The SEC revolving door and comment letters |
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| Institution: | 1. NUS Business School, National University of Singapore, Singapore;2. School of Accountancy, Singapore Management University, Singapore;1. University of Michigan-Flint, Flint, MI, United States;2. Miami University, Oxford, OH, United States;3. University of Memphis, Memphis, TN, United states;4. Old Dominion Unversity, Norfolk, VA, United States;1. School of Economics and Management, Tsinghua University, Beijing 100084, China;2. Guanghua School of Management, Peking University, Beijing 100085, China;3. School of Accountancy, Singapore Management University, Singapore 188065, Singapore;4. College of Economics and Management, China Agricultural University, Beijing 100083, China;1. Faculty of Business and Economics, The University of Hong Kong, Hong Kong, China;2. School of Economics and Management, Harbin Institute of Technology, Shenzhen, China;1. University of Huddersfield, Huddersfield Business School, Queensgate, Huddersfield HD1 3DH, UK;2. Heriot-Watt University, Edinburgh Business School, Mary Burton Building, Edinburgh EH14 4AS, UK |
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| Abstract: | Government officials, advocacy groups, and the business press have raised concerns that former SEC employees may continue to influence the SEC after leaving the agency. Using hand-collected data on the characteristics of 1,384 lawyers who represented firms in responding to SEC comment letters between 2005 and 2016, we examine the impact of post-revolving SEC employees on the SEC comment letter process. Among other determinants, we find that older and larger firms with a history of litigation are more likely to hire former SEC lawyers over non-SEC lawyers. Relative to firms that involve only non-SEC lawyers, we find that firms that involve former SEC lawyers in responding to SEC comment letters negotiate to a greater extent with the SEC, and have a lower likelihood and number of amendment filings, after matching on lawyer, law firm, comment letter, and firm characteristics. |
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