BUSINESS STRATEGY AND INTERNAL CONTROL OVER FINANCIAL REPORTING* KATHLEEN A. BENTLEY-GOODE, The University of New South Wales NATHAN J. NEWTON, The University of Missouri-Columbia ANNE M. THOMPSON, The University of Illinois at Urbana-Champaign March 2015 * We thank Michael Drake, Karla Johnstone, Phil Lamoreaux, Elaine Mauldin, Thomas Omer, Mark Peecher, and participants at the 2014 AAA Annual Meeting for helpful comments. We are grateful to the University of Illinois at Urbana-Champaign, University of Missouri-Columbia, and University of New South Wales for financial support. BUSINESS STRATEGY AND INTERNAL CONTROL OVER FINANCIAL REPORTING ABSTRACT: This study examines whether a firm’s business strategy is an underlying determinant of the quality of its internal control over financial reporting (ICFR). Organizational theory suggests that firms following an innovative “prospector” strategy are likely to have weaker internal controls than firms following an efficient “defender” strategy. We find that business strategy is a significant predictor of material weaknesses, incremental to known determinants of material weaknesses. We also find that relative to defenders, prospectors are less likely to remediate or disclose material weaknesses on a timely basis. Finally, we find that guidance in AS No. 5 instructing auditors to take a risk-based approach to ICFR evaluation improved auditors’ ability to link business strategy risks to internal control deficiencies by improving the timeliness with which material weaknesses are reported. Our results indicate that prospectors are riskier audit clients and suggest that business strategy is a useful summary indicator for evaluating firms’ internal control strength. Keywords: business strategy; internal control; material weakness; Sarbanes-Oxley; Auditing Standard No. 5 Data availability: Data are obtained from public sources as indicated in the text. BUSINESS STRATEGY AND INTERNAL CONTROL OVER FINANCIAL REPORTING I. INTRODUCTION Using organizational theory, we predict that the type of business strategy that a firm follows serves as an underlying determinant of the quality of the firm’s internal control over financial reporting (ICFR).1 The Sarbanes-Oxley Act of 2002 requires management to annually review and report on the effectiveness of the company’s ICFR and requires auditors to attest to the effectiveness of ICFR for large U.S. listed firms. Understanding why some firms have ineffective controls, known as material weaknesses, is important to stakeholders because material weaknesses are associated with lower quality accruals (Doyle, Ge, and McVay 2007a; Ashbaugh-Skaife, Collins, Kinney, and LaFond 2008), adverse market reactions (Gupta and Nayar 2007; Beneish, Billings, and Hodder 2008; Hammersley, Myers, and Shakespeare 2008), and greater debt and equity costs (Ashbaugh-Skaife, Collins, Kinney, and LaFond 2009; Dhaliwal, Hogan, Trezevant, and Wilkins 2011; Kim, Song, and Zhang 2011).2 Kinney (2000, 88) indicates that the largest obstacle academics face in the area of internal control quality and quality assurance is “our own limited knowledge...of business strategy and organization design, management processes, risk, and risk management.” Recent research finds that firms following a particular business strategy experience higher likelihoods of restatements and litigation despite higher audit fees (Bentley, Omer, Sharp 2013), which the authors suggest is due to auditors insufficiently identifying client business risks. We propose a complimentary explanation for their results, namely, that firms following certain business strategies maintain weaker ICFR and that auditors do not assess control risk 1 Strategy is a broad concept where a firm's strategy can be distinguished in at least two levels: business- and corporate-level strategies. Business-level strategy involves determining how the company expects to compete within a given industry whereas corporate-level strategy involves determining in which area of business the firm should be involved and is the source of strategy variation between industries (Beard and Dess 1981; Hambrick 1983; Dent 1990; Bruggeman and Van der Stede 1993). Our study focuses on business-level strategy. 2 Refer to Schneider, Gramling, Hermanson, and Ye (2009) for a literature review. 1 appropriately for these clients. From an audit quality standpoint, incorporating business strategy into the study of reported material weaknesses and identifying settings in which auditors are less likely to assess control risk appropriately can potentially improve the quality of auditors’ risk assessments and ultimately the quality of the audit report. In addition, because business strategy is visible to outsiders, documenting the association between business strategy and internal control environments provides useful insights to stakeholders, auditors, and regulators for understanding which firms are more likely to have weaker internal controls, particularly among firms exempt from internal control attestation requirements.3 Organizational theory indicates that firms within industries follow different strategies and that these strategies are observable based on firm-level characteristics. For example, innovative “prospector” firms (e.g., first-to-market firms) are frequently evolving to focus on new product-market opportunities, resulting in rapid growth, firm complexity, internal control modifications, and profit volatility (Miles and Snow 1978, 2003; Hambrick 1983; Simons 1987). Conversely, organizational theory suggests that firms following an efficiencyoriented “defender” strategy (e.g., cost-leadership firms) focus on producing a stable set of products and exhibit more stable growth patterns within existing product lines (Miles and Snow 1978, 2003; Hambrick 1983). Defender firms are associated with firm-level characteristics opposite to those of prospectors: gradual growth, less complexity and more consistent profitability.4 3 The use of an externally visible signal of internal control quality would be particularly useful for investors, analysts, and other stakeholders of informationally opaque issuers that are exempt from Sarbanes-Oxley 404(b) such as small filers and recent IPOs. Stakeholders could consider business strategy in assessing the reliability of management’s assertions in the financial statements, earnings forecasts, and other communications, particularly among firms that are likely to have weaker internal controls. 4 The Miles and Snow typology includes a third viable strategy, which is a hybrid strategy consisting of elements of both prospectors and defenders. We follow prior accounting research (e.g., Simons 1987, Ittner, Larcker, and Rajan 1997; Bentley et al. 2013) in focusing our discussion on the two distinct strategies at the endpoints of the strategy continuum (prospectors and defenders) as these firms are most easily distinguished based on organizational attributes. 