it serves the interests of long-term value creation.
The quarterly reporting requirement was designed for a market environment markedly different from today’s. The investment landscape has evolved substantially—becoming more professionalized, specialized, and data-rich. Furthermore, the private equity market has evolved considerably and is not subject to disclosure requirements.
Simultaneously, research continues to shed light on how reporting frequency influences corporate decision-making and resource allocation.
- A 2023 study of Japanese firms found that when companies were required to report quarterly, managers systematically cut R&D spending and adjusted operations to meet near-term targets
- “The Real Effects of Mandatory Quarterly Reporting” reached parallel conclusions in Europe: firms forced into quarterly disclosure engaged in short-term manipulation, saw brief performance increases, then experienced subsequent declines
Alternative approaches have been demonstrated in the UK and European Union, where corporations are permitted to report less frequently, complemented by requirements for timely disclosure of significant events. Such a system can both reduce the need to orient all communications on three-month intervals and maintain transparency, which is paramount in any eventual rule change.
It is critical to distinguish between mandatory quarterly reporting (retrospective disclosure of performance) and voluntary quarterly earnings-per-share (EPS) guidance (forward-looking projections). FCLTGlobal research has consistently indicated that earnings guidance, specifically, does not improve company valuation, reduce volatility, or enhance management accountability, and it has declined in prevalence as a result: Close to 50 percent of large-cap companies in 2004 put out quarterly forecasts, compared to 21 percent in 2024. Though distinct from reporting, EPS guidance has become emblematic of the 3-month cycles that some public companies feel stuck in, and which many are evidently trying to escape.
As such, FCLTGlobal supports an SEC review of current quarterly reporting requirements, examining whether the existing framework serves its dual mandate of investor protection and capital formation in today’s market environment. This review should consider:
- Reporting flexibility that allows companies to align disclosure frequency with their business models and strategic timelines
- Enhanced material event disclosure requirements to maintain transparency between formal reporting periods
- Alternative reporting formats, such as year-to-date or trailing twelve-month disclosures, that provide context while reducing short-term focus
- The continued distinction between mandatory reporting and voluntary guidance practices
We do not advocate for the wholesale elimination of corporate reporting. Rather, we believe a modernized framework can maintain robust transparency and accountability while also prioritizing long-term value creation over short-term returns.