On the SEC's 2010 enforcement cooperation program

Andrew J. Leone, Edward Xuejun Li*, Michelle Liu

*Corresponding author for this work

Research output: Contribution to journalArticlepeer-review

5 Scopus citations


This study examines changes in SEC enforcement and firm cooperation after the SEC introduced its new cooperation program in 2010. While previous research shows that the SEC penalized cooperative firms prior to 2010, our results suggest that after that year, it rewarded cooperation, especially good faith actions. We also find that after 2010, the SEC increased mentions of cooperation in public speeches and publicized more details about firm cooperative activities in AAERs. Finally, we find some evidence that misconduct firms increased good faith cooperation after the SEC revised its cooperation program in 2010. Our findings suggest that having a more explicit leniency program improves its effectiveness.

Original languageEnglish (US)
Article number101355
JournalJournal of Accounting and Economics
Issue number1
StatePublished - Feb 2021


  • Cooperation
  • Leniency
  • Prosecutorial discretion
  • Restatement
  • SEC enforcement

ASJC Scopus subject areas

  • Accounting
  • Finance
  • Economics and Econometrics


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