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Reporting misstatements as revisions: An evaluation of managers' use of materiality discretion

Contemporary Accounting Research 2023 40(4), 2745-2784 open access
Abstract In recent years, firms reporting revisions of prior financial statements outnumber those reporting restatements. Misstatements that are material to prior periods are required to be reported as restatements, whereas immaterial errors can be reported as revisions. Based on SEC guidance and widely used materiality benchmarks, I find a significant percentage (29%) of revisions are suspect in that they meet at least one materiality criterion. These suspect revisions are 15% to 29% more likely to be reported when managers have a strong incentive to avoid restatements—when they face the threat of a compensation clawback for reporting a restatement. This result is especially salient when the clawback policy does not require misconduct for recoupment and when the error correction significantly reduces prior period net income. Overall, this evidence suggests that some managers use materiality discretion opportunistically to report misstatements as revisions instead of restatements.

Does Financial Statement Comparability Facilitate SEC Oversight?*

Contemporary Accounting Research 2023 40(2), 1315-1349
ABSTRACT This study examines the impact of cross‐firm financial statement comparability on regulatory oversight of accounting quality. Required to review each firm's periodic filings at least once every three years, the SEC learns about the degree to which a firm's accounting system is comparable to those of its peers. We posit that the SEC's ex ante knowledge about financial statement comparability, gleaned from prior‐year filing reviews, facilitates its evaluation of firms' accounting quality during the current‐year filing review. Consistent with the notion that comparable accounting systems enhance regulators' ability to identify discretionary accounting deviations, we find that the likelihood of the SEC issuing a comment letter for higher abnormal accruals increases with financial statement comparability. Further analysis reveals that the regulatory benefits from higher financial statement comparability are more salient when the SEC faces higher monitoring constraints in filing reviews. Moreover, our finding shows that comparable accounting numbers across firms help the SEC detect severe accounting violations that necessitate restatements. Overall, we provide novel evidence suggesting that higher financial statement comparability improves the efficacy of the SEC's oversight of accounting quality by reducing the information costs associated with cross‐firm comparisons.