Multinational Finance Journal

CSR Performance and SEC Comment Letter Review Process

Multinational Finance Journal, 2026, vol. 30, no. 3, pp. 41-78
Doi: 10.67454/30-3-2 – an open-access journal article

Abdul-Rahman Khokhar, Sobey School of Business, Saint Mary’s University, Halifax, Canada

Christine A. Panasian, Sobey School of Business, Saint Mary’s University, Halifax, Canada

Hesam Shahriari, College of Business, Prairie View A&M University, Prairie View, TX, United States

 

Abstract:

We build on the stakeholder theory and reputation literature to document an implicit benefit of firms’ corporate social responsibility (CSR) performance through a novel channel—the Comment Letter (CL) review process by the Securities and Exchange Commission (SEC). We find that a firm’s CSR performance is inversely related to the likelihood of receiving an SEC CL. Moreover, we document that for firms that receive a CL from the SEC, a higher CSR performance is associated with a less severe and less complex review process and, thus, lower associated costs of resolving the CL review. Our results are robust to a comprehensive list of firm-level controls, the inclusion of industry and state fixed effects, and the clustering of standard errors by firm and year. In addition, we show that the findings are robust to potential sample selection bias, alternative specifications and estimation methods, and other endogeneity concerns.

 

Keywords:

Corporate Social Responsibility; CSR Performance; Stakeholder Theory; Reputation; Trust; SEC Comment Letter Process; Disclosure Quality

 

Citation (APA):

Khokhar, A.-R., Panasian, C. A., & Shahriari, H. (2026). CSR performance and SEC comment letter review process. Multinational Finance Journal, 30(3), 41–78.

Citation (Harvard):