Such claims in the period leading up to 2012 motivated deferral of IC compliance for
‘‘emerging growth firms’’ in the JOBS Act. However, Gao, Ritter, and Zhu (2013) show that the
downward trend in IPOs started well before SOX (see Figure 3, where the drop in small firm IPOs
occurred in 2001, before SOX’s passage). Gao et al. (2013) also document that despite the SEC
revising rules to reduce the compliance costs burden on small companies, and then small firms
being permanently exempted by Congress in the Dodd-Frank Act, the number of small IPOs has not
increased. Gao et al. (2013) attribute the drop-off in IPOs to the absence of profitable small
companies and technological changes that make economics of scope and ability to speed products
to markets more important than in the past, giving an advantage to larger firms.
While the evidence of SOX’s effect on the number of IPOs in the U.S. remains contested, the
pricing of the IPOs that did occur after SOX improved. Johnson and Madura (2009)