Some critics of SOX have also claimed that the costs of SOX, especially the burden of section
404 compliance on small firms, contributed to fewer IPOs in the U.S. in the 2000s (e.g., IPO Task
Force 2011). The drop-off in IPOs is most pronounced for small firms, consistent with a SOX
explanation. Bova, Minutti, Richardson, and Vyas (2013) document a related finding—U.S. private
companies, especially smaller ones, are more likely to be acquired rather than raise financing
through an IPO, post-SOX, unlike a control sample in the U.K., a result that could also contribute to
the IPO drop-off.