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Fiduciaries and semiannual reporting collide at the point where a portfolio holding no longer supplies the same regular 10-Q evidence.

Last updated June 10, 2026

Submitted for NASAA IAR CE approval.  To be submitted for CFP, CIMA, and  CPA professionals.  

What happens when the world’s largest capital market reduces the required frequency of standardized public financial information? 

We may soon find out. 

The SEC has proposed a rule allowing public companies to stop filing 10-Qs and file semiannually financials instead. 

A major finding of the compilation and analysis of the public comments:  the SEC proposal for semiannual reporting is drawing overwhelming opposition.  

The analysis reviewed 511 records, including 507 public comment letters and 4 SEC meeting memoranda. Of the public comments, 479 opposed the shift or urged the SEC to keep quarterly reporting, while only 10 were counted as strictly pro-semiannual and 9 were mixed or conditional.  

Commenters were roughly 98% opposed and 2% in favor of semiannual reporting by publicly held companies. 

Commenters viewed the proposal as a change in the cadence of formal standardized public information and not merely a recordkeeping change. 

Opposition came from retail investors, advisers or financial professionals, and investment club members. 

At this class, investment advisers learn how to:

Explain the 479-to-10 response, the SEC's public comment process, and deadline.

Describe how Form 10-S changes interim reporting cadence.

Explain why adviser duties don't change despite fewer filings and disclosures. 

View commenters as investor proxies in analyzing their responses.

Distinguish SEC forms, earnings releases, and guidance.

Evaluate accounting-profession concerns about audits and interim reviews.

Analyze retail, professional, institutional, and investment-club commenters.

Assess fiduciary monitoring risks and accounting integrity concerns.

Evaluate issuer-flexibility arguments and market-risk concerns.

Apply historical context and communicate practical client responses.

At least 300 comments mentioned one of these investor types, and at least 160 identified as retail, individual, private, personal, retirement, or self-directed investors, 42 involved financial or capital-markets credentials, and 16 referenced investment clubs—Better Investing, NAIC, or similar groups. 

Another key finding of the analysis of the comments is the change the proposed rule's adoption would make to fiduciary risk.  If companies elect semiannual reporting, advisers still must monitor holdings, explain recommendations, and document a prudent process, even if they have less regular form 10-Q evidence. 


CE Status

Organization Status Course ID
CFP Board Approved 
349328
IWI / CIMA Not Approved

NASAA Approved
C82109
NASBA Approved
Approved – Course has been fully approved
Pending Review – Submitted and awaiting review
– Not yet submitted
Not Approved – Course is not approved for CE

Credit Requirements (On-Demand)

To earn credit for this on-demand course, participants must pass a 5-question assessment quiz with a score of at least 70% and complete three ungraded review questions.


Who Should Attend

IARs, CFP® professionals, EAs, CFAs, CPA financial planners, CPA/PFSs, CIMAs, CLUs, ChFCs, and other professionals seeking to adopt practices for advising individuals affected by neurodivergence.


Cost

Free to Advisors4Advisors members ($60/quarter)


CPE / CE Credit

  • Credit Hours: 1/2  

  • Field of Study: Specialized Knowledge 

  • Course Level: Intermediate


Prerequisites

None


Advanced Preparation

None


Delivery Method

Reading 4813 words

Class curriculum

  1. Instructions

  2. Class Content

  3. Review Exercise

  4. Assessment

  5. Feedback

About this class

  • $19.99
  • 0 hours of video content

Instructor

Frank Murtha

Frank Murtha, who holds a Ph.D. in Counseling Psychology, has taught at The City University of New York, Penn State, and New York University. In 2001, Dr. Murtha co-founded MarketPsych Inc., a statistically valid assessment for identifying investor personality traits, and he consults to institutional investors on macro- and micro-behavioral economics. In early 2021, he co-founded Financial Counseling Institute.

Read the first two practice tips.