NIXON, David C <br/><br/>
With friends like these :  rule-making comment submissions to the securities and exchange commission 

 -  2002 
<br/><br/> Structure and process theorists (McCubbing, Noll, and Weingast, among others), argue that the Administrative Procedures Act establishes a privileged position for the dominant organized interest of an industry in their dealings with regulatory agencies. We examined whether this was indeed the case with respect to the APA-required notice and comment period for rule making at the Securities and Exhange Commission (SEC). Based on an analysis of the commission's own statements regarding comment submissions in 1998, there is little to no evidence that interest that are more institutionally privileged are any more effective in changing the SEC's mind once the agency has proposed a rule