2 Organizational theory proposes that prospector firms are likely to have weaker internal controls than defender firms, but there are several reasons that empirical data may not support this prediction. First, prior studies in organizational management and managerial accounting provide mixed evidence on the association between business strategy and internal controls (e.g., Simons 1987; Dent 1990; Langfield-Smith 1997; Agbejule and Jokipii 2009). Second, although prior studies link material weaknesses to some firm-level characteristics of business strategy, such as growth or complexity attributes, (Ge and McVay 2005; Doyle et al. 2007b), the effect of business strategy may be subsumed by these other determinants of ICFR deficiencies. Furthermore, because public companies are expected to maintain effective ICFR under both the Sarbanes-Oxley Act and the Foreign Corrupt Practices Act, the theoretical association between business strategy and internal control may not extend to ICFR due to federal regulations. Finally, Bentley et al. (2013) find that restatements and litigation are more likely among prospector firms. Because financial restatements often imply weaknesses in ICFR (Kinney and McDaniel 1989, Auditing Standard No. 5), their study suggests an association between business strategy and ICFR. However, Bentley et al. (2013) attribute their findings to client business risk (CBR) rather than to financial reporting risk. Business risk auditing proposes that CBR and financial reporting risk are closely linked because auditors must gain a sufficient understanding of CBR in order to assess inherent risk and control risk appropriately (Bell, Mars, Solomon, and Thomas 1997; Bell, Peecher, and Solomon 2002; Knechel 2007). Thus, an auditor’s failure to gain a sufficient understanding of CBR could indicate a failure to assess control risk appropriately, leading to increased likelihoods of both undetected internal control deficiencies and restatements. However, CBR encompasses risks external to the organization as well as risks embedded in the client’s core business processes that are not addressed by ICFR. As Bell et al. (1997, 64) note, “…for the auditor to judge 3 effectively whether accounting estimates and valuations reflect the proper levels of uncontrolled business risk, he must look outside of the accounting system to the actual sources of risks, and the processes in place to control them.” Thus, the increased risk of restatements and litigation documented by Bentley et al. (2013) could be attributable to uncontrolled business process risks rather than weaknesses in the accounting system and ICFR controls. We use the archival measure of business strategy developed by Bentley et al. (2013) to investigate the relationship between business strategy and occurrences of internal control weaknesses. First, we examine the role of business strategy on the probability of disclosing a material weakness, incremental to known determinants of internal control weaknesses from prior literature (e.g., Doyle et al. 2007b). Next, we examine whether business strategy is associated with the number of material weaknesses reported as well as the remediation of reported material weaknesses. We find that firms following a prospector strategy are significantly more likely to report material weaknesses and are less likely to remediate material weaknesses than firms following a defender strategy. Next, we perform two tests that explore the association between business strategy and reported material weaknesses from an audit perspective. First, we examine the timeliness of firms’ material weaknesses reporting by adapting the framework in Rice and Weber (2012) where material weaknesses reported in conjunction with a restatement are considered to be untimely relative to material weaknesses reported in the absence of a restatement, which are considered to be timely. Timely material weaknesses imply that management and/or the auditor’s controls and substantive tests detected the material weakness prior to issuing the audit report. In contrast, untimely material weaknesses imply that management and/or the auditor failed to detect or report a material weakness in a prior period and that the material weakness was not detected until the internal control system failed to prevent a material 4 misstatement in the financial statements.5 This test is also important for understanding the role of business strategy in the audit process because prospector firms need to modify their control systems more often than firms following other strategies, which may increase auditors’ difficulty in identifying or assessing the severity of internal control deficiencies. We find that firms following a prospector strategy are significantly more likely to report both timely and untimely material weaknesses relative to defender firms, which implies both that prospector firms have weaker controls than defender firms and that managers and auditors have greater difficulty detecting and/or reporting deficiencies in ICFR among prospector clients. Finally, we examine whether the relationship between business strategy and reported material weaknesses differs during the sample period due to changes in auditing standards governing auditors’ attestation of ICFR. In contrast to Auditing Standard No. 2 (AS No. 2), which was effective in the early years of the sample, Auditing Standard No. 5 (AS No. 5) (effective for audits after November 15, 2007) directs auditors to adopt a “top down, risk based” approach to evaluating ICFR. Because a firm’s business strategy is a key input to the auditor’s risk assessment (AICPA 2006; IFAC 2009; Bentley et al. 2013), it is possible that AS No. 5 strengthened the association between business strategy and reported material weaknesses or improved the timeliness with which auditors detect material weaknesses. However, if auditors exert insufficient effort to understand CBR for prospector clients as implied by Bentley et al. (2013), AS No. 5 may have no effect on the association between strategy and reported material weaknesses. While we find a strong association between business strategy and material weaknesses in both the AS No. 2 and AS No. 5 periods, we find that the association in the AS No 2 period is driven by untimely material weaknesses announced in conjunction with a restatement whereas in the AS No. 5 period, business 5 Under current U.S. auditing standards, auditors do not include internal control deficiencies judged to be less severe than a material weakness in their audit reports. 5 strategy is associated only with timely material weaknesses. Thus, the top-down risk based approach to evaluating internal controls appears to have improved auditors’ detection of material weaknesses among riskier prospector clients. We make several contributions to the literature. First, by linking organizational theory to the accounting literature, we provide a theoretical framework for understanding findings from prior studies and illustrating why business strategy is an underlying determinant of firms’ control systems. We also contribute to the newly developing research that suggests that firms following a prospector strategy are riskier audit clients. From a conceptual and practice standpoint, our paper provides a significant contribution beyond Bentley et al. (2013) by identifying internal controls as an area of heightened risk for prospector firms and control risk assessment as a specific area for audit quality improvement for prospector audit clients. Third, our results showing that the relationship between business strategy and the timeliness of material weakness reporting is different in the pre- versus post-AS No. 5 periods suggest that the top-down, risk-based approach to auditing internal controls in the post-AS No. 5 period improved audit quality surrounding internal controls for certain riskier clients. Finally, this study provides useful information to outside parties who rely on internal control reports for decision making. Because a firm’s business strategy, such as a focus on innovation versus cost leadership, is observable to outsiders, it is likely easier for stakeholders to assess the probable strength of a firm’s internal controls based on business strategy than by evaluating the individual determinants of material weaknesses documented in the prior literature. This observation may be useful for regulators planning risk-based inspections and is particularly salient for stakeholders in firms that are exempt from ICFR attestation requirements (e.g., non-accelerated filers and recent IPOs) that are often characterized by relatively weaker information environments and greater information asymmetry. 