SEC Comment Letters and Insider Sales
研究发现，在SEC关于收入确认的意见函公开披露前，内部人交易显著增加，尤其在高空头头寸的公司中交易量达到正常水平的三倍；意见函发布后股价有1%-5%的负向漂移，且内部人提前卖出越多，负向漂移越强，表明内部人从交易中获利。
ABSTRACT We document that insider trading is significantly higher than normal levels prior to the public disclosure of SEC comment letters relating to revenue recognition. Furthermore, insider trading is triple its normal level for firms with high short positions. We find a small negative return at the comment letter release date and a negative drift in returns of 1 to 5 percent over the next 50 days following the release. We also find that greater pre-disclosure sales are associated with a stronger negative drift. This evidence suggests that insiders appear to benefit from trading prior to revenue recognition comment letters. We investigate whether the delayed price reaction to comment letter releases is due to investor inattention. Consistent with this explanation, we document that comment letters are downloaded infrequently from EDGAR in the days following their public disclosure. JEL Classifications: M41; M48; K42