W hen policy arrangements appear to favor well-organized and wealthy interests, should we infer "capture" of the political process? In particular, might larger firms receive regulatory "protection" even when the regulatory agency is not captured by producers? I model regulatory approval--product approval, licensing, permitting and grant making--as a repeated optimal stopping problem faced by a learning regulator subject to variable political pressure. The model is general but stylistically applied to pharmaceutical regulation. Under the assumption that consumers are differentially organized, but producers are not, there nonetheless exist two forms of "protection" for larger, older producers. First, firms submitting more applications may expect quicker and more likely approvals, even in cases where their reputations for safety are below industry average. Second, "early entrants" to an exclusive market niche (disease) receive shorter expected approval times than later entrants, even when later entrants offer known quality improvements. The findings extend to cases of bounded rationality and a reduced form of endogenous firm submissions. The model shows that even interest-neutral "consumer" regulation can generate protectionist outcomes, and that commonly adduced evidence for capture is often observationally equivalent to evidence for other models of regulation.The theory [of economic regulation] tells us to look, as precisely and carefully as we can, at who gains and who loses, and how much, when we seek to explain a regulatory policy . . . . It is of course true that the theory would be contradicted if, for a given regulatory policy, we found the group with larger benefits and lower costs of political action being dominated by another group with lesser benefits and higher cost of political action . . . .The first purpose of the empirical studies is to identify the purpose of the legislation! The announced goals of a policy are sometimes unrelated or perversely related to its actual effects, and the truly intended effects should be deduced from the actual effects.--George J. Stigler, "The Theory of Economic Regulation" (1975, 140) The prospect for any change in the [OSHA cotton dust] standard, however, is not great. Now that the large firms in the industry are in compliance, they no longer advocate changes in the regulation. Presumably, the Daniel P. Carpenter is Professor,