With Friends Like These: Rule-Making Comment Submissions to the Securities and Exchange Commission
研究检验了行政程序法是否赋予行业主导组织在规则制定中的特权地位，通过分析1998年证券交易委员会对评论提交的声明，发现没有证据表明机构特权利益更能改变已提议的规则。
Structure and process theorists (McCubbins, Noll, and Weingast, among others), argue that the Administrative Procedures Act establishes a privileged position for the dominant organized interest of an industry in their dealings with regulatory agencies. We examined whether this was indeed the case with respect to the APA-required notice and comment period for rule making at the Securities and Exchange Commission (SEC). Based on an analysis of the commission‘s own statements regarding comment submissions in 1998, there is little to no evidence that interests that are more institutionally privileged are any more effective in changing the SEC’s mind once the agency has proposed a rule.