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Conflicted Regulators: Indirect Revolving-Door Connections in SEC Filing Reviews
We investigate whether prior employment connections influence the strictness of the Securities and Exchange Commission (SEC) filing review process. Using novel data on over 250 accountants at the SEC, we define connected examiners as accountants reviewing financial statements audited by their former employer. We find that SEC review teams with a higher percentage of connected examiners are less likely to detect financial statement errors, raise fewer substantive issues, and are less likely to push back on registrants’ responses to comment letters. Our estimates also indicate that the effect of examiners’ prior employment connections is strongest earlier in their SEC tenure and attenuates with time. Our findings provide important practical insights on the boundaries of the revolving door between regulators and the regulated, suggesting that even indirect connections can impact oversight.
The Impact of the SEC’s Office of Minority and Women Inclusion: Evidence from the Filing Review Process
We examine the impact of the SEC’s Office of Minority and Women Inclusion (OMWI) on the role of employee gender in the Division of Corporation Finance’s filing review process. Gender bias theory suggests that women may work harder to compensate for perceived bias and discrimination. Consistent with this theory, we find that women reviewers issue longer comment letters, raise more issues, ask more accounting-specific questions, reference more authoritative guidance, request more filing amendments, follow up on more issues from prior rounds, and take longer to close the comment letter process. We also find that women are less prevalent in higher paygrades and leadership positions. These gender differences attenuate after the establishment of OMWI in 2011, but significant differences remain. Analyses of SEC employee survey data corroborate our comment letter results. Data Availability: All data are publicly available.