The Effect of SEC Reviewers on Comment Letters and Financial Reporting Quality

Abstract

We examine whether the idiosyncrasy of individual employees of U.S. financial regulators contributes to inconsistent regulatory outcomes. Using a sample of SEC comment letters, we show that SEC reviewers’ idiosyncratic style plays an economically and statistically significant role in explaining the cross-sectional variation in filing review outcomes, even after holding firm and disclosure attributes constant. We also show that the reviewer style is persistent across firms and time. Finally, we find that reviewers with a stricter style are associated with improved financial reporting quality. These findings suggest that individual SEC reviewers have significant influence on the SEC filing review process.

Keywords: SEC Reviewers, Reviewer Style, Comment Letters, Financial Reporting Quality

JEL Classification: M41, M45, M48