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Individual Lawyers, The Sec Revolving Door, And Comment Letters, Michael Shen, Samuel T. Tan
Individual Lawyers, The Sec Revolving Door, And Comment Letters, Michael Shen, Samuel T. Tan
Research Collection School Of Accountancy
Government officials, advocacy groups, and the business press have raised concerns that former SEC employees may continue to influence the SEC after leaving the agency. Using a hand-collected database of individual lawyers that represent firms in responding to SEC comment letters, we examine the impact of individual lawyers, and lawyers formerly employed by the SEC, on the comment letter process. We document significant differences between lawyers and law firms in their clients’ resistance to SEC comment letters, and find that firms that retain former SEC employees are larger, more profitable, and more likely to have received a comment letter raising …