6 The rest of our paper is organized as follows. Section 2 provides the literature review and our hypothesis development. Section 3 details our research design. Section 4 describes our descriptive data and empirical results. Section 5 presents our additional analyses. Section 6 concludes. II. LITERATURE REVIEW AND HYPOTHESIS DEVELOPMENT Management Control Systems and Strategy Prior research identifies a firm’s business strategy as an important component of the management control system (e.g., Simons 1987; Dent 1990; Langsfield-Smith 1997; Henri 2006). A significant body of accounting and organizational management research investigates the relationship between management control systems and strategy.6 Management control systems encompass accounting-based controls systems for planning and monitoring, and strategic and operational control elements (Langsfield-Smith 1997). Prior research examining elements of accounting control systems focuses on the business strategy of the firm (Dent 1990; Langfield-Smith 1997). Strategic organizational theory indicates that “the organization’s control system should be congruent with its strategy” (Agbejule and Jokipii 2009, 502), and early accounting studies concluded that a firm’s business strategy should be one of the primary components in the design of an accounting control system (e.g., Dermer 1977; Otley 1980; Simons 1987). Strategy theorists (e.g., Miles and Snow 1978, 2003; Miller and Friesen 1978; Porter 1980) hypothesize that control systems vary among firms depending on the strategy of the firm. Miles and Snow (1978, 2003) hypothesize that the control structures of firms following an entrepreneurial/innovation-oriented strategy (“prospectors”) are generally decentralized and flexible to adapt quickly to changing market conditions. For example, Miles and Snow suggest that controls within prospector firms are focused more on external scanning activities 6 Refer to Dent (1990) and Langsfield-Smith (1997) for comprehensive literature reviews. 7 to locate new market opportunities. The highly decentralized organizational form allows prospectors to encourage “risk taking” and “creativity” in managerial decision-making, thus enabling their strategic pursuit of new product/market opportunities (Joyce and Slocum 1990, 141). Firms with decentralized structure employ “little formal control over member behaviors. . . [where] [c]ontrol systems monitor outputs and not behaviors” (Joyce and Slocum 1990, 142). Thus, Simons (1987) predicts that prospectors will “de-emphasize accounting controls in general, placing greater emphasis on fostering individual creativity and innovation” (360). In contrast, the control structures of firms following a cost/efficiency-oriented strategy (“defenders”) are generally centralized and rigid in order to maximize efficiency (Miles and Snow 1978, 2003; Porter 1980). Miles and Snow suggest that controls within defender firms are focused more on activities related to cost control and monitoring than on activities to identify new business opportunities (Simons 1987). In addition, defender firms employ the “extensive use of rules and standard operating procedures [to] ensure that individuals from different functional areas are exposed to similar work practices and procedures . . . [resulting in] highly effective internalized set of controls” (Joyce and Slocum 1990, 139). For these reasons, Simons (1987) predicts that defenders will “place heavier reliance on formal accounting procedures, especially those directed to cost control” (360). While there are numerous strategy taxonomies, we focus on the Miles and Snow (1978, 2003) typology throughout this paper because it “provides the richest portrayal of organizational arrangement associated with particular strategies” (Dent 1990, 10-11) and also because of its “comprehensiveness” (Zahra and Pearce 1990, 753).7 The Miles and Snow (1978, 2003) typology is based on the rate of change that a firm alters its product-market mix. Three viable strategies emerge within a particular industry (Miles and Snow 1978, 2003; 7 Refer to Bentley et al. (2013, 782-783) for an in-depth discussion of how the Miles and Snow (1978) typology aligns with other commonly used strategy typologies (e.g., Miller and Friesen 1982; Porter 1980). 8 Hambrick 1983). Firms at one end of the strategy continuum frequently/rapidly change their product mix (prospectors) while firms at the other end rarely/gradually change their product mix (defenders).8, 9 Miles and Snow (1978, 2003) identify a third type of viable business strategy within a particular industry, which is known as “analyzers.” Analyzers (occupying the middle of the strategy continuum) are neither as solely innovation-oriented as prospectors nor as efficiency-driven as defenders and compete on the basis of a hybrid strategy—i.e., they focus on efficiency in some divisions and innovation in others. The empirical strategy-control literature typically examines the extreme strategies of prospectors and defenders (Fisher 1995), which we follow as well in our hypothesis development.10 Although organizational theory proposes that control systems differ between firms following different business strategies, limited empirical evidence supports these conjectures. While some studies report results consistent with the link between organizational theory and firm control systems (Miller and Friesen 1982; Govindarajan 1986; Bruggeman and Van der Steede 1993), other studies indicate mixed support (Simons 1987; Agbejule and Jokipii 2009). Thus, Langfield-Smith (1997, 207) concludes that “our knowledge of the relationship between [management control systems] and strategy is limited, providing considerable scope for further research.” Similarly, in providing an overview of the strategy and organizational 8 Refer to Miles and Snow (1994) for strategy classification examples. For example, within the microprocessor industry, Intel is classified as a prospector because this firm is a “leader in product innovation” while National Semiconductor is classified as a defender because this firm “focus[es] narrowly on efficient chip production” (Miles and Snow 1994, 14). 9 Business strategy is the process of aligning the firm to its market, where firms find “a way to respond to or help shape current and future customer needs . . . . Over time, successful firms relate to the market and the broader environment with a consistent approach that builds on their unique competencies and sets them apart from their peers” (Miles and Snow 1994, 12). Each type of business strategy has relative advantages and disadvantages and no one strategy is necessarily ideal. For prospectors, their primary advantage is market innovation while their primary disadvantage is a tendency to overextend resources and hence risk lower profitability. For defenders, their primary advantage is efficiency and stability while their primary disadvantage is the risk of obsolescence due their inability to rapidly respond to market shifts. Refer to Miles and Snow (1978, 2003) for further description. 10 Consistent with organizational theory predictions that prospectors and defenders are equally viable strategies across industries, Bentley et al. (2013) show that both strategies exist within each industry and at various investment opportunity set (IOS) levels “including industries where the IOS is the highest.” Refer to the descriptive statistics for industry distribution details by strategy. 9 control literature concerning accounting control system design, Dent (1990, 21) concludes that “[r]esearch at the interface between accounting and strategy is, as yet, undeveloped,” especially in the area of control systems. Further, while strategic management studies exploring the linkage between a firm’s control system design and its strategy suggest that organizational structure is contingent upon contextual factors such as firm size, environment, and technology (e.g., Gordon and Miller 1976; Merchant 1981, 1984, 1985; Govindarajan and Gupta 1985), Dent’s (1990, 10) literature review concludes that “the relationships are weak and the conclusions fragmentary.” Dent (1990, 10) calls specifically for more research “exploring relationships between organizations’ strategies and their control systems, recognizing strategic posture as an important variable in the contingency framework.” We extend the work in this area by investigating whether firms’ business strategies are an underlying source of differences in reported internal control weaknesses over financial reporting, as attested to by external auditors. Hypothesis Development Section 404(a) of the Sarbanes-Oxley Act (SOX) requires that management annually review and report on the effectiveness of their company’s internal controls and Section 404(b) requires that auditors attest to the effectiveness of internal controls over financial reporting (effective November 15, 2004 for accelerated filers) (SEC 2002). Companies must disclose “material weaknesses” in ICFR and are not required to disclose less severe internal control weaknesses (SEC 2003, 2004).11 Due to the material weakness disclosure requirements under SOX, several recent studies have examined firm-level determinants of material weaknesses (e.g., Ge and McVay 2005; Doyle et al. 2007b). 