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The readability of company responses to SEC comment letters and SEC 10-K filing review outcomes

Author

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  • Cory A. Cassell

    (University of Arkansas)

  • Lauren M. Cunningham

    (The University of Tennessee)

  • Ling Lei Lisic

    (Virginia Polytechnic Institute and State University)

Abstract

An emerging literature shows that shareholders benefit from the Securities and Exchange Commission’s (SEC) filing reviews in terms of improved disclosures and reduced information asymmetry. However, these reviews also impose significant costs on companies because comment letter remediation diverts time and resources away from normal operations and may result in restated or amended filings. Applying processing fluency theory, we examine whether the readability of the company’s initial response to an SEC comment letter is associated with the likelihood of unfavorable outcomes from the review. We find that less readable company responses are associated with longer SEC response times and a greater likelihood that the company restates or amends a reviewed filing. Because the company response is preceded by a specific request for information from the SEC (i.e., a prompt), our setting allows for an improved ability to disentangle the effects of disclosure readability from the effects of disclosure content.

Suggested Citation

  • Cory A. Cassell & Lauren M. Cunningham & Ling Lei Lisic, 2019. "The readability of company responses to SEC comment letters and SEC 10-K filing review outcomes," Review of Accounting Studies, Springer, vol. 24(4), pages 1252-1276, December.
    • Handle: RePEc:spr:reaccs:v:24:y:2019:i:4:d:10.1007_s11142-019-09507-x
    DOI: 10.1007/s11142-019-09507-x
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    3. Panta, Humnath & Narayanasamy, Arun & Panta, Ayush, 2023. "Organizational capital and credit ratings," Finance Research Letters, Elsevier, vol. 57(C).
    4. Panta, Humnath & Panta, Ayush, 2023. "Organizational capital and readability of financial reports," Finance Research Letters, Elsevier, vol. 55(PA).
    5. Muhammad Nadeem, 2022. "Board Gender Diversity and Managerial Obfuscation: Evidence from the Readability of Narrative Disclosure in 10-K Reports," Journal of Business Ethics, Springer, vol. 179(1), pages 153-177, August.
    6. Lu, Jing & Qiu, Yuhang, 2023. "Does non-punitive regulation diminish stock price crash risk?," Journal of Banking & Finance, Elsevier, vol. 148(C).
    7. Ben-Amar, Walid & Bujaki, Merridee & McConomy, Bruce & McIlkenny, Philip, 2021. "Gendering merit: How the discourse of merit in diversity disclosures supports the gendered status quo on Canadian corporate boards," CRITICAL PERSPECTIVES ON ACCOUNTING, Elsevier, vol. 75(C).
    8. Toufiq Nazrul & Adam Esplin & Kevin E. Dow & David M. Folsom, 2022. "Religiosity at the Top and Annual Report Readability," JRFM, MDPI, vol. 15(10), pages 1-19, October.
    9. Hu, Ning & Xu, Jiayi & Xue, Shuang, 2022. "Mandatory disclosure of comment letters and analysts' forecasts," International Review of Financial Analysis, Elsevier, vol. 84(C).
    10. Bret A. Johnson & Ling Lei Lisic & Joon Seok Moon & Mengmeng Wang, 2023. "SEC comment letters on form S-4 and M&A accounting quality," Review of Accounting Studies, Springer, vol. 28(2), pages 862-909, June.
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