NIRI Files Comment Letter on SEC Scaled Disclosure Rulemaking Proposal
In July 2026, NIRI filed a comment letter indicating strong support for the SEC’s rulemaking proposal (SEC File No. S7-2026-18) to simplify public company filer status definitions, and to scale disclosure requirements based on a company’s size and maturity.
NIRI Files Comment Letter on SEC’s Semiannual Reporting Rule Proposal
In July 2026, NIRI submitted a comment letter to the SEC regarding its proposed rule that would permit public companies to voluntarily elect to file semiannual reports on a new Form 10-S, in lieu of filing quarterly reports on Form 10-Q (SEC File No. S7-2026-15). Based on several surveys, NIRI members were almost evenly split between support (39%) and opposition (38%) regarding this proposal, but do strongly support the SEC reforming the rules underpinning Forms 10-Q and 10-K, to reduce or eliminate repetitive, immaterial, and boilerplate disclosures.
NIRI Submits Comment Letter on SEC Rulemaking Proposal to Reform Reg S-K
In April 2026, NIRI submitted a comment letter to the SEC on its rule proposal to reform Regulation S-K (SEC File No. CLL-15). NIRI recommended that the SEC: (1) prioritize financial materiality as the fundamental tenant of public company disclosure; (2) provide for disclosure scaled to a company’s size and maturity; (3) employ flexible, principles-based disclosure regulatory approach; (4) reduce disclosure duplication; and (5) streamline risk-factor disclosure.
NIRI Joins Society for Corporate Governance and NYSE on 13F Modernization Rulemaking Proposal
NIRI, the Society for Corporate Governance and the NYSE submitted a joint proposed SEC rulemaking to modernize Section 13(f) disclosure rules that would, among other things, reduce the quarterly disclosure period from 45 calendar days to five business days. NIRI requests that public companies join in supporting this proposal and has made available a downloadable support letter template that can be tailored for each company. Please be sure to submit comment letters via email to “rule-comments@sec.gov” with “File No. 4-825” noted in the subject line.