CFO Accounting Expertise and SEC Comment Letter Process

Abstract

In this study, we explore the expanded role of chief financial officers (CFOs) in facilitating corporate disclosure by examining how their accounting expertise influences the resolution process of Securities and Exchange Commission (SEC) comment letters issued on 10-K reports. Using CFO professional profile data collected extensively through EDGAR, Lexis-Nexis, and several online searches, we find that CFO accounting expertise improves the resolution of SEC comment letters by reducing the remediation costs and the likelihood of unfavorable resolution outcomes. We also show that the effect of CFO accounting expertise is more pronounced when the CFO’s involvement in the resolution process is greater, and the SEC comment letter includes comments on accounting topics. Our findings are robust to a battery of robustness tests. Overall, this study highlights the importance of CFOs’ role and function in regulatory compliance.JEL codes: G14; G30; M40; M41; M48