Regulator Continuity and Decision-Making Quality: Evidence from SEC Comment Letters
研究发现美国证券交易委员会员工对同一公司多次审查（连续性）会降低评论信质量，表现为实质性评论减少、披露修改更少、审查内容更相似，而时间推移、公司变化和增强问责感可缓解这一负面效应。
ABSTRACT Staff at the U.S. Securities and Exchange Commission (SEC) conduct recurring reviews of firms’ filings to deter misconduct and facilitate investor access to high-quality information. We identify the names of SEC staff who work on a comment letter and examine whether their prior involvement (i.e., continuity) is associated with comment letter quality. Our results are consistent with continuity leading to lower-quality comment letters. Continuity is associated with fewer substantive comments, agreed-upon disclosure changes, and greater similarity between consecutive comment letter reviews. These results are consistent with continuity increasing staffs’ tendency to focus on familiar issues and overlook other areas of potential deficiencies. Time, changes in firms’ operations, and increasing staffs’ feelings of accountability can mitigate the negative effect of continuity on comment letter quality. Our study suggests benefits to a fresh perspective in regulatory monitoring. JEL Classifications: G18; M41; M48.