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Does the Public Disclosure of the SEC’s Oversight Actions Matter?

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  • Ormazabal, Gaizka
  • Duro, Miguel
  • Heese, Jonas

Abstract

This paper studies the effect of the public disclosure of the Securities and Exchange Commission (SEC)’s oversight activity on firms’ financial reporting. We exploit a major change in the SEC’s disclosure policy: in 2004, the SEC decided to make its comment-letter reviews publicly available. Using a novel dataset of SEC comment letters (CLs), we analyze the capital-market responses to firms’ quarterly earnings releases during SEC reviews conducted before and after the policy change. We find that these responses increase significantly following the policy change. Consistent with public disclosure of CLs increasing market discipline, we find that this relative increase is stronger among firms with higher percentages of dedicated institutional investors or independent directors. In contrast, we do not find conclusive evidence that public disclosure of CLs increases SEC oversight intensity. Corroborating these results, we also document a set of changes firms make to their accounting reports during these reviews. Our results indicate that the public disclosure of regulatory oversight activities can enhance the effect of these activities.

Suggested Citation

  • Ormazabal, Gaizka & Duro, Miguel & Heese, Jonas, 2017. "Does the Public Disclosure of the SEC’s Oversight Actions Matter?," CEPR Discussion Papers 12145, C.E.P.R. Discussion Papers.
  • Handle: RePEc:cpr:ceprdp:12145
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    as
    1. Rafael La Porta & Florencio Lopez‐De‐Silanes & Andrei Shleifer, 2006. "What Works in Securities Laws?," Journal of Finance, American Finance Association, vol. 61(1), pages 1-32, February.
    2. Gary S. Becker, 1974. "Crime and Punishment: An Economic Approach," NBER Chapters, in: Essays in the Economics of Crime and Punishment, pages 1-54, National Bureau of Economic Research, Inc.
    3. Stephan Hollander & Maarten Pronk & Erik Roelofsen, 2010. "Does Silence Speak? An Empirical Analysis of Disclosure Choices During Conference Calls," Journal of Accounting Research, Wiley Blackwell, vol. 48(3), pages 531-563, June.
    4. Kedia, Simi & Rajgopal, Shiva, 2011. "Do the SEC's enforcement preferences affect corporate misconduct?," Journal of Accounting and Economics, Elsevier, vol. 51(3), pages 259-278, April.
    5. Kothari, S. P., 2001. "Capital markets research in accounting," Journal of Accounting and Economics, Elsevier, vol. 31(1-3), pages 105-231, September.
    6. Asthana, Sharad & Balsam, Steven, 2001. "The effect of EDGAR on the market reaction to 10-K filings," Journal of Accounting and Public Policy, Elsevier, vol. 20(4-5), pages 349-372.
    7. Hans B. Christensen & Luzi Hail & Christian Leuz, 2016. "Capital-Market Effects of Securities Regulation: Prior Conditions, Implementation, and Enforcement," The Review of Financial Studies, Society for Financial Studies, vol. 29(11), pages 2885-2924.
    8. Jackson, Howell E. & Roe, Mark J., 2009. "Public and private enforcement of securities laws: Resource-based evidence," Journal of Financial Economics, Elsevier, vol. 93(2), pages 207-238, August.
    9. Karpoff, Jonathan M. & Lee, D. Scott & Martin, Gerald S., 2008. "The Cost to Firms of Cooking the Books," Journal of Financial and Quantitative Analysis, Cambridge University Press, vol. 43(3), pages 581-611, September.
    10. Beyer, Anne & Cohen, Daniel A. & Lys, Thomas Z. & Walther, Beverly R., 2010. "The financial reporting environment: Review of the recent literature," Journal of Accounting and Economics, Elsevier, vol. 50(2-3), pages 296-343, December.
    11. Dechow, Patricia & Ge, Weili & Schrand, Catherine, 2010. "Understanding earnings quality: A review of the proxies, their determinants and their consequences," Journal of Accounting and Economics, Elsevier, vol. 50(2-3), pages 344-401, December.
    12. Sudipta Basu & Truong Xuan Duong & Stanimir Markov & Eng-Joo Tan, 2013. "How Important are Earnings Announcements as an Information Source?," European Accounting Review, Taylor & Francis Journals, vol. 22(2), pages 221-256, June.
    13. Holger Daske & Luzi Hail & Christian Leuz & Rodrigo Verdi, 2008. "Mandatory IFRS Reporting around the World: Early Evidence on the Economic Consequences," Journal of Accounting Research, Wiley Blackwell, vol. 46(5), pages 1085-1142, December.
    14. 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.
