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Investor Relations and Regulation FD

Investor Relations and Regulation FD

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stop disclosing altogether. 3 Critics argued that Reg <strong>FD</strong> would have in a chilling effect on<br />

communications as firms would prefer silence over publicly releasing information that could be<br />

exploited by competitors or misinterpreted by investors. The evidence tends to support the<br />

contrary, with several studies demonstrating that disclosure has increased in the post-Reg <strong>FD</strong> era.<br />

For example, Heflin et al. (2003) finds that public earnings disclosures more than doubled from<br />

pre- to post-Reg <strong>FD</strong>. Bushee et al. (2004) find that Reg <strong>FD</strong> had a dampening effect on manager’s<br />

decisions to host conference calls, however, the magnitude of the effect was not large. We expect<br />

that IR firms were likely to have been engaged in private guidance pre-Reg <strong>FD</strong> but that they will<br />

transition to public guidance after implementation of the rule.<br />

The analyst community was vocal in its opposition to Reg <strong>FD</strong>. They argued that Reg <strong>FD</strong><br />

would reduce the quantity <strong>and</strong> quality of disclosure, leading to a lower quality of analyst<br />

forecasts <strong>and</strong> a weakened information environment (SIA, 2001). IR professionals are also<br />

concerned about forecast quality <strong>and</strong> cite decreased st<strong>and</strong>ard deviation of analyst forecasts <strong>and</strong><br />

increased analyst forecast accuracy as measures of IR performance (Mahoney <strong>and</strong> Lewis, 2004).<br />

Additionally, the SEC was concerned that analysts felt pressured to maintain an optimistic view<br />

of a company in order to have continued access to selectively disclosed information. In general,<br />

the evidence implies that Reg <strong>FD</strong> has reduced selective disclosures to analysts but with mixed<br />

evidence on accuracy <strong>and</strong> dispersion. Gintschel <strong>and</strong> Markov (2004) find the price impact of<br />

analyst reports is lower <strong>and</strong> that this decrease is related to proxies for the level of selective<br />

disclosure prior to Reg <strong>FD</strong> (e.g. brokerage size) . Mohanram <strong>and</strong> Sunder (2006) find that analysts<br />

are spending more effort in private information discovery post-Reg <strong>FD</strong>. They also find an<br />

increase in forecast dispersion <strong>and</strong> that analysts with preferential links (the proxy again is<br />

brokerage size) have greater accuracy in the prior period but that this advantage is negated post-<br />

3 A third (illegal) option would be to continue privately disclosing <strong>and</strong> disregard Reg <strong>FD</strong>.<br />

7

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