Abstract
We study how public participation shapes financial regulation using a novel dataset of 453 SEC rules proposed between 1995 and 2024. We collect over 81,000 public comments and 5,600 meetings between regulators and stakeholders related to those rules. Using large language models, we identify participants and extract structured measures of comment content and tone. We document asymmetries in stakeholder participation: retail investors dominate comment volume with shorter submissions, while institutional actors engage primarily through detailed comments and meetings with the SEC officials. Input from sophisticated stakeholders is more likely to be incorporated into the final rule release and informs rule adoption. Overall, the results indicate that rulemaking outcomes respond to the composition and sophistication of participation, not volume.
Disciplines
Banking and Finance Law | Law and Economics | Securities Law
Date of this Version
2-10-2026
Working Paper Citation
Guseva, Yuliya; Hutton, Irena; Pritchard, Adam C.; and Grundfest, Joseph, "Who Gets a Seat at the Table? Stakeholder Participation in SEC Rulemaking" (2026). Law & Economics Working Papers. 310.
https://repository.law.umich.edu/law_econ_current/310