Regulator Continuity and Decision-Making Quality: Evidence from SEC Comment Letters

49 Pages Posted: 1 Apr 2021

See all articles by Matthew Kubic

Matthew Kubic

University of Texas at Austin

Sara Toynbee

University of Texas at Austin

Date Written: March 10, 2021

Abstract

High quality financial information depends on the effectiveness of regulators charged with ensuring compliance with financial reporting regulation. We use the Securities and Exchange Commission (SEC) filing review process as a setting to test whether individual regulators’ prior involvement (i.e., review team continuity) is associated with the quality of their decision-making. Although continuity may allow regulators to develop valuable knowledge to improve their decision-making, our results are more consistent with continuity leading to lower-quality reviews. Specifically, we find that review team continuity is associated with shorter reviews that ask fewer questions related to authoritative guidance or materially deficient areas, are more similar to the prior review, and are less likely to elicit an acknowledgement that the firm will change their filings. Our inferences are robust to using SEC staff turnover as an instrument for continuity. Overall, our results suggest new team members may provide a fresh perspective.

Keywords: SEC, comment letter, regulators, decision-making biases, rotation, teams

JEL Classification: M41, M48

Suggested Citation

Kubic, Matthew and Toynbee, Sara, Regulator Continuity and Decision-Making Quality: Evidence from SEC Comment Letters (March 10, 2021). Available at SSRN: https://ssrn.com/abstract=3802115 or http://dx.doi.org/10.2139/ssrn.3802115

Matthew Kubic

University of Texas at Austin ( email )

2317 Speedway
Austin, TX 78712
United States

Sara Toynbee (Contact Author)

University of Texas at Austin ( email )

2317 Speedway
Austin, TX 78712
United States

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