We document that an SEC investigation of an underwriter imposes indire
ct penalties on the underwriter and its past clients, particularly IPO
clients. Targeted underwriters experience large declines in IPO marke
t share and increased regulatory scrutiny and client risk after an SEC
investigation is announced. Stock prices of clients decline significa
ntly. We attribute these effects to a sudden deterioration in the valu
e of the underwriter's reputation capital, suggesting that the general
assumption in prior IPO research that underwriter reputation is stati
onary may be inappropriate. Our results also suggest that the SEC's po
wer to institute investigations should be considered when designing op
timal securities regulation. (C) 1998 Elsevier Science S.A. All rights
reserved.