Earnings Conference Calls and the SEC Comment Letter Process

• 成果类型: Article; Early Access
• 署名作者: Lerman, Alina; Steffen, Thomas D.; Zhang, Kangkang
• 署名单位: University of Connecticut; Yale University; University of Illinois System; University of Illinois Urbana-Champaign
• 刊物名称: MANAGEMENT SCIENCE
• ISSN/ISSBN: 0025-1909
• DOI: 10.1287/mnsc.2023.02065
• 发表日期: 2026
• 关键词: CONFERENCE CALLS; SEC comment letters; voluntary disclosure; regulators

摘要

The Securities and Exchange Commission (SEC) reviews firms' financial reports and issues comment letters to ensure compliance with applicable disclosure and accounting requirements. We explore the nature, determinants, and consequences of SEC comment letters that refer to information disclosed in voluntary earnings conference calls. Using handcollected data, we document that the SEC primarily references these voluntary disclosures to illustrate insufficiencies and, less commonly, inconsistencies in mandatory filings across a wide range of topics. These letters are more likely to be issued when filing reviews are more complex, SEC staff are less resource constrained, and for firms with more institutional investors and analysts. Conference call-related comments tend to occur during higherquality review processes and require greater remediation costs than other comments. The SEC's use of call disclosures also leads to more pronounced changes in firms' subsequent mandatory filings, particularly when the firm indicates agreement with SEC comments. However, we observe a mixed effect on the overall information environment, consistent with possible unintended consequences for the quality of firms' voluntary disclosures.