Tobit is often used because efficiencies are on a defined range 0 to 100% so least squares regression as a second stage does not make sense as the noise term can not result in values above 100 or less than 0.
However, doing the analysis in multiple stages is itself problematic.
A simple google scholar search on the terms
Tobit Regression in Second stage DEA Banks
Results in both example papers using this method on Banks and the papers explaining the potential problems.