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SEC monitoring of foreign firms’ disclosures in the presence of foreign regulators

Author

Listed:
  • James P. Naughton

    (Northwestern University)

  • Rafael Rogo

    (Indiana University)

  • Jayanthi Sunder

    (University of Arizona)

  • Ray Zhang

    (Simon Fraser University)

Abstract

SEC comment letters indicate that the SEC has reviewed the firm’s filings and identified a disclosure issue. Using the existence of an SEC comment letter as a proxy for SEC monitoring, we document a negative association between the level of SEC monitoring of foreign firms and the strength of those foreign firms’ home-country institutions, consistent with the idea that the SEC implicitly shares its regulatory duties with international securities regulators. We find that foreign cross-listed firms are subject to lower monitoring intensity than foreign firms listed only on US exchanges, but do not find a statistically significant difference in monitoring between foreign firms listed only on US exchanges and US firms. These findings suggest that it is the presence of another regulator that drives the intensity of SEC monitoring. We also find that US investor holdings are positively associated with the level of SEC oversight, suggesting that the SEC focuses its resources on firms that pose a greater risk to US investors. Collectively, our analyses show that two countervailing forces drive the SEC’s choice to monitor foreign firms. On the one hand, the SEC reduces monitoring intensity when it can rely on the public and private enforcement institutions in the foreign firm’s home country. On the other hand, the SEC provides increased monitoring of certain foreign firms when investors on US exchanges have greater investment exposure in those firms.

Suggested Citation

  • James P. Naughton & Rafael Rogo & Jayanthi Sunder & Ray Zhang, 2018. "SEC monitoring of foreign firms’ disclosures in the presence of foreign regulators," Review of Accounting Studies, Springer, vol. 23(4), pages 1355-1388, December.
    • Handle: RePEc:spr:reaccs:v:23:y:2018:i:4:d:10.1007_s11142-018-9467-x
    DOI: 10.1007/s11142-018-9467-x
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    References listed on IDEAS

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    Cited by:

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    3. Koulikidou, Kleopatra & Chantziaras, Antonios & Dedoulis, Emmanouil & Leventis, Stergios, 2023. "Regulatory enforcement, foreignness, and language negativity: Evidence from SEC comment letters," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 51(C).
    4. Reiter, Nayana, 2021. "Investor communication and the benefits of cross-listing," Journal of Accounting and Economics, Elsevier, vol. 71(1).

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