Generative AI and Regulatory Oversight: Evidence from SEC Comment Letters
Release time：06 January 2026
Jan
07
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Time & Date
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10:30 am
-
12:00 pm,
January
07,
2026
(Wednesday)
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Venue
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Room 103, Conference Complex Ⅱ
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| TOPIC | Generative AI and Regulatory Oversight: Evidence from SEC Comment Letters |
| TIME&DATE | 10:30 am - 12:00 am, January 7, 2026 (Wednesday) |
| Venue | Room 103, Conference Complex Ⅱ |
| Speaker |
Susan Shu Boston College |
| Abstract | This paper studies the use of generative AI at the Securities and Exchange Commission (SEC), focusing on a key enforcement tool – comment letters. Using the AI-detection tool GPTZero, we find that comment letters with higher AI usage are less comprehensive, and this relation holds in panel regressions as well as in an instrumental variables (IV) analysis. Further analysis reveals that comment letters with higher AI usage are more likely to omit important issues, such as topics related to revenue recognition, indicating that AI is not simply cutting “fluff.” The negative association between AI usage and comment letter extensiveness is more pronounced when SEC staff are busier and for industries requiring specialized knowledge. However, we find that it is attenuated, and in some cases reversed, when review teams include staff who are experienced, senior, or have accounting background. Finally, we find that coverage of small firms increased following the release of ChatGPT in November 2022, highlighting a potential benefit of AI. Taken together, our results provide early evidence on how generative AI influences regulatory oversight. |
| Biography | Professor Susan Shu earned her B.A. from the University of Dubuque and her M.S. and Ph.D. from the University of Rochester. She is the Ernst & Young Faculty Fellow and a full professor at Boston College. She currently serves as the Director of the Ph.D. program in accounting. Her research interests include corporate disclosure, media, social media, enforcement, securities litigation, insider trading, and economics of auditor-client alignments. Her research has appeared in leading academic journals such as the Journal of Accounting and Economics, Journal of Financial Economics, Journal of Accounting Research, and The Accounting Review. In 2014, Professor Shu received the prestigious Notable Contributions to Accounting Literature Award from the American Accounting Association for her (coauthored) paper “Do Managers Withhold Bad News?” |