    15. Patricia M. Dechow & Richard G. Sloan & Amy P. Sweeney, 1996. "Causes and Consequences of Earnings Manipulation: An Analysis of Firms Subject to Enforcement Actions by the SEC," Contemporary Accounting Research, John Wiley & Sons, vol. 13(1), pages 1-36, March.
    16. Ball, Ray & Kothari, S. P. & Robin, Ashok, 2000. "Corrigendum to "The effect of international institutional factors on properties of accounting earnings"; [Journal of Accounting and Economics 29 (2000) 1-51]," Journal of Accounting and Economics, Elsevier, vol. 30(2), pages 241-241, October.
    17. Coffee, John C., Jr., 2007. "Law and the Market: The Impact of Enforcement," Working Papers 07-3, University of Pennsylvania, Wharton School, Weiss Center.
    18. Holthausen, Rw & Verrecchia, Re, 1988. "The Effect Of Sequential Information Releases On The Variance Of Price Changes In An Intertemporal Multi-Asset Market," Journal of Accounting Research, Wiley Blackwell, vol. 26(1), pages 82-106.
    19. Kim, Irene & Skinner, Douglas J., 2012. "Measuring securities litigation risk," Journal of Accounting and Economics, Elsevier, vol. 53(1), pages 290-310.
    20. Klein, April, 2002. "Audit committee, board of director characteristics, and earnings management," Journal of Accounting and Economics, Elsevier, vol. 33(3), pages 375-400, August.
    21. Jonathan M. Karpoff & D. Scott Lee & Gerald S. Martin, 2014. "The Consequences to Managers for Financial Misrepresentation," Springer Books, in: Roberto Pietra & Stuart McLeay & Joshua Ronen (ed.), Accounting and Regulation, edition 127, chapter 0, pages 339-375, Springer.
    22. Christian Leuz & Catherine Schrand, 2009. "Disclosure and the Cost of Capital: Evidence from Firms' Responses to the Enron Shock," NBER Working Papers 14897, National Bureau of Economic Research, Inc.
    23. Ball, Ray & Kothari, S. P. & Robin, Ashok, 2000. "The effect of international institutional factors on properties of accounting earnings," Journal of Accounting and Economics, Elsevier, vol. 29(1), pages 1-51, February.
    24. Ball, R & Brown, P, 1968. "Empirical Evaluation Of Accounting Income Numbers," Journal of Accounting Research, Wiley Blackwell, vol. 6(2), pages 159-178.
    25. Christensen, Hans B. & Hail, Luzi & Leuz, Christian, 2013. "Mandatory IFRS reporting and changes in enforcement," Journal of Accounting and Economics, Elsevier, vol. 56(2), pages 147-177.
    26. Heese, Jonas & Khan, Mozaffar & Ramanna, Karthik, 2017. "Is the SEC captured? Evidence from comment-letter reviews," Journal of Accounting and Economics, Elsevier, vol. 64(1), pages 98-122.
    27. Ball, Ray & Robin, Ashok & Wu, Joanna Shuang, 2003. "Incentives versus standards: properties of accounting income in four East Asian countries," Journal of Accounting and Economics, Elsevier, vol. 36(1-3), pages 235-270, December.
    28. Collins, Daniel W. & Kothari, S. P., 1989. "An analysis of intertemporal and cross-sectional determinants of earnings response coefficients," Journal of Accounting and Economics, Elsevier, vol. 11(2-3), pages 143-181, July.
    29. Christian Leuz & Peter D. Wysocki, 2016. "The Economics of Disclosure and Financial Reporting Regulation: Evidence and Suggestions for Future Research," Journal of Accounting Research, Wiley Blackwell, vol. 54(2), pages 525-622, May.
    30. Robert W. Holthausen, 2009. "Accounting Standards, Financial Reporting Outcomes, and Enforcement," Journal of Accounting Research, Wiley Blackwell, vol. 47(2), pages 447-458, May.
    31. Tim Loughran & Bill Mcdonald, 2011. "When Is a Liability Not a Liability? Textual Analysis, Dictionaries, and 10‐Ks," Journal of Finance, American Finance Association, vol. 66(1), pages 35-65, February.
    32. Miles B. Gietzmann & Angela K. Pettinicchio, 2014. "External Auditor Reassessment of Client Business Risk Following the Issuance of a Comment Letter by the SEC," European Accounting Review, Taylor & Francis Journals, vol. 23(1), pages 57-85, May.
    33. Bushman, Robert M. & Piotroski, Joseph D., 2006. "Financial reporting incentives for conservative accounting: The influence of legal and political institutions," Journal of Accounting and Economics, Elsevier, vol. 42(1-2), pages 107-148, October.
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    Cited by:

    1. Ormazabal, Gaizka, 2018. "The Role of Stakeholders in Corporate Governance: A View from Accounting Research," CEPR Discussion Papers 12775, C.E.P.R. Discussion Papers.

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    More about this item

    Keywords

    Disclosure rules; Sec comment letters; Sec oversight;
    All these keywords.

    JEL classification:

    • M41 - Business Administration and Business Economics; Marketing; Accounting; Personnel Economics - - Accounting - - - Accounting

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