Comment letter frequency and CFO turnover: a dynamic survival analysis

Earlier research on chief financial officer (CFO) turnover considered whether one of detailed regulatory findings, such as restatements, affected the likelihood of CFO turnover. However, since the passing of Sarbanes–Oxley Act (SOX), the Security Exchange Commission (SEC) has revised the regulatory approach it uses. It now investigates companies on a more frequent basis and using Comment Letters (CLs) regularly asks registrants to explain disclosure practice with a view to possibly requiring enhanced or revised disclosures. In this new proactive environment, some registrants may repeatedly receive CLs asking questions about multiple disclosure issues. This research uses a dynamic hazard model specification to investigate whether through time CFO turnover increases as the registrants accumulate more CLs. In addition to CL frequency, a measure of the severity of SEC CLs is introduced to see if it moderates the effect of frequenc