Research

Regulation and enforcement in the financial sector

Map of the United States with locations marked by red dots

Threat of entry and the use of discretion in banks’ financial reporting

Journal of Accounting and Economics, 2019, 67(1), 1-35

Abstract

This paper studies managers’ use of accounting discretion to deter entry. Using state-level changes in branching regulation under the Interstate Banking and Branching Efficiency Act, I find geographically-constrained community banks increased their loan loss provisions to appear less profitable when faced with the threat of entry by competitors. Additional tests rule out alternative explanations that firm economics or regulators drove the increase. I complement my analyses with survey-based evidence. Findings from the survey confirm that banks prefer to locate in markets where incumbents have high profitability and low credit losses, and that banks use competitors’ financial statements to analyze competition.

Materials

As part of this study, I conducted a survey of community bankers. Details related to the survey can be found in Appendix A of the paper, as well as here:

Media

Chart of the number of enforcement decisions and orders (EDOs) per year, 1990 to 2017, with their mean and median length

Observing Enforcement: Evidence from Banking

with Anya Kleymenova

Journal of Accounting Research, 2022, 60(4), 1583-1633

Abstract

This paper finds that the disclosure of supervisory actions by bank regulators is associated with changes in their enforcement behavior. Using a novel sample of enforcement decisions and orders (EDOs) and a change in the disclosure regime, we find that regulators issue more EDOs, intervene sooner, and rely more on publicly observable signals following the regime change. EDO documents become longer, more complex, and contain more boilerplate language. Our results also indicate that intervention happens sooner and more frequently in counties with higher news circulation, which suggests that regulators take into account the public perception of their actions. We evaluate potentially confounding factors, including the savings and loan (S&L) crisis and competition from thrifts, and find robust results. We also study bank outcomes and document that uninsured deposits decline at EDO banks in the disclosure regime, especially for those covered in the news. Finally, we observe that bank failure accelerates despite improvements in capital ratios and asset quality. Overall, our research provides new insights on the disclosure of regulatory actions.

Materials

Awards

  • 2019 Bureau Van Dijk Best Paper Award in Banking, Sydney Banking and Financial Stability Conference
  • 2020 EFA Best Paper Award

Media

Bar charts of changes in mortgage portfolio share and market share for minority and Black or African American borrowers during and after EDOs

Bank Supervision and Organizational Capital: The Case of Minority Lending

with Byeongchan An, Robert Bushman and Anya Kleymenova

Journal of Accounting Research, 2024, 62(2), 505-549

Abstract

Racial disparities in mortgage lending have important welfare implications. We investigate whether improvements in banks’ organizational capital and associated control systems facilitate increased lending to minority borrowers. We focus on bank supervisors’ enforcement decisions and orders (EDOs) against banks, which can enforce changes in banks’ internal processes, procedures, and management practices. We hypothesize that EDO-imposed improvements in loan policies, internal governance, and employee training mitigate deficiencies in credit assessments and lending decisions that previously disadvantaged minority borrowers. We find that relative to white borrowers, mortgage lending to minority borrowers significantly increases following the resolution of EDOs, where this positive effect increases with the strictness of bank supervisors and the severity of the EDO. Using a semi-supervised machine learning method to analyze and quantify the text of EDOs, we find that increases in minority lending are significantly higher for EDOs specifying revisions of loan policies, implementation of formal internal governance procedures, or more employee training, especially in areas with a high proportion of subprime borrowers. Overall, we find that EDO-driven improvements in organizational capital generate unintended, positive social externalities that enhance access to credit for minority borrowers.

Materials

Media

Line chart of the probability of loan delinquency by months since origination, for loans made before, during and after an EDO and for control loans

Trust in Banks and Borrower Behavior

with Samuel Chang and Jizhou Wang

Working paper

Abstract

We examine how trust shapes retail borrowers’ decisions to transact with banks, using regulatory enforcement actions as reputational shocks that erode consumers’ confidence. Survey data confirm that enforcement actions are associated with significant declines in trust in banks and bankers. Using granular loan data from TransUnion linking borrowers to lenders, we find that higher-quality borrowers exit sanctioned banks. Consistent with a trust-based mechanism, higher-quality borrowers also leave unsanctioned banks and migrate to nonbank financial institutions, reducing their overall exposure to the banking sector. Sanctioned banks retain fewer repeat borrowers, and the shift toward lower-quality borrowers intensifies as survey-based trust declines and local news coverage becomes negative. In contrast, borrower quality shows little change when local news is positive or conveys trust, and in regions without local news outlets, underscoring the media’s role in contextualizing news and shaping consumers’ trust. Additional tests indicate these findings are inconsistent with supply-side explanations.

Media

Financial sector enforcement and credit access in developing markets

A crowded bazaar lane lined with vendors and sacks of produce

Community Membership and Reciprocity in Lending: Evidence from Informal Markets

with Regina Wittenberg-Moerman

Journal of Accounting and Economics, 2024, 78(1), 101697

Abstract

We study credit access in informal economies where market institutions, such as financial reporting systems, auditing, and courts, are nonexistent or function poorly. Using the setting of a large bazaar in India, we find that community membership plays a vital role in access to credit. Wholesalers are more likely to provide credit and offer greater amounts of credit to within-community retailers, and are more lenient when these retailers are delinquent. Furthermore, wholesalers who lent preferentially to their community retailers pre-COVID are more likely to receive help from their community following the COVID-19–related income shock, particularly from same-community landlords and suppliers. Also, wholesalers with low endowments, those with greater within-community information flow about them, and those facing income shocks are more likely to provide preferential credit to their community retailers. Our findings are consistent with an indirect reciprocity mechanism explaining within-community credit flows.