11 Refer to Ge and McVay (2005) and Doyle et al. (2007b) for a thorough discussion of the differences between significant deficiencies and material weaknesses in internal controls. We follow Doyle et al. (2007b) in focusing on the mandated reporting on material weaknesses rather than the more voluntary significant deficiencies. 10 We first investigate whether business strategy is associated with the likelihood of disclosing material weaknesses in ICFR. There are two primary reasons to expect a positive association between business strategy and material weaknesses. First, organizational theory predicts a theoretical link between business strategy and internal control as discussed previously. Second, many of the firm-level attributes that are empirically linked to material weaknesses in ICFR such as rapid growth, complexity, and profit variability are characteristics of firms following an innovative prospector strategy. For example, rapid growth and acquisitions or restructuring activities are associated with a higher likelihood of internal control deficiencies (Ashbaugh-Skaife, Collins, and Kinney 2007; Doyle et al. 2007b). Likewise, firms with more stable operations are less likely to quickly outgrow their control structure compared to rapidly growing firms (Doyle et al. 2007b). Prospector firms are typically associated with more rapid and sporadic growth due to their continual pursuit of new product-market opportunities in different domains as compared to their industry counterparts. Conversely, defender firms are associated with stable growth patterns due to narrowly-focused product-market areas where growth tends to occur within existing product lines versus across product lines into new areas (Miles and Snow 1978, 2003). Prior accounting research also finds that firm complexity is associated with material weaknesses and/or internal control deficiencies (Ge and McVay 2005; Ashbaugh-Skaife et al. 2007; Doyle et al. 2007b). Miles and Snow (1978, 2003) predict that prospectors maintain decentralized control to help facilitate their diverse and numerous operations which are structured across product groups, resulting in greater complexity within their organizational structure. Further, prospectors must be adept to quickly adapting to changing market conditions to maintain their market-leadership position, and this results in greater complexity (Miles and Snow 1978, 2003). Consistent with these predictions, Simons (1987) finds that prospectors modify their internal control systems much more frequently than defenders, and 11 Hambrick (1983, 23) finds that prospectors have “more flexible, labor intensive capacity configurations” compared to defenders, which have much more structured automated capital configurations. In relation to financial performance, prior accounting research finds that financially weaker firms are more likely to encounter material weaknesses and/or disclose internal control deficiencies (Ge and McVay 2005; Ashbaugh-Skaife et al. 2007; Doyle et al. 2007b; Rice and Weber 2012). Prospectors risk lower profitability or reporting losses more frequently compared to industry peers because they overextend their financial resources in pursuit of riskier opportunities (Miles and Snow 1978, 2003). Conversely, defenders focus heavily on cost reduction as their strategic advantage and thus are less likely to encounter losses or overextend their resources. Prior research confirms that prospectors experience lower profitability and financial distress more frequently than defenders (Hambrick 1983; Ittner et al. 1997; Bentley et al. 2013). In summary, prior accounting research documents that many characteristics of business strategy are associated with ICFR deficiencies, suggesting empirical support for an association between strategy and material weaknesses in ICFR. However, there are several reasons why the empirical data may not support this prediction. First, prior studies in management and managerial accounting provide mixed evidence on the association between business strategy and internal controls (e.g., Simons 1987; Dent 1990; Langfield-Smith 1997; Agbejule and Jokipii 2009). Second, although prior studies link material weaknesses to some firm-level characteristics of business strategy, such as growth or complexity attributes, (Ge and McVay 2005; Doyle et al. 2007b), the effect of business strategy may be subsumed by these other determinants of ICFR deficiencies. Furthermore, because public companies are expected to maintain effective ICFR under both the Sarbanes-Oxley Act and the Foreign Corrupt Practices Act, the theoretical association between business strategy and internal control may not extend to ICFR due to federal 12 regulations. Ultimately, whether business strategy is associated with reported internal control weaknesses over financial reporting is an empirical question, so we state Hypothesis 1a in the null form. H1a: There is no association between business strategy and the likelihood of reported material weaknesses in ICFR Remediation of prior deficiencies can improve financial reporting quality and help restore investor confidence (Ashbaugh-Skaife et al. 2008; Goh 2009). However, despite the benefits of remediation, “management may not be willing to invest time and resources in remediating these deficiencies because such efforts divert attention and resources from the core businesses” (Goh 2009, 550). Prior research finds that firms are less likely to remediate material weaknesses (or less likely to remediate material weaknesses in a timely manner) when they report greater numbers of deficiencies and when they exhibit lower profitability and more complex operations (Goh 2009; Johnstone, Li, and Rupley 2011), which are characteristics of prospector firms (e.g., Miles and Snow 1978, 2003; Hambrick 1983). Further, because prospector firms need to change their control systems more frequently (Simons 1987), management may be less likely to remediate deficiencies in evolving or outdated processes. For these reasons, we also examine the association between business strategy and the likelihood of remediating reported deficiencies. We state Hypothesis 1b in the null form: H1b: There is no association between business strategy and the likelihood of remediating reported material weaknesses in ICFR. Next, Bentley et al. (2013) conclude that prospector firms have higher likelihoods of restatements and litigation due to higher client business risk (CBR) rather than financial reporting risk. They also find that auditors increase their effort for prospector firms but that the incremental effort is insufficient to addresses this risk. We propose that weaker internal controls and inappropriate control risk assessment among prospector clients provides a 13 complimentary explanation for these findings. Under current U.S. auditing standards, auditors assess the client’s inherent and control risk as inputs to the nature, timing, and extent of planned audit procedures. If the auditor assesses one of these inputs inappropriately, the planned audit procedures may not reduce audit risk to an acceptably low level, leading to an increased likelihood of restatement. Because a strong understanding of the client’s business risk is a key input to the auditor’s control risk assessment (Bell et al. 1997; Bell et al. 2002), Bentley et al.’s (2013) findings imply that auditors’ control risk assessments for prospector clients may be inadequate due to an insufficient understanding of CBR. If this is the case, then prospector clients should have higher likelihoods of undetected or unreported control deficiencies in a given year which could later manifest as the restatements documented by Bentley et al. (2013). However, CBR also encompasses risks external to the financial reporting process such that auditors could obtain a strong understanding of the client’s accounting information system while simultaneously obtaining an inadequate understanding of CBR. As Bell et al. (1997, 64) note: “Without looking outside of [the client’s accounting system,] it is difficult for the auditor to learn whether it processes all business activities and measures them giving due consideration to all relevant business risks.” Because it is unclear whether the failure to assess CBR appropriately for prospector clients leads to inappropriate control risk assessment, and therefore undetected or unreported control deficiencies, we pose Hypothesis 2 in the null form. H2: There is no association between business strategy and the likelihood of undetected or unreported control deficiencies. Our final hypothesis examines the effect of Auditing Standard No. 5 (AS No. 5) in 2007 on the association between business strategy and ICFR deficiencies. AS No.5 adopts a “top-down,” risk-based approach to internal control audits (PCAOB 2007; Doogar, 14 Sivadasan, and Solomon 2010). This principles-based approach to ICFR audits superseded the more prescriptive “bottom-up” guidance offered under Auditing Standard No. 2 (AS No. 2) (PCAOB 2004, 2007). Under AS No. 5, auditors are encouraged to use risk-assessments to guide ICFR audits and to scale ICFR audits to client size and complexity because “the size and complexity of the company, its business processes, and business units, may affect the way in which the company achieves many of its control objectives” (PCAOB 2007, AS 5.13). Unlike the “one-size-fits-all” approach of AS No. 2, AS No. 5 allows for more variation in audit approaches across clients, permits auditors to direct their attention towards higher risk areas, and gives more room for auditors’ professional judgment (PCAOB 2007; Jiang and Wu 2009; Doogar et al. 2010). As discussed in the previous section, business strategy is a contributing factor toward a firm’s control structure and overall business risk. Hence, following AS No. 5, auditors may alter control testing efforts depending on the client’s business strategy. If auditors are responsive to AS No. 5, business strategy should influence their control risk assessments because standards now permit a risk-based approach to evaluating ICFR. Thus, under AS No. 5, auditors may be more likely to detect and/or report material weaknesses for prospector audit clients, while control risk assessments for the less risky defender clients are likely to remain unchanged or be scaled back. However, the results in Bentley et al. (2013) suggest that auditors do not fully account for risky business strategy in their audits, so AS No. 5 may have no effect on the association between strategy and reported material weaknesses. Ultimately, whether AS No. 5 improved auditors’ ability to use a risk-based approach to identify material weaknesses is an empirical question, so we state our hypothesis in the null form. H3: The association between business strategy and reported material weaknesses is no different in the pre- and post-AS No. 5 periods. 15 III. RESEARCH DESIGN Sample Selection To construct our sample, we identify 41,513 internal control opinions in Audit Analytics over the period 2004-2011. We eliminate 10,329 observations missing data in Compustat, CRSP, and Audit Analytics to calculate our control variables and 12,617 observations missing data to calculate the strategy variable. We exclude 1,069 Section 302 opinions where the firm reported a material weakness or significant deficiency but did not report a material weakness under Section 404. Finally, we exclude 3,844 observations associated with firms claiming an exemption from SOX Section 404 in the current year. Our final sample consists of 13,654 observations. The sample selection is presented in Table 1. [Insert Table 1 here] Multivariate Model Strategy Measure We follow Bentley et al. (2013) in measuring a firm’s business strategy based on Miles and Snow’s (1978, 2003) business strategy typology. The Bentley et al. (2013) archival strategy measure extends Ittner et al.’s (1997) strategy measure and uses six ratios to capture the different dimensions of business strategy. These six ratios are: (1) research and development expense to sales (captures new product development), (2) selling, general and administrative expenses to sales (captures marketing efforts), (3) annual percentage change in sales (captures growth patterns), (4) employees to sales (captures production efficiency), (5) net property, plant and equipment to total assets (captures capital structure), and (6) standard deviation of total number of firm employees (captures organizational stability). Following prior research (e.g., Ittner et al. 1997; Bentley et al. 2013), we compute these measures using the rolling five-year average and rank these measures into quintiles for each firm-year relative to other firms in the same industry. 16 Once all the six measures are ranked into quintiles, the quintile rank scores are summed across each firm-year such that firms could receive a maximum score of 30 (where the firm ranked in the top industry-quintile across all six measures) and a minimum score of 6 (where the firm ranked in the bottom industry-quintile across all six measures). Firms with higher (lower) STRATEGY scores represent Prospector (Defender) firms. For instance, firms with higher STRATEGY scores have more new product development, marketing and growth activities, lower efficiency (i.e., a greater ratio of employees to sales and lower capital intensity), and less organizational stability (i.e., greater fluctuations in total employees) relative to industry competitors, which is characteristic of prospector firms.12 We interpret a positive (negative) coefficient on STRATEGY to mean that firms with characteristics most consistent with a prospector strategy are positively (negatively) associated with the dependent variable of interest. However, for ease of exposition, we discuss STRATEGY in terms of prospector firms relative to defender firms. The STRATEGY measure has been validated using both archival (Bentley et al., 2013) and survey methods (Bentley, 2013).13 Regression Model To test H1a, we estimate a logistic regression model predicting internal control material weaknesses based on the models in Doyle et al. (2007b). The dependent variable in this model equals one if the firm receives an adverse audit report concerning ICFR under Section 404 of the Sarbanes-Oxley Act during year t and equals zero if the firm receives an 12 The capital intensity measure is reverse-coded “so that observations in the lowest (higher) quintile are given a score of 5 (1)” (Bentley et al. 2013, 810). Bentley et al. (2013) provide more detail of how STRATEGY aligns with firms following Prospector or Defender strategies in their Appendices 2 and 3. 13 For example, Bentley et al. (2013) perform factor analysis and find that all six STRATEGY components load on a single factor. This finding suggests that the six ratios capture one underlying construct. Bentley et al. (2013) also use canonical correlation analysis and redundancy index tests to find that STRATEGY is a different construct than complexity and risk. Finally, Bentley (2013) concludes that firms following a Prospector or Defender strategy are properly classified using survey responses from senior executives in management and marketing positions to compare firms to the STRATEGY measure. 17 unqualified audit report on ICFR (MW).14 Firms that do not report on ICFR under Section 404 of the Sarbanes-Oxley act are excluded from the sample by construction. The independent variable of interest is STRATEGY as discussed previously. We estimate Model 1 as follows: (1) We also test H1a using an alternative dependent variable (MW_COUNT) where the dependent variable equals the number of material weaknesses reported during year t. We reestimate Model 1 as a negative binomial regression where the dependent variable equals the number of material weaknesses reported during year t (MW_COUNT).15 The control variables represent firm-specific factors that prior literature indicates are predictive of internal control deficiencies in order to determine whether business strategy is predictive of material weaknesses incremental to these known determinants. Unless otherwise specified, all variables are measured as of the year t year-end balance sheet date. We control for firm size using the natural log of the market value of equity (LnMVE) and control for firm age using the natural log of the number of years the firm has appeared in the CRSP monthly return file (AGE). We include two controls for firm performance. First, AGGR_LOSS is an indicator variable equal to one if earnings before extraordinary items summed over the prior two years is less than zero. Second, we control for financial distress using the probability of bankruptcy, following Shumway (2001) (BANKRUPTCY). Doyle et al. (2007b) explore the role of complexity in material weakness disclosures due to the increased costs involved in aggregating information and coordinating internal controls across multiple divisions and geographic locations. As discussed previously, strategy 14 We perform supplemental tests by including significant deficiencies and material weaknesses reported under Section 302 of the Sarbanes-Oxley Act over the period 2004-2011 and obtain consistent inferences (untabulated). 15 We use negative binomial regression because the count dependent variable, MW_COUNT, is over-dispersed (mean = 0.153, variance = 0.421) which can bias the standard errors downward in a Poisson regression (Long and Freese 2006). Negative binomial regressions include an additional error term in a Poisson regression to correct this bias in the standard errors. 18 and complexity reflect different constructs, although both are likely associated with internal control deficiencies. For this reason, we include three controls for business complexity following Doyle et al. (2007b): (1) the natural log of the number of special purpose entities reported on Exhibit 21 to the firm’s 10-K (SPE), (2) the natural log of the number of business and geographic segments as reported in Compustat Segment (SEGMENTS), and (3) FOREIGN, an indicator variable equal to one if the firm reports foreign currency translations during the year per Compustat.16 In addition, firm growth is an important determinant of both business strategy and because firms can “outgrow” their internal controls through internal growth and through acquisitions. The model includes three controls for growth following Doyle et al. (2007b): (1) EXTREME_GROWTH, an indicator variable equal to one if change in industry-adjusted sales growth is in the largest quintile; (2) the total dollar amount of acquisitions in the current and prior year scaled by the firm’s market capitalization (ACQ_VALUE); and (3) total restructuring charges in the current and prior year scaled by market capitalization (RESTRUCTURING). Because auditors’ abilities to detect internal control deficiencies are an important dimension of audit quality, we include an indicator variable equal to one if the firm retains a Big 4 auditor and equal to zero otherwise (BIGN). We include an indicator variable equal to one if the firm reports a restatement in year t (RESTATEMENT) because restatements are common indicators of material weaknesses (PCAOB 2004). We also control for management changes because prior research suggests that corporate governance and management turnover are associated with the disclosure of material weaknesses (Li, Sun, and Ettredge 2010; Johnstone et al. 2011). In addition, prior research suggests that prospector firms experience more frequent CEO turnover than other firms (Miles and Snow 1978, 2003; Thomas and Ramaswamy 1994, 1996). We include an indicator variable equal to one if either the firm 16 We collect the number of SPEs reported by the firm following the procedure described in Feng, Gramlich, and Gupta (2009). 19 experienced a change in CEO or CFO during the year (EXEC_TURN) or a change in the board of directors during the year (BOD_TURN) as reported in the Audit Analytics Director and Officer Changes module. We also control for the extent of outside monitoring using the percentage of shares held by institutions as of year-end (INST_OWN). Finally, we include indicator variables for industry using the Fama-French 12 industry classification and cluster standard errors by firm and year to control for time-series and cross-sectional correlation (Gow, Ormazabal, and Taylor 2010). To test H1b proposing that prospector firms are less likely to remediate material weaknesses, we examine only firms reporting a material weakness in year t and estimate a logistic regression where the dependent variable equals one if the firm receives an unqualified internal control report in year t+1 and equals zero otherwise (REMEDIATE). Following prior research examining material weakness remediation, the independent variables in this model are calculated as the average of the values in years t and t+1 (Goh 2009), when possible. Variables related to the original material weakness (RESTATEMENT and MW_COUNT) and variables that are not meaningful when averaged (AGE, STRATEGY) are included in the model at their values in year t. The value of BIGN for year t+1 is included to capture the auditor in the year of remediation. To test H2, we adapt Rice and Weber’s (2012) framework for identifying timely versus untimely material weakness reporting. Because a restatement announcement implies a material weakness in internal control (PCAOB 2007), Rice and Weber consider material weaknesses announced in conjunction with, or in the next opinion following, a restatement to be untimely whereas other material weaknesses are considered to be reported on a timely basis. We estimate a multinomial logistic regression model where the dependent variable falls into one of three categories each year: (1) a material weakness reported in conjunction with, or in the next audit report following, a restatement of the financial statements or SOX 404 20 report (an untimely material weakness), (2) a material weakness reported in the absence of a restatement announcement (a timely material weakness), or (3) no material weakness reported during the year.17 The control variables follow Model 1. If auditors fail to assess control risk appropriately due to an inadequate understanding of CBR, we should observe a positive and significant coefficient for STRATEGY for untimely material weaknesses. H3 proposes no difference in the relative associations between STRATEGY and MW in the pre- and post-AS No. 5 periods. First, we estimate Model 1 separately in the pre- and post-AS No. 5 periods (2004-2006 and 2007-2011, respectively) and test the equality of the coefficients for STRATEGY across the two periods using seemingly unrelated estimation. Second, we re-estimate the multinomial logistic regression examining the timeliness of reported material weaknesses separately in the AS No. 2 and AS No. 5 periods. If AS No. 5 had no effect on auditor detection and reporting of material weaknesses, then we should observe no difference in the associations between STRATEGY and both timely and untimely material weaknesses. IV. DESCRIPTIVE STATISTICS AND EMPIRICAL RESULTS Table 2, Panel A presents descriptive statistics for the dependent and independent variables in Model 1. Eight percent of audit opinions in the sample report a material weakness in internal control over financial reporting. With respect to the business strategy types, 7.4 percent of observations are classified as prospectors, 5.4 percent are classified as 17 Our approach differs from Rice and Weber (2012) whose unit of analysis is an individual restatement over the period 2004-2008. Rice and Weber do not perform a firm-year level analysis and exclude subsequent restatements announced by repeat restatement firms, firms that reported material weaknesses but no restatement, and firms that never reported a material weakness. While these research design choices are appropriate for their research question which examines the determinants of untimely reporting, we expand our analysis to include non-restatement firms, non-material weakness firms, and repeat restatements in order to link the findings in Table 4 to the timely versus untimely reporting framework. Furthermore, we conduct our analysis at the firmyear level rather than the restatement level in order to include non-restatement observations. Our inferences are consistent when we estimate a logistic regression comparing untimely to timely material weaknesses and when restricting the sample only to firm years that are later restated. 21 defenders, and 87.2 percent are classified as analyzers.18 The mean market capitalization (LnMVE) equals 6.9 or approximately $1 billion, consistent with the small-filer exclusion for internal control attestation under Section 404 (Gao, Wu, and Zimmerman 2009). Table 2, Panel B presents the industry composition of the sample. Business equipment is the most commonly represented industry in the sample (24.4 percent). Manufacturing, Wholesale and Retail, Healthcare, and Other Industries each comprise less than 15 percent of the sample and all other industries each comprise less than 10 percent of the sample. Among prospector firms, 30.3 percent operate in Business Equipment, 25.7 percent operate in Healthcare, and 13 percent operate in manufacturing with all other industries each representing less than 10 percent of the sample. Among defender firms, 22.9 percent operate in Other industries, 19 percent operate in Manufacturing, 16.3 percent in Chemicals, and 10.6 percent operate in Business Equipment with all other industries each representing less than 10 percent of the sample.19 [Insert Table 2 here] Table 3 presents correlations among the variables. The correlations among most variable pairs are small. STRATEGY is positively correlated with MW and MW_COUNT (significant at the 5 percent level) indicating that firms following a prospector strategy (i.e., firms with higher STRATEGY scores) have more material weaknesses in their internal controls. STRATEGY is negatively correlated with REMEDIATE indicating that firms following a prospector strategy are less likely to remediate material weaknesses in their internal controls. Regarding control variables, STRATEGY is positively correlated with 18 We follow Bentley et al. (2013) in defining “pure” prospector firms as those having the highest STRATEGY scores (i.e., scores between 24 and 30), “pure” defender firms as those having the lowest STRATEGY scores (i.e., scores between 6 to 12), and “hybrid” analyzer firms as occupying the middle of the STRATEGY continuum (i.e., scores between 13 to 23). We find consistent results when we replace our discrete STRATEGY measure with these indicator variables in untabulated robustness tests. 19 Bentley et al. (2013) find industry distributions between prospectors and defenders to be in relatively equal proportions because they show the industry distributions of the STRATEGY measure prior to data cuts for control variables. We show similar industry distributions when constructing the STRATEGY measure prior to imposing our sample restrictions. 22 LNMVE, AGGR_LOSS, FOREIGN, EXTREME_GROWTH, EXEC_TURN, and BOD_TURN and is negatively correlated with AGE, BANKRUPTCY, SPE, RESTRUCTURING, and INST_OWN. These correlations are consistent with organizational theory and prior empirical research. Although the correlation between BANKRUPTCY and LNMVE exceeds |0.50|, multicollinearity diagnostics confirm the stability of the coefficient estimates and indicate that these correlations are not problematic.20 [Insert Table 3 here] Table 4 presents multivariate tests of H1. Columns 1 and 2 present the test of H1a investigating whether firms following a prospector strategy are more likely to report a material weakness and/or report a greater number of material weaknesses than firms following a defender strategy. In Column 1, the coefficient for STRATEGY is positive and significant (p<0.01) indicating that firms whose characteristics are most consistent with a prospector strategy (hereafter prospectors) are more likely to report a material weakness. A likelihood ratio test (untabulated) indicates that the addition of STRATEGY to the model adds incremental explanatory power over a model based on prior research that omits STRATEGY (χ2 =11.64, p<0.01). In Column 2, the coefficient for STRATEGY is positive and significant (p<0.01) indicating that prospectors report a greater number of material weaknesses. Column 3 presents the test of H1b examining whether prospector firms are less likely to remediate material weaknesses in year t+1. In Column 3, the coefficient for STRATEGY is negative and marginally significant (p<0.10), indicating that prospectors are less likely than defenders to remediate material weaknesses reported in year t during year t+1. [Insert Table 4 here] Table 5 presents the results of testing H2, which examines the timeliness of reported material weaknesses. Column 1 presents the coefficient estimates comparing firms reporting 20 The largest variance inflation factor equals 3.74 and the condition index equals 19.42. Both tests indicate that multicollinearity is not a concern in our models. 23 a timely material weakness to firms reporting no material weakness, and Column 2 presents the coefficient estimates comparing firms reporting an untimely material weakness to firms reporting no material weakness. If auditors fail to assess control risk appropriately for prospector clients, the coefficient for STRATEGY in column 2 should be positive and significant. The coefficient for STRATEGY is positive and significant (p<0.01) in Column 2 and also positive and marginally significant in Column 1 (p<0.10).21 The results in Table 5 indicate that firms with greater prospector characteristics are more likely to report both timely and untimely material weaknesses relative to firms reporting no material weaknesses. These results reveal that while firms and auditors are more likely to report timely material weaknesses for prospector firms than other firms, they also have greater difficulty identifying and reporting material weaknesses among prospector firms, potentially due to inadequate control risk assessment as implied by a failure to gain a sufficient understanding of the client’s CBR. This finding has three additional implications. First, because prospectors are more likely to report untimely material weaknesses than other firms, the absence of a material weakness in the auditor’s attestation report may be less diagnostic of internal control quality to financial statement users of prospector firms than other firms. Second, these results imply that the increased likelihood of material weaknesses among prospector firms is not driven solely by prospector’s greater propensity for restatements as documented in Bentley et al. (2013). Finally, these results suggest that focusing on control risk assessment is a potential area for improved audit quality among prospector audit clients. [Insert Table 5 here] Table 6 Panel A presents the test of H3 regarding the association between business strategy and material weaknesses in the AS No. 2 and AS No. 5 periods. The coefficient for 21 When we estimate the same regression using a sample of restatement-year observations as in Rice and Weber (2012), our results are similar. 24 STRATEGY is positive and significant (p<0.05) during the AS No. 2 period and positive and significant (p<0.01) during the AS No. 5 period. The coefficients for STRATEGY during the two periods are not statistically different from one another. Because the “top-down” riskbased approach to internal control attestation did not change the strength of the association between business strategy and material weaknesses, these results are consistent with the conclusion in Bentley et al. (2013) that auditors devote insufficient effort to understanding the risks faced by prospector firms. Table 6 Panel B presents results examining how business strategy is associated with the timeliness of material weakness reporting in the AS No. 2 and As No. 5 periods. The first two columns display regressions for the AS No. 2 period. The coefficient for STRATEGY is significant only in the “untimely” column (p<0.05). This finding indicates that auditors had difficulty linking business strategy and the presence of material weaknesses during this regulatory period. The third and fourth columns present the results for the AS No. 5 period. In columns 3 and 4, STRATEGY is significant (p<0.10) only in the “timely” column. These results, when combined with the results in Panel A, suggest that business strategy is a determinant of material weaknesses in both regulatory periods. However, AS No. 5 improved auditor detection of material weaknesses among riskier clients because material weaknesses are more likely to be reported in a timely manner under AS No. 5 rather than upon revelation of a restatement under AS No. 2. This result is consistent with the intent of AS No. 5, which mandated a top-down, risk-based approach to internal control auditing. [Insert Table 6 here] Sensitivity Tests In untabulated analysis, we examine whether firms following a prospector strategy are more likely to report company-level, account-level, staffing, complexity, and general material weaknesses (Doyle et al. 2007b; Ge and McVay 2005). The coefficient for STRATEGY is 25 positive and significant for each of these five types of material weaknesses. These results indicate that business strategy consistently predicts a significantly higher likelihood of internal control material weaknesses among prospectors than among defenders regardless of the nature of the material weakness. Next, Doyle et al. (2007b) argue that firms with stronger corporate governance should have fewer internal control problems. Similar to Doyle et al. (2007b), many governance variables limit our sample size due to missing data in commercial databases. Our main tests include governance variables with minimal data restrictions: CEO/CFO turnover, board of director turnover, and institutional ownership. When we include additional governance variables from Corporate Library that significantly reduce our sample size including (1) whether the CEO is chairman of the board, (2) the independence percentage of the board, and (3) the number of board meetings, we continue to find consistent results in our hypothesis tests. While our descriptive statistics indicate no size difference between prospector and defender firms (lnMVE), we consider whether firm size is correlated with strategy and hence an alternative explanation for our results.22 In untabulated analysis, we split the sample based on median firm size and continue to find consistent results in both small and large firm subsamples. Therefore, we conclude that our results are not driven by effects related to firm size. In our tabulated regressions, we use a continuous measure to capture the strategy of each firm. Lower values of this measure represent defenders, while higher values represent prospectors. Following Bentley et al. (2013), we construct indicator variables for defenders and prospectors and replace the continuous strategy measure with the indicator variables in 22 Finding insignificant size differences between prospectors and defenders is consistent with both organizational theory expectations (Miles and Snow 1978, 2003) and prior empirical research findings (e.g., Smith, Guthrie, and Chen 1989; Bentley et al. 2013). 26 each of the tabulated regressions. Results using the indicator variables are consistent with the tabulated results. We consider a firm's business strategy to be an underlying determinant of internal control weaknesses because of the relative stability of a firm’s strategy over time (Miles, Snow, Meyer, and Coleman1978; Mintzberg 1978; Snow and Hambrick 1980; Hambrick 1983). To test this assumption, we examine the consistency of firm classification based on strategy during our sample time period (2004-2011). Firms almost never switch from a prospector to a defender (or vice-versa) in our sample period (only one firm makes this switch), consistent with theoretical expectations. Further, we note that firms classified as prospectors (defenders) at the start of our sample retain consistently high (low) STRATEGY scores throughout the entire sample period. Finally, we find that less than 2 percent of firms change their STRATEGY score by more than 3 values (out of a total scale of 24) from year-toyear. Altogether, we confirm that a firm’s strategy is consistent over time throughout our sample period. These results imply that business strategy serves as one of the underlying, firm-specific characteristics that determine the firm’s control structure, which aligns with theoretical expectations. VI. CONCLUSION This study links organizational theory to accounting to examine whether a firm’s business strategy affects its internal controls over financial reporting (ICFR). Using archival data, our results suggest that business strategy significantly impacts firms’ ICFR, incremental to known determinants of material weaknesses. We find evidence that innovation-oriented “prospector” strategy firms are significantly more likely to report material weaknesses than efficiency-oriented “defender” strategy firms. Prospector firms also report a greater number of material weaknesses and are less likely to remediate material weaknesses in the following year. Second, we find that prospector firms are significantly more likely to report both timely 27 and untimely material weaknesses relative to defender firms. This result suggests that, in addition to prospectors having more material weaknesses than defender firms, auditors have greater difficulty in identifying and reporting material weaknesses for their prospector clients. Third, we investigate whether auditors’ focus on top-down risk assessment in the post AS No. 5 period improved their internal control reporting. We find a strong association between strategy and material weaknesses in both the pre- and post-AS No. 5 periods; however, AS No. 5 appears to have improved auditors’ detection of material weaknesses among prospector firms, as indicated by a shift in the reporting timeliness of MWs from untimely reporting under AS No. 2 to timely reporting under AS No. 5. Altogether, our findings suggest that (1) prospector firms have weaker controls than defender firms, (2) auditors have greater difficulty detecting and/or reporting deficiencies in ICFR among prospector clients, and (3) the implementation of AS No. 5 improved auditors’ ability to identify MWs for prospector clients in a timely manner. Our research is subject to two primary limitations. While we rely on Miles and Snow’s (1978, 2003) strategy typology and prior empirical research to create our business strategy measure, our measure is assessed with noise. Second, we cannot control for selection bias associated with the firm’s decision to adopt a particular strategy. Organizational theory posits that a firm’s business strategy is chosen early in a firm’s life cycle (initiated by management’s commitment of resources towards pursing certain objectives) and remains relatively stable over time. Firm strategy reflects a