Conflicted Regulators: Indirect Revolving-Door Connections in SEC Filing Reviews
研究美国证券交易委员会（SEC）审查员与前雇主（审计公司）的间接雇佣关系如何影响审查严格性，发现关联审查员更少发现错误、提出较少实质问题，且随任职时间延长效应减弱。
ABSTRACT 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. JEL Classifications: G18; M41; M48.