54 Pages Posted: 6 Apr 2017 Last revised: 14 Jun 2017
Date Written: June 9, 2017
SEC oversight of publicly listed firms ranges from comment letter (CL) reviews of firms’ reporting compliance to pursuing enforcement actions against violators. Prior literature finds that firm political connections (PC) negatively predict enforcement actions, inferring SEC capture. We present new evidence that firm PC positively predict CL reviews and substantive characteristics of such reviews, including the number of issues evaluated and the seniority of SEC staff involved. These results, robust to identification concerns, are inconsistent with SEC capture and indicate a more nuanced relation between firm PC and SEC oversight than previously suggested.
Keywords: comment letters, political connections, regulatory capture, SEC enforcement
JEL Classification: D72, G18, M41, M48
Suggested Citation: Suggested Citation
Heese, Jonas and Khan, Mozaffar and Ramanna, Karthik, Is the SEC Captured? Evidence from Comment-Letter Reviews (June 9, 2017). Harvard Business School Accounting & Management Unit Working Paper No. 17-087; Journal of Accounting & Economics (JAE), Forthcoming. Available at SSRN: https://ssrn.com/abstract=2947752