Publication Type

Journal Article

Version

acceptedVersion

Publication Date

5-2023

Abstract

Government officials, advocacy groups, and the business press have raised concerns that former SEC employees may continue to influence the SEC after leaving the agency. Using hand-collected data on the characteristics of 1,384 lawyers who represented firms in responding to SEC comment letters between 2005 and 2016, we examine the impact of post-revolving SEC employees on the SEC comment letter process. Among other determinants, we find that older and larger firms with a history of litigation are more likely to hire former SEC lawyers over non-SEC lawyers. Relative to firms that involve only non-SEC lawyers, we find that firms that involve former SEC lawyers in responding to SEC comment letters negotiate to a greater extent with the SEC, and have a lower likelihood and number of amendment filings, after matching on lawyer, law firm, comment letter, and firm characteristics.

Keywords

SEC comment letters, external counsel, revolving door, regulatory capture, Securities and Exchange Commission employees, influence, lawyers

Discipline

Accounting | Accounting Law | Legal Ethics and Professional Responsibility

Research Areas

Corporate Reporting and Disclosure

Publication

Journal of Accounting and Public Policy

Volume

42

Issue

3

First Page

1

Last Page

20

ISSN

0278-4254

Identifier

10.1016/j.jaccpubpol.2023.107080

Publisher

Elsevier

Copyright Owner and License

Authors

Additional URL

https://doi.org/10.1016/j.jaccpubpol.2023.107080

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