C. Aubrey Smith Center  ·  UT McCombs School of Business

Comment letter analyses

Public-facing analyses of the comment files for recent PCAOB and SEC rulemakings — what stakeholders are saying, where they agree and disagree, which arguments are gaining traction, and how the picture differs by constituency.

Active dockets

Open SEC · File No. S7-2026-15 Comment period closes July 6, 2026

Semiannual Reporting and Form 10-S

The SEC's proposed amendments to permit optional semiannual reporting in lieu of quarterly Form 10-Q filings. As of the May 22 snapshot: 310 comment letters with 30 substantive-tier per-letter notes. Overall position split is heavy opposition (89% Object), but the substantive tier is much more divided (40% Object) and breaks sharply by constituency — auditors & accounting firms unanimously support or support-with-caveats, while lawyers cluster on Object.

310 letters 30 substantive notes 10 canonical themes 5 template letters detected

View the SEC Semiannual Reporting analysis →

Recently closed PCAOB · Release No. 2026-001 Comment period closed May 15, 2026

PCAOB Strategic Priorities (2026–2030)

The PCAOB's Request for Public Comment on its 2026–2030 strategic priorities — what the Board should focus on across inspections, standard-setting, enforcement, and registration. 67 substantive comment letters from Big 4 firms, mid-tier firms, institutional investors (including the PCAOB's own Investor Advisory Group, ICI, ICGN, CII, CalSTRS), audit-committee organizations, federal regulators (FHFA), state regulators (NASBA, NASAA), and Senator Elizabeth Warren.

67 letters 67 per-letter notes 10 canonical themes 7 stakeholder groups

View the PCAOB Strategic Priorities analysis →

About these analyses

Each analysis reads every comment letter end-to-end and surfaces — by stakeholder group, by canonical theme, and (for the SEC docket) by position — what's distinctive about each commenter's contribution and where the field converges or diverges. The PCAOB analyses are structured around the questions the Board asked; the SEC analysis is structured around the agree/disagree axis since the proposal is yes/no on optionality.

The site is generated from per-letter notes and per-docket canonical curation by docket-specific build scripts. The goal is to make the comment file easier to inspect without losing the link back to individual letters and stakeholder positions.

Editorial by the C. Aubrey Smith Center at the UT McCombs School of Business.