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Styles of Regulators: Evidence from the SEC's Comment Letters†

Contemporary Accounting Research 2022 39(2), 789-825 open access
We investigate whether individual securities regulators exhibit personal styles in their work, a question of importance to corporate executives and capital market participants. Using the SEC's comment letters as our setting, we find that SEC staff members exhibit unique personal “styles.” We manually collect information on SEC staff members and provide evidence that staff members' personal characteristics influence the SEC's review process. Further analyses reveal that SEC staff members with a CPA qualification are associated with a lower likelihood of future accounting restatements; moreover, similarity between the SEC staff member and the firm's correspondent is associated with lower scrutiny intensity. Overall, our study offers evidence that SEC staff members exhibit individual differences and that their styles shape the SEC's enforcement actions. Our results offer implications for the working of securities regulators.

Rocking the boat: How relative performance evaluation affects corporate risk taking

Journal of Accounting and Economics 2022 73(1), 101425
We argue that relative performance evaluation (RPE) contracts introduce a tournament among the focal firm and peer firms. We test whether a firm's riskiness is altered by its CEO's incentive to win the tournament. We find that a firm that performed poorly relative to its peers during an interim period takes more risk in the remainder of the evaluation period than a firm with better interim performance. This effect is stronger when the interim assessment date is closer to the end of the evaluation period and when winning the competition is more important to the CEO. Together, our results suggest that RPE contracts create tournament incentives for CEOs and significantly affect corporate risk taking.