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The effect of enforcement transparency: Evidence from SEC comment-letter reviews

Author

Listed:
  • Miguel Duro

    (IESE Business School)

  • Jonas Heese

    (Harvard Business School)

  • Gaizka Ormazabal

    (IESE Business School
    C.E.P.R)

Abstract

This paper studies the effect of the public disclosure of the Securities and Exchange Commission (SEC) comment-letter reviews (CLs) on firms’ financial reporting. We exploit a major change in the SEC’s disclosure policy: in 2004, the SEC decided to make its CLs publicly available. Using a novel dataset of CLs, we analyze the capital-market responses to firms’ quarterly earnings releases following CLs conducted before and after the policy change. We find that these responses increase significantly after the policy change. These stronger responses partly occur while the review is ongoing and persist on average for two years. Corroborating these results, we also document a set of changes that firms make to their accounting reports following CLs. Our results indicate that disclosure of regulatory oversight activities can strengthen public enforcement.

Suggested Citation

  • Miguel Duro & Jonas Heese & Gaizka Ormazabal, 2019. "The effect of enforcement transparency: Evidence from SEC comment-letter reviews," Review of Accounting Studies, Springer, vol. 24(3), pages 780-823, September.
    • Handle: RePEc:spr:reaccs:v:24:y:2019:i:3:d:10.1007_s11142-019-09503-1
    DOI: 10.1007/s11142-019-09503-1
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    2. Heese, Jonas & Krishnan, Ranjani & Ramasubramanian, Hari, 2021. "The Department of Justice as a gatekeeper in whistleblower-initiated corporate fraud enforcement: Drivers and consequences," Journal of Accounting and Economics, Elsevier, vol. 71(1).
    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. Jonas Heese, 2022. "Does Industry Employment of Active Regulators Weaken Oversight?," Management Science, INFORMS, vol. 68(12), pages 9198-9218, December.
    5. Hou, Chenxue & Wang, Qijian, 2023. "CSRC oral communication and corporate disclosure," Journal of Corporate Finance, Elsevier, vol. 79(C).
    6. Zhu, Xiuli & Li, Xiaohui & Zhou, Kexin & Yu, Yuying, 2023. "The impact of annual reports transparency and comment letters on the cost of debt: Evidence for China," Pacific-Basin Finance Journal, Elsevier, vol. 77(C).
    7. Longhao Xu & Zhijian James Huang & Fenghua Wen, 2022. "Comment letters and stock price synchronicity: evidence from China," Review of Quantitative Finance and Accounting, Springer, vol. 59(4), pages 1387-1421, November.
    8. James P. Ryans, 2021. "Textual classification of SEC comment letters," Review of Accounting Studies, Springer, vol. 26(1), pages 37-80, March.
    9. Hills, Robert & Kubic, Matthew & Mayew, William J., 2021. "State sponsors of terrorism disclosure and SEC financial reporting oversight," Journal of Accounting and Economics, Elsevier, vol. 72(1).
    10. Ge, Wenxia & Ouyang, Caiyue & Shi, Zhenyang & Chen, Zhanliao, 2022. "Can a not-for-profit minority institutional shareholder make a big difference in corporate governance? A quasi-natural experiment," Journal of Corporate Finance, Elsevier, vol. 72(C).
    11. Yao, Youfu & Hong, Yun, 2023. "Can comment letters impact excess cash holdings? Evidence from China," International Review of Economics & Finance, Elsevier, vol. 83(C), pages 900-922.
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    14. Hutton, Amy & Shu, Susan & Zheng, Xin, 2022. "Regulatory transparency and the alignment of private and public enforcement: Evidence from the public disclosure of SEC comment letters," Journal of Financial Economics, Elsevier, vol. 145(1), pages 297-321.

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