Biography | Melissa Niles

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Melissa Niles

Associate

Boston, MA: 617 338 2458

Melissa Niles

Associate

mniles@sullivanlaw.com

Boston, MA: 617 338 2458

Biography

Melissa is a corporate associate in the Boston office. Melissa earned her J.D. at Northeastern University School of Law, where she served as the Combined Northern New England Sub-Regional Director of the Northeast Black Law Students Association, Co-Chair of the Black Law Students Association, as well as a member of the Intellectual Property Society, and the First Generation Law Students Association. Melissa received her B.A. in Government and Law from Lafayette College, where she was a Founding Member of the BIPOC Abolition Coalition and President of the Women of Color Association.

While at Northeastern, Melissa served as a Judicial Intern to the Honorable Angel Kelley, where she collaborated closely with law clerks to aid in preparation for hearings and researched legal issues to assist law clerks with preparation of recommendations.

Education

Northeastern University School of Law (J.D.)
Lafayette College (B.A.)

Bar & Court Admissions

Massachusetts

Viewpoints

SEC Proposes Optional Semiannual Interim Reporting Framework

If Adopted, Companies Could Elect to File One Semiannual Report After Their Second Quarter Instead of Three Quarterly Reports After Each of the First Three Quarters On May 5, 2026, the Securities and Exchange Commission (SEC) proposed amendments to the rules and forms governing periodic filing requirements for public companies that would allow companies to file one semiannual Form 10-S report and one annual Form 10-K report rather than filing three quarterly Form 10-Q reports and one annual Form 10-K report. Based on their filing status (non-accelerated filer v. accelerated/large accelerated filer), companies would have 40 or 45 days to file newly proposed Form 10-S following the end of the first semiannual period (i.e., six months) of each fiscal year. While the frequency of reporting under the Form 10-S would be reduced, the required contents of the Form 10-S would essentially be the same as the existing requirements for the contents of Form 10-Q. The proposal would also update Regulation S-X to include the new semiannual reporting option, adapt the “staleness” rules for registration statements to accommodate semiannual reporting and streamline the related financial statement requirements. The new Form 10-S framework would be optional for companies, and those that do not elect semiannual reporting could continue filing quarterly Form 10-Q reports.[1] Optional Shift from Quarterly to Semiannual Reporting Under current rules, depending on their filer status, reporting companies have 40 or 45 days following the end of each fiscal quarter to file a Form 10-Q. Form 10-Q requires quarterly financial statements prepared under U.S. generally accepted accounting principles reviewed by an independent public accountant and tagged in Inline XBRL data language, as well as various narrative disclosures including, management’s discussion and analysis of financial condition and results of operations, disclosures regarding the effectiveness of disclosure controls and procedures and any material changes in internal control over financial reporting, material changes in risk factors, and certifications by the principal executive and financial officers as exhibits. The SEC’s proposal introduces a new interim reporting framework under which companies may transition from quarterly to semiannual reports, with the same content as is currently required for Form 10-Qs, but covering the semiannual period rather than a quarterly period. Companies that elect semiannual reporting would file a single semiannual report on newly proposed Form 10-S, in place of three quarterly reports on Form 10-Q, while in each case continuing to file an annual report on Form 10-K. Under the proposal, companies would make the election to report on a semiannual basis by indicating their election through a check box on the cover page of the company’s annual Form 10-K or, as applicable, certain Securities Exchange Act or Securities Act registration statements including Forms 10, S-1, S-3, S-4, and S-11. Companies that do not make this election would remain subject to the existing quarterly reporting framework. The proposal’s election-based approach is intended to provide companies with greater flexibility in determining the frequency of their interim reporting. Once an election is made for a particular year, a company would not be able to change its filing frequency for the ensuing year. The proposed amendments introduce two new defined terms to distinguish companies based on their interim reporting obligations. Under the proposal, a “quarterly filer” would be a company that is required to file quarterly reports on Form 10-Q pursuant to Exchange Act Rule 13a-13(a). A “semiannual filer” would be a company that is required to file semiannual reports on the newly proposed Form 10-S pursuant to Exchange Act Rule 13a-13(b). These definitions provide a clear framework for incorporating references to semiannual filers throughout the SEC’s rules and forms that currently rely on quarterly reporting concepts. Filing Deadlines While the principal difference between the two forms is the reporting period covered, both quarterly filers and semiannual filers would be subject to the same filing deadlines. Specifically, a semiannual filer would be required to file Form 10-S 40 or 45 days after the end of the first semiannual period depending on the issuer’s filer status. Amendments to Regulation S-X The proposed amendments would revise Regulation S‑X to align financial statement requirements for interim reports, proxy statements, and registration statements with the proposed optional semiannual reporting framework and to update the existing financial statement staleness rules. These changes are intended to modernize the financial statement updating framework and reduce technical complexity in Securities Act filings, making it easier for companies to determine when they need to update financial statements included or incorporated by reference into registration statements and proxy statements. Under the proposal, Rule 3‑01 and Rule 8‑08 would be restructured to establish a single, consolidated framework governing the age and updating of annual and interim financial statements. As part of this restructuring, proposed Rule 3‑01(a) would clarify that financial statements must be current as of the filing date, treating the effective date of a registration statement or the proposed mailing date of a proxy statement as the filing date for purposes of determining whether financial statements must be updated. Consistent with the semiannual reporting model, the proposal would replace the current quarterly‑based staleness regime with an approach tied to a company’s most recent required interim reporting period. Interim financial statement requirements would be determined by filer status, with semiannual filers permitted to report on a six‑month basis without preparing quarterly financial statements solely to satisfy Securities Act or proxy statement updating requirements. Comment Period The SEC has requested public comments on all aspects of the proposal. Comments must be submitted within 60 days after publication of the proposing release in the Federal Register. Following the close of the comment period, the SEC will review feedback from market participants and determine whether to adopt the proposed amendments, which may be modified in response to comments received. More Information If you would like further information about how these changes may affect your reporting obligations, please contact the lawyers at Sullivan & Worcester LLP with whom you regularly consult or one of the lawyers listed above. [1]The amendments would have no impact on foreign private issuers that file annual reports on Form 20-F or their obligations with respect to the staleness rules for registration statements utilized by such issuers such as Forms F-1 and F-3.

