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Is the SEC Captured? Evidence from Comment-Letter Reviews

Author

Listed:
  • Jones Heese

    (Harvard Business School, Accounting and Management Unit)

  • Mozaffar Khan

    (University of Minnesota)

  • Karthik Ramanna

    (Oxford University)

Abstract

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.

Suggested Citation

  • Jones Heese & Mozaffar Khan & Karthik Ramanna, 2017. "Is the SEC Captured? Evidence from Comment-Letter Reviews," Harvard Business School Working Papers 17-087, Harvard Business School.
  • Handle: RePEc:hbs:wpaper:17-087
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    More about this item

    Keywords

    comment letters; political connections; regulatory capture; SEC enforcement;
    All these keywords.

    JEL classification:

    • D72 - Microeconomics - - Analysis of Collective Decision-Making - - - Political Processes: Rent-seeking, Lobbying, Elections, Legislatures, and Voting Behavior
    • G18 - Financial Economics - - General Financial Markets - - - Government Policy and Regulation
    • M41 - Business Administration and Business Economics; Marketing; Accounting; Personnel Economics - - Accounting - - - Accounting
    • M48 - Business Administration and Business Economics; Marketing; Accounting; Personnel Economics - - Accounting - - - Government Policy and Regulation

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