PROFESSOR SARAH WILLIAMS’S RESEARCH ON THE ROLE OF ENFORCEMENT AT THE SEC AND THE PCAOB HAS BEEN PUBLISHED BY ST. JOHN’S LAW REVIEW

St. John's Law ReviewMarch 2025 — Professor Sarah Williams’s article, “Regulatory Personhood: The Elixir for Redundancy Between the SEC and the PCAOB,” is now in print.

“Regulatory Personhood” evaluates criticisms levied over the course the existence of the Public Company Accounting Oversight Board that the agency was redundant of the Securities and Exchange Commission. It is Professor Williams’s second article on the oversight of public company auditors in the U.S. Her first article, “The Alchemy of Effective Auditor Oversight,” published in 2022, analyzed the effectiveness of the manner in which the PCAOB secures jurisdiction over public company auditors. “Regulatory Personhood” explores the shared enforcement authority of the SEC and the PCAOB. It finds that the overlapping enforcement authority of the two agencies is complementary, and not redundant. It attributes this symbiosis to regulatory personhood, which gives the SEC a proprietary interest in only a narrow subset of cases that are within the purview of both agencies.


Professor Sarah Williams is an Associate Professor at Penn State Dickinson Law. Prior to joining Dickinson Law, Professor Williams practiced law as a securities regulator. She was Deputy Director at the Public Company Accounting Oversight Board, Associate General Counsel at NASD (now FINRA), and spent several years as a lawyer at the U.S. Securities and Exchange Commission. Professor Williams began her legal career as an associate at Arnold & Porter in Washington, D.C.