Massachusetts SJC Clarifies Law on Appellate Interest After Judgment Satisfied in Full Pending Appeal

On March 11, 2025, the Massachusetts Supreme Judicial Court (the “SJC”) issued a decision concluding that once a losing party satisfies a judgment in full, postjudgment interest stops running even if the losing party then appeals. The decision stands to have a potentially significant impact for Massachusetts litigants’ strategic appellate decisions going forward. In the case, H1Lincoln, Inc. v. S. Washington St., LLC[1], the defendants, having lost at trial, paid the entire amount of the more than $20 million judgment against them, in full, and proceeded to appeal. They argued that their payment meant that the judgment should therefore have been considered fully satisfied regardless of their appellate rights, and so postjudgment interest should stop running. The Superior Court motion judge disagreed and ruled to allow postjudgment interest to continue to accrue pending appeal. In taking up the case, the SJC dealt with the issue in the context of a 2021 SJC decision (“Governo”)[2] which had held that conditional payments do not constitute full satisfaction of a judgment. In Governo, the defendants sought to deposit funds with the court (effectively in escrow) pending appeal. The defendant offered to release the deposited funds immediately if the plaintiff did not appeal, but to keep the deposit if an appeal proceeded. The SJC noted that such a conditional payment of a judgment cannot stop the accrual of postjudgment interest, as it prevents the plaintiff from having use of the funds unless it agreed to forfeit its right to appeal. In H1 Lincoln, the evolved question therefore became: “whether a payment in full by a judgment debtor who intends to appeal is only a ‘conditional payment.’” The SJC concluded that “full payment of a judgment fully satisfies the [postjudgment interest] statutory requirement and terminates the accrual of interest, even if the judgment debtor pursues an appeal.” The SJC supported its rationale by reiterating the established premise that postjudgment interest is not punitive, but rather compensatory. It found support in the postjudgment interest statute’s history, noting that “the purpose of postjudgment interest is to compensate the prevailing party for the loss of the use of money” when a judgment is not immediately paid. The statutory purpose thereby puts “the judgment creditor and the judgment debtor in the same position they would have enjoyed had the debtor paid the judgment promptly.” Where the plaintiff in such circumstances is made whole by virtue of a fully satisfied judgment, the Court reasoned, there can be no further compensatory need to run the interest clock any further. The Court further noted that it would be contrary to the Legislature’s intent in a statute designed to encourage prompt payment to read the law in a way that would discourage judgment debtors who exercise their right to appeal from paying the entire judgment up front. Importance of the Decision As Massachusetts litigators are well aware (but others may not be), statutory postjudgment interest in Massachusetts accrues at an incredible rate of 12% per annum. Such an unusually high interest rate can be a debilitating stumbling block to a party considering an appeal; after all, appeals can take upwards of a year (or more), during which time interest is steadily accruing. The skyrocketing cost of a potential loss plus 12% interest certainly complicates the decision on whether to pursue a meritorious appeal. This new decision gives would-be appellants more strategic breathing room. If they so choose, such parties can now pay the judgment in full and then prosecute an appeal, knowing they will not be on the hook for endlessly accruing 12% interest. Of course, this strategy is only of interest to parties capable of paying the underlying judgment in the first place. Nonetheless, it adds a layer of flexibility for litigants who might have otherwise written off their appeal rights as prohibitively expensive. The Natural Next Question – What if the Appeal Succeeds? The plaintiff in H1 Lincoln argued, unsuccessfully, that it should continue to accrue interest as it did not truly have full use and enjoyment of the judgment as-paid, “because the payment remains subject to risk and uncertainties of appeal.” The SJC was more persuaded by the defendants’ response: that defendants assumed a significant financial risk in paying the judgment because the plaintiff might dissipate all of the funds before the defendants had an opportunity to prevail on appeal. In contemplating this point, the decision proceeded to mention, but not answer, the question of what does happen if the appeal is successful. Clearly, a successful appeal is pointless if the previously paid judgment proves unrecoverable. Fortunately, courts have the inherent authority to order restitution, as recognized by the Restatement of Restitution § 74, and at least one unreported Massachusetts decision.[3] What remains murky is how such restitution would be handled and executed in practice. The refund process during a successful appeal therefore remains an important consideration for parties involved in both paying judgments and appealing them. * * * Ultimately, while the H1 Lincoln decision clarifies postjudgment interest considerations surrounding appellate rights, the issue of restitution in the event of a successful appeal remains a significant consideration for successful and unsuccessful litigants’ strategies in similar cases. [1] SJC-13651, 2025 WL 757719 (Mass. Mar. 11, 2025). [2] Governo Law Firm LLC v. Bergeron, 487 Mass. 188 (2021). [3] Dombrowski v. Cronin, 2001 Mass. App. Div. 194, 2001 WL 1021054, at *2 (Mass. App. Div. Aug. 28, 2001).

