We test conjectures about the determinants of materiality judgments by examining a financial reporting choice made by firms that discover errors in prior years' financial statements. From late 2004 to mid-2006, more than 250 U.S. firms uncovered and corrected operating lease accounting errors either by formal restatement—required for errors deemed material—or by a less visible current-period “catch-up” adjustment. We test the role of materiality considerations outlined in SAB No. 99 as well as factors outside authoritative guidance in explaining the correction method chosen. Although both quantitative and qualitative materiality considerations cited in the guidance explain a large portion of the variation in firms' error correction decisions, we find that the prior actions of other firms also appear to play a major role. We also find that clerical considerations, but not strategic disclosure concerns, help explain cross-sectional variation in the timing of firms' error correction announcements.
We investigate the effects of PCAOB inspections on the relationships between Big 4 auditors and their clients using a new measure to capture the information garnered from the reports. Specifically, we measure the relative importance of accounting standards to each client's financial statements and calculate the exposure to deficient auditing by relating their auditor's inspection deficiencies to the accounting standards. This measure of deficient auditing exposure is then adjusted by the exposure that would occur for the average of the other Big 4 auditors. We find that our measure of relative exposure to deficient auditing is positively related to auditor changes, but is not related to audit changes in audit fees. These results suggest PCAOB inspections affect auditor-client relationships, but auditors do not have the ability to increase fees to remediate deficient auditing, nor do they reduce fees to retain clients when they have more deficiencies in areas important to the clients. Our findings have implications for understanding and regulating the market for audit services.
We gain unique insights into materiality judgments about accounting errors by examining SEC comment letter correspondence. We document that managers typically use multiple quantitative benchmarks in their materiality analyses, with earnings being the most common benchmark. In most of the cases we review, managers deem the error immaterial despite its exceeding the traditional “5 percent of earnings” rule of thumb, often in multiple periods and by a large degree. Instead of attempting to conceal these overages, managers tend to forthrightly acknowledge them, often asserting that the benchmark is abnormally low during the violation period. We find that 17–26 percent of these “low benchmark” assertions are suspect (although none of these “low benchmark” assertions are challenged by the SEC). We also document substantial variation in the extent to which qualitative factors are mentioned as considerations. The SEC generally is deferential toward managers' arguments and judgments but is more likely to challenge immateriality claims when managers admit there are qualitative factors that indicate errors are material.
We investigate whether a firm’s market power within its product market affects management sales forecast behavior. Our examination of the relation between market power and management sales forecasts is motivated by the notion that sales forecasts differ from other types of forecasts because sales forecasts provide investors and competitors with a more transparent signal of a firm’s short-term demand expectations and its immediate actions in the product market than other forecasts. Thus, we first provide evidence consistent with sales forecasts containing unique information about future sales and evidence consistent with this information being related to competitor pricing and output decisions. We then find evidence that higher market power, proxied by excess margin, is associated with a higher likelihood of issuing sales forecasts after controlling for industry-level competition effects and earnings forecast behavior. Overall, our findings are consistent with higher-market-power firms being more willing to publicly disclose sales forecast information.
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