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The Role of Academic Research in SEC Rulemaking: Evidence from
 Business Roundtable v. SEC

We examine the role that academic research plays in SEC rulemaking. This paper documents the SEC’s patterns of consumption of academic research from 2007 through 2017. We show how the Business Roundtable v. SEC ruling in 2011 increased consideration given to academic research during SEC rulemaking. We find that after the ruling, the SEC cites more papers and, in particular, more papers that illustrate the costs of regulation. This change in academic citations results in fewer negative comment letters on proposed SEC regulations. We survey academics whose research was cited by the SEC, and the majority respond that the SEC’s description of their work is completely or mostly accurate. When we survey general academics, their average rating of the SEC’s accuracy is lower, although the rating improves regarding specific SEC quotes citing academic research. The average rating of the SEC’s substantiveness is lower than that for accuracy. JEL Classification: A11, G18, G38, M48