I explore the use of field data in conjunction with archival evidence by examining Iliev, Miller, and Roth's (2014) analysis of an amendment to the Securities Exchange Act of 1934. This regulatory amendment allowed depositary banks to cross-list firms without the cooperation of foreign issuers. Iliev, Miller, and Roth (2014) argue that the regulation failed to fulfill its intended purpose and imposed significant costs on foreign firms for the benefit of depositary banks. Drawing on evidence from lawyers, issuers, depositary banks, and regulators involved in the design and implementation of the amendment, I describe a more optimistic assessment of the amendment and its effects on capital markets. I conclude by discussing opportunities for field data in financial reporting and disclosure research.