Media

Screen from the choice experiment comparing two retailers on community, profits, relationship length, sales and trade credit

Information Preference and Credit Allocation in a Bazaar Economy

with Regina Wittenberg-Moerman

Management Science, 2025, 71(12), 10642-10670

Abstract

Traders operating in informal economies tend to use non-accounting metrics in their credit allocation decisions. By using a combination of survey questions and a hypothetical choice experiment, we explore wholesalers’ preferences for retailers’ accounting information and, importantly, the reasons for its limited use. Based on estimates of wholesalers’ willingness to pay for retailer information, we find that although wholesalers continue to value non-accounting information such as retailers’ community membership and relationship length, they also overwhelmingly value their sales and profits in making credit decisions. However, wholesalers do not use accounting information because they perceive it to be unreliable, and retailers do not share this information because they feel it will be misused. Our findings suggest that improving the reliability of accounting information and preventing its misuse will increase the use of such information in credit allocation in informal markets.

Media

Accounting and the Informal Economy: A Review and Discussion

Journal of Accounting and Economics, Forthcoming

Abstract

This paper discusses Aguilar, Lind, and Ramesh’s study of accounting practices in the informal economy. Using survey data from the International Labour Organization (ILO), the authors document that a substantial fraction of informal microenterprises in Central America voluntarily maintain accounting records, and that accounting quality is associated with owner characteristics, financing choices, access to credit, and business expansion plans. I situate these findings within the broader literature on informality and on the role of accounting in economic development, and argue that the paper opens up a promising agenda for accounting research in developing economies. I also outline directions for future work, including the need for research that can identify the causal effect of accounting on economic development.

Map of India with bank branch locations marked in two colors

Banking on Trust: Supervisory Transparency and Depositors’ Actions

with Abhiman Das and Tanmoy Majilla

Working paper

Abstract

We explore the role of institutional trust in influencing depositors’ reactions to bank supervisory actions in India. Utilizing a unique event that led to unexpected penalties on banks and the quasi-random nature of branch locations, we find news of penalties on some banks leading to deposit withdrawals from offending and neighboring nonoffending branches. Such withdrawals are more pronounced in regions with lower trust in public institutions, including trust in courts and banks. Trust is associated with information access and the quality of local services. We find limited evidence that credit and economic activity also decline in regions with deposit withdrawals.

Media

Regulation and enforcement in the broader economy

Bar chart of deferred prosecution agreements per year, 2001 to 2019, with and without a corporate monitor

Out of Site, Out of Mind? The Role of the Government-Appointed Corporate Monitor

with Lindsey Gallo and Kendall Lynch

Journal of Accounting Research, 2023, 61(5), 1633-1698

Abstract

We study the role of a relatively new type of external firm monitor, an on-site government-appointed Corporate Monitor, and assess whether such appointments reduce firms’ propensity to violate laws. Using a sample of deferred and non-prosecution agreements, we first document the determinants of Monitor-appointment. We find firms that voluntarily disclose wrongdoing and have more independent directors are less likely to have Corporate Monitors, whereas those with more severe infractions, mandated board changes, and increased cooperation requirements are more likely to have Monitors. We find such appointments are associated with an 18%-25% reduction in violations while the Monitor is on site, however, the effect does not persist after the Monitorship ends. Using a semi-supervised machine learning method to measure changes in firms’ ethics and compliance norms, we find that the reduction in violations is associated with changes in ethics and compliance that also do not persist. Finally, we document that firms under Monitorship experience a persistent reduction in innovation, highlighting a previously unexplored cost of these interventions. Overall, our results suggest that, although Corporate Monitors on site are associated with fewer violations, firms revert to previous levels of violations following Monitors’ departure.

Materials

Awards

  • The 2022-23 Glen McLaughlin Prize for Research in Accounting Ethics (Steed School of Accounting, University of Oklahoma)

Media

Repatriation Taxes and Foreign Cash Holdings: The Impact of Anticipated Tax Reform

with Lisa De Simone and Joseph Piotroski

The Review of Financial Studies, 2019, 32(8), 3105-3143

Abstract

We examine whether an anticipated reduction in future repatriation taxes affects the amount of cash U.S. multinationals hold overseas. We find that the expected benefits of a repatriation tax reduction are positively associated with accelerated accumulations of global cash holdings once Congress proposed legislation. Additional tests examining domestic and foreign corporations, voluntary disclosures of foreign cash, and corporate payout behavior support our conclusion that observed increases in excess global cash are driven by changes in foreign cash. We also document that U.S. multinationals accumulating excess cash engage in complementary organizational and financial reporting activities designed to maximize expected tax benefits.

Media

Accounting information and productivity

Map of Taiwan showing semiconductor plant locations and earthquake intensity contours

Supply Chain Shocks and Firm Productivity: The Role of Reporting Quality

with Philip Berger

Journal of Accounting and Economics, 2026, 81(2), 101833

Abstract

We examine the role of accounting information quality in firms’ responses to a supply chain shock. Large bodies of research examine the role of accounting quality in recurring operating or investing decisions, but evidence is lacking on how the quality of accounting information relates to how well firms restructure in the face of a disruptive shock. Our shock is the 1999 Taiwan earthquake, which negatively impacted a subset of US high-technology manufacturing firms by disrupting their supply chains. We find total factor productivity increases for affected US high-tech firms relative to unaffected ones. We also find that affected firms increase their productivity more if they have higher pre-shock accounting quality. Finally, we investigate the channels by which the accounting quality mechanism operates in our setting and find that better accounting quality reduces information frictions related to management’s assessment of the investment opportunity set.

Awards

  • Best Paper in Corporate Finance, 2018 SFS Cavalcade Asia-Pacific

Media