The SEC's September spike: Regulatory inconsistency within the fiscal year

• 成果类型: Article
• 署名作者: Donelson, Dain C.; Kubic, Matthew; Toynbee, Sara
• 署名单位: University of Iowa; University of Texas System; University of Texas Austin
• 刊物名称: JOURNAL OF ACCOUNTING & ECONOMICS
• ISSN/ISSBN: 0165-4101
• DOI: 10.1016/j.jacceco.2023.101636
• 发表日期: 2024
• 关键词: revolving-door; ENFORCEMENT; securities; PRIVATE; performance; POLITICS; LAW; COMPENSATION; COOPERATION; disclosure

摘要

We examine whether performance reporting leads to inconsistent enforcement at the Securities and Exchange Commission (SEC). In a sample of over 13,000 SEC enforcement actions, we show that SEC staff respond to performance -reporting pressures and file more enforcement actions in September, the final month of the SEC's fiscal year, than in any other month. The increase in case volume in September is not fully explained by staff filing more procedural cases or accelerating case filings. Instead, SEC staff pursue less complex cases and agree to more lenient financial and non -financial sanctions to increase case volume in September. We attempt to rule out alternative explanations for our results, including natural SEC workflow and resource constraints. Overall, our findings suggest that performance reporting creates agency conflicts that lead to regulatory inconsistency within the fiscal year. (c) 2023 Elsevier B.V. All rights reserved.