News

Sullivan & Worcester Welcomes 2024 First-Year Associates

Sullivan has welcomed its 2024 First-Year Associates to the firm. The associates join Sullivan after having completed the firm's summer associate program, as well as various clerkships and internships. Harriet Bryant, Nathan Kosik-Desmond and Melissa Niles will be located in our Boston office, while Jiahang Zhou will be located in New York. Harriet Bryant Harriet received her J.D. from Suffolk University Law School, where she was Chief Comment Editor for Transnational Law Review and Co-Coordinator of the Alumni Relations Committee for the Women's Law Association. She received her Master of Arts, with honors, in Modern History and Art History from the University of St. Andrews in the UK. While in law school, Harriet was a Judicial Intern to the Honorable Mary Rudolph Black, Associate Justice. Nathan Kosik-Desmond Nathan received his J.D. from the University of Southern California Gould School of Law. He graduated from Concordia University with a B.A., with distinction, after receiving his Diploma of College Studies in Commerce from Marianopolis College. While at USC, Nathan was a member of the Black Law Students Association, First Generation Professionals and the Business Law Society. Melissa Niles Melissa earned her J.D. at Northeastern University School of Law, where she served as the Combined Northern New England Sub-Regional Director of the Northeast Black Law Students Association, Co-Chair of the Black Law Students Association, as well as a member of the Intellectual Property Society, and the First Generation Law Students Association. Melissa received her B.A. in Government and Law from Lafayette College, where she was a Founding Member of the BIPOC Abolition Coalition and President of the Women of Color Association. While at Northeastern, Melissa served as a Judicial Intern to the Honorable Angel Kelley, where she collaborated closely with law clerks to aid in preparation for hearings and researched legal issues to assist law clerks with preparation of recommendations. Jiahang Zhou Jiahang (Jay) earned his J.D. from William & Mary Law School, where he was Senior Articles Editor for William & Mary Bill of Rights Journal. After graduating with a B.A. in Economics from the University of California, Santa Barbara, Jay earned his M.S., with honors, from State University of New York, Maritime College. Prior to law school, Jay worked as an energy trader in the maritime industry for a Danish trading house. While in law school, Jay served as a Judicial Extern to the Honorable Junius P. Fulton III, Virginia Court of Appeals.

May 11, 2026

–Client Alert

SEC Proposes Optional Semiannual Interim Reporting Framework

March 18, 2025

–Client Alert

Massachusetts SJC Clarifies Law on Appellate Interest After Judgment Satisfied in Full Pending Appeal

Sullivan Client Alert

November 21, 2024

–Client Alert

Governor Signs Economic Development and Clean Energy Bills: Key Insights

Sullivan Client Alert

October 10, 2024

–Firm Announcement

Sullivan & Worcester Welcomes 2024 First-Year Associates

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