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A Stochastic Model of the Internal Control System
The primary purpose of incorporating a set of internal controls in the financial information system is to enhance the system's reliability-i.e., to maintain a high probability of preventing, detecting, and eliminating errors, irregularities, and fraud in the financial information system. The demonstrated reliability of the system provides evidence as to the quality of the output of the system. It is well accepted that the effectiveness of internal controls must be taken into account in determining the extent and nature of the audit procedures appropriate in a given examination.' The more reliable the system, the less extensive the tests the auditor need conduct. Recognizing this inverse relationship between effectiveness of internal control and audit scope, the American Institute of CPAs requires all auditors to initially evaluate the reliability of internal controls as a matter of audit standards.2 Recently, the Committee on Auditing Procedures of the AICPA released several statements on the subject of internal controls which re-emphasize the importance of the study of their reliability.3 But, despite this emphasis, the auditor currently does not possess a means to objectively evaluate the reliability of the internal control system. Conventionally, the auditor uses questionnaires, flow charts, and tests of transactions for evaluation pur-
The Sarbanes-Oxley Act and the Choice of Bond Market by Foreign Firms
This paper examines the economic impact of the Sarbanes-Oxley Act (SOX) by studying foreign firms? choice of whether to issue bonds in the U.S. public bond market or elsewhere before and after the law's enactment in 2002. After controlling for firm characteristics, bond features, home-country attributes, and market conditions, I find that foreign firms rely less on the U.S. public bond market after SOX. Additionally, some determinants of choosing the U.S. public bond market have changed since the passage of SOX: firms listing equities on U.S. stock exchanges, adopting International Financial Reporting Standards (IFRS), and doing large bond issuances are more likely to choose this market in the post-SOX period than in the pre-SOX period. Overall, these results are consistent with a shift in the expected costs and benefits of choosing the U.S. public bond market following SOX. This paper provides the first evidence about how SOX influences debt financing decisions and alters capital flows across international bond markets.
The Effect of Issuing Biased Earnings Forecasts on Analysts' Access to Management and Survival
This study offers evidence on the earnings forecast bias analysts use to please firm management and the associated benefits they obtain from issuing such biased forecasts in the years prior to Regulation Fair Disclosure. Analysts who issue initial optimistic earnings forecasts followed by pessimistic earnings forecasts before the earnings announcement produce more accurate earnings forecasts and are less likely to be fired by their employers. The effect of such biased earnings forecasts on forecast accuracy and firing is stronger for analysts who follow firms with heavy insider selling and hard‐to‐predict earnings. The above results hold regardless of whether a brokerage firm has investment banking business or not. These results are consistent with the hypothesis that analysts use biased earnings forecasts to curry favor with firm management in order to obtain better access to management's private information.
On the EPA's Radar: The Role of Financial Reports in Environmental Regulatory Oversight
This paper investigates the role of corporate financial reports in the Environmental Protection Agency's (EPA) regulatory activities. By tracking the EPA's direct retrieval of SEC filings, we identify three key findings. First, the EPA retrieves a large volume of financial reports, especially from firms in high‐pollution industries. Second, the EPA is more likely to access financial reports during enforcement investigations and significant rule proposals, but less so during compliance monitoring, with patterns varying predictably across firms. Third, the EPA's reliance on financial reports is potentially driven by its demand for information on firm liquidity, solvency, and profitability. Overall, our study highlights the usefulness of financial reports for the EPA as an environmental regulator.
Measuring Organizational Capital
Prior research has pointed to differences in organizational capital as a reason for the persistent performance discrepancies among otherwise similar firms. In this paper, we develop and validate a new measure of organizational capital. Based on over a million crowd‐sourced employee reviews scraped from Glassdoor, we construct the measure of organizational capital at the firm‐year level using the word embedding model and ChatGPT‐generated synthetic reviews. Our measure varies over time in accordance with macro trends, and differs both across and within firms, reflecting firm heterogeneity and major internal changes. We validate our measure by testing empirical predictions of the properties of organizational capital discussed in prior literature. Our findings suggest that this measure captures a slowly evolving intangible asset that is significantly associated with firm performance and top management's influence, aligning with the conceptualization of organizational capital by Dessein and Prat. We further showcase applications of our measure in accounting, economics, finance, and management literature. Taken together, the paper provides implications for various stakeholders who are interested in assessing and managing firms' organizational capital.
The Signaling Value of Internal Employee Coordination
We examine the effect of internal employee coordination on customer trust, focusing specifically on employees’ responsiveness to each other as an important, quantifiable, and objective aspect of internal coordination. Using proprietary data from a company with exogenous assignment of employees to teams that serve individual customers, we study how inter‐employee responsiveness influences customer trust. Each customer is served via an app‐based group chat by a randomly assigned team of employees. Our data include more than 2 million group chat messages with over 16 thousand customers. We find that inter‐employee responsiveness serves as a credible signal that helps build customer trust, as evidenced by their subsequent contracting choices. The effect is more pronounced when the signal is (1) more frequent and (2) more intense. Our findings highlight the novel value of internal employee responsiveness as a credible signal that helps build trust with external stakeholders.
The Effect of Mandatory IFRS Adoption on Financial Analysts’ Information Environment
This paper examines the effect of the mandatory adoption of International Financial Reporting Standards (IFRS) by the European Union on financial analysts’ information environment. To control for the effect of confounding concurrent events, we use a control sample of firms that had already voluntarily adopted IFRS at least two years prior to the mandatory adoption date. We find that analysts’ absolute forecast errors and forecast dispersion decrease relative to this control sample only for those mandatory IFRS adopters domiciled in countries with both strong enforcement regimes and domestic accounting standards that differ significantly from IFRS. Furthermore, for mandatory adopters domiciled in countries with both weak enforcement regimes and domestic accounting standards that differ significantly from IFRS, we find that forecast errors and dispersion decrease more for firms with stronger incentives for transparent financial reporting. These results highlight the important roles of enforcement regimes and firm‐level reporting incentives in determining the impact of mandatory IFRS adoption.
The Effect of Regulation FD on Transient Institutional Investors' Trading Behavior
We assess the impact of Regulation Fair Disclosure (Reg FD) on the trading behavior of transient institutional investors in the quarter prior to a bad news break in a string of consecutive earnings increases. Bad news breaks are defined as breaks that are by growth firms, preceded by longer strings of consecutive earnings increases, followed by longer strings of consecutive earnings decreases, and associated with larger declines in earnings. Pre–Reg FD transient institutions have abnormal selling of stocks in the quarter immediately preceding a bad news break. This abnormal selling is confined to firms that hold conference calls in the pre–Reg FD period. However, in the post–Reg FD period transient institutions do not exhibit similar abnormal selling of stocks in the quarter before a bad news break. Furthermore, after Reg FD transient institutions allocate less of their stock portfolios to conference call firms relative to non–conference call firms in the quarters prior to a bad news break. These results demonstrate that Reg FD has had an impact on management's selective disclosure behavior and significantly changed the trading behavior of transient institutions.
Conditional Earnings Conservatism and Corporate Refocusing Activities
We extend standard models of conditional earnings conservatism and adaptation value to the context of the corporate refocusing activities of UK listed companies. This analysis is interesting because refocusing activities are: (1) commonly anticipated by significant negative returns in the financial year(s) before the refocusing event; (2) typically associated with large material charges; and (3) likely to be part of a strategic plan with the internal decision preceding the formal public announcement. We complement Burgstahler and Dichev [1997] by showing how their nonlinear relation between share prices and earnings changes around refocusing events as adaptation options are exercised. Because refocusing events also involve large realized losses and major changes to firms’ strategic plans, we expect to see systematic changes in the timing relations between stock returns and reported earnings. To capture this, we show how the coefficients of Basu's [1997] model of conditional conservatism change around refocusing events.