Policy Impact
Professor White’s impact on policy has been made across a number of federal agencies, primarily the U.S. Securities and Exchange Commission. Josh White has testified to the U.S. Congress on multiple occasions. He has written numerous policy white papers and comment letters that were highly referenced in rulemaking endeavors. His work has been cited by lawmakers and senior government officials.
Congressional Testimony · Speeches · White Papers · Comment Letters · References by Policymakers
Congressional Testimony
Beyond Scope: How the SEC’s Climate Rule Threatens American Markets
House Financial Services Committee · April 10, 2024
Reforming the Proxy Process to Safeguard Investor Interests
House Financial Services Committee, Subcommittee on Capital Markets · July 13, 2023
Speeches
Information in the Age of AI
ICI Compliance, Risk, and Legal Conference · Nashville, TN · September 17, 2026
Policy White Papers
Stakeholder Engagement with PCAOB Website Data
PCAOB White Paper · September 2025 · with Rahsan Inget and Jake Krupa
This paper offers the first comprehensive empirical analysis of direct stakeholder engagement with audit-related information made available on the PCAOB website.
Corporate Liquidity Provision and Share Repurchase Programs
U.S. Chamber of Commerce, Center for Capital Markets Competitiveness · Fall 2021 · with Craig Lewis
This study demonstrates that stock buybacks provide significant benefits, including increased stock liquidity, reduced volatility, and savings for retail investors.
- Cited in the SEC’s Final Rule, Share Repurchase Disclosure Modernization (May 3, 2023)
- Cited by SEC Commissioner Hester Peirce in her statement (May 3, 2023)
- Cited in the opinion of the U.S. Court of Appeals for the Fifth Circuit in Chamber of Commerce et al. v. SEC, No. 23-60255 (October 31, 2023), which also cited the related comment letter; the buyback rule was vacated on December 19, 2023
Science or Compliance? Will Section 404(b) Compliance Impede Innovation by Emerging Growth Companies in the Biotech Industry?
Biotechnology Innovation Organization White Paper · February 2019 · with Craig Lewis
The 2012 JOBS Act aimed to help low-revenue biotech and tech companies access capital by easing regulatory compliance burdens.
- Cited in the SEC’s Final Rule, Accelerated Filer and Large Accelerated Filer Definitions (March 12, 2020)
- Cited by SEC Commissioner Hester Peirce in her statement (March 12, 2020)
Outcomes of Investing in OTC Stocks
U.S. Securities and Exchange Commission White Paper · December 2016
This paper investigates the over-the-counter (OTC) stock market using Electronic Blue Sheets (EBS) data, finding that OTC stocks are highly illiquid and frequently targeted for market manipulation.
- Cited by NASAA in a request for comments (April 26, 2023)
- Cited by SEC Commissioner Caroline Crenshaw in a speech (May 14, 2021)
- Cited in the SEC’s Final Rule, Publication or Submission of Quotations Without Specified Information (September 16, 2020)
- Cited in the SEC’s Proposed Rule, Publication or Submission of Quotations Without Specified Information (September 25, 2019)
- Cited by SEC Investor Advocate Rick Fleming in a speech (May 9, 2017) and in a report (April 21, 2017)
Qualified Residential Mortgage: Background Data Analysis on Credit Risk Retention
U.S. Securities and Exchange Commission White Paper · August 2013 · with Scott Bauguess
This document analyzes serious delinquencies among non-GSE securitized mortgages in response to concerns about the 2011 proposed Qualified Residential Mortgage (QRM) criteria.
- Cited by SEC Commissioner Luis A. Aguilar in a statement (October 22, 2014)
- Cited in the Final Rule on Credit Risk Retention (January 10, 2014)
- Cited in the Re-Proposed Rule on Credit Risk Retention (August 28, 2013)
Authored or Co-Authored Comment Letters on Rulemaking
- SEC Roundtable on Emerging Markets Risks — June 6, 2020
- Application of the Proxy Rules to Proxy Voting Advice — June 23, 2021
- Human Capital Disclosure Requirements — January 11, 2022
- Share Repurchase Disclosure Modernization — April 1, 2022*
- Share Repurchase Disclosure Modernization — October 7, 2022*†‡
- Share Repurchase Disclosure Modernization — January 11, 2023*
- Non-compliance with Laws and Regulations (NOCLAR) — March 15, 2024
* Cited in the SEC’s Final Rule, Share Repurchase Disclosure Modernization (May 3, 2023).
† Cited in the SEC’s Final Rule, Insider Trading Arrangements and Related Disclosures (December 14, 2022).
‡ Cited in the amicus brief of Investor Choice Advocates Network, Chamber of Commerce v. SEC (July 17, 2023).
References by Policymakers or Lawmakers to Academic Research
- Maryland Securities Commissioner Melanie Lubin cites “Deregulating innovation capital: The effects of the JOBS Act on biotech startups” in testimony to Congress (April 19, 2023)
- SEC Chief Accountant Wesley Bricker cites “The effect of institutional ownership on firm transparency and information production” in a speech (May 2, 2019)
- FTC Commissioner Noah Joshua Phillips cites “The effect of institutional ownership on firm transparency and information production” in a speech (June 1, 2018)
- SEC Chair Mary Jo White cites “Differences in the information environment prior to seasoned equity offerings under relaxed disclosure regulation” in a speech (October 28, 2015)
- SEC Commissioner Michael Piwowar cites “Differences in the information environment prior to seasoned equity offerings under relaxed disclosure regulation” in a speech (May 16, 2014)
- SEC Commissioner Dan Gallagher cites “Differences in the information environment prior to seasoned equity offerings under relaxed disclosure regulation” in a speech (April 29, 2014)
Others: SEC Advisory Committee on Small and Emerging Companies, A. Green (testimony to Congress), T. Quaadman (testimony to Congress), Rep. P. McHenry (report to Congress), Massachusetts Chief Securities Regulator, G-20Y Summit Global Financial Industry Committee, GAO (report to Congress).
The Securities and Exchange Commission disclaims responsibility for any private publication or statement of any SEC employee or Commissioner. This website expresses the author’s views and does not necessarily reflect those of the Commission, the Commissioners, or other members of the staff.