[PDF][PDF] Corporate human capital disclosures: Evidence from the first two years of the SEC's disclosure mandate

E Demers, VX Wang, K Wu - SSRN Scholarly Paper. Rochester …, 2024 - researchgate.net
SSRN Scholarly Paper. Rochester, NY: Social Science Research Network. doi, 2024researchgate.net
In 2020, the SEC issued amendments to Regulation SK requiring filers to provide
discussions related to their human capital (HC) management practices. We use textual
analysis to extract qualitative characteristics of these disclosures for all available 10-Ks
during the first two years of the mandate. We document that, instead of evolving towards
“best in class” disclosure practices under the principles-based regulation, firms exhibit a
regression towards the mean on each qualitative characteristic that we examine: length …
Abstract
In 2020, the SEC issued amendments to Regulation SK requiring filers to provide discussions related to their human capital (HC) management practices. We use textual analysis to extract qualitative characteristics of these disclosures for all available 10-Ks during the first two years of the mandate. We document that, instead of evolving towards “best in class” disclosure practices under the principles-based regulation, firms exhibit a regression towards the mean on each qualitative characteristic that we examine: length, number of topics, specificity, numerosity, readability, and similarity. In other words, although firms with poorer-quality disclosures improve over time, those with better-quality disclosures learn that they have overshot the average standard and reduce the quality of their disclosures. Further tests reveal that, notwithstanding their limitations, certain HC disclosure characteristics are significantly associated with employee ratings from Glassdoor as well as with firm value.
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