If adopted, the proposal could make it harder for affected banks to access funding by limiting their ability to use Form S-3. However, they argued that the proposal's changes to Form S-3 eligibility would make it more difficult for certain bank holding companies to access the public capital markets. Specifically, the groups objected to the proposal's elimination of Form S-3 eligibility for certain "ineligible issuers." That flexibility becomes especially important during periods of market stress, when access to the capital markets may be available only for a limited time, they said. Another proposal would allow public companies, including banks, to choose between quarterly financial reporting and a semiannual reporting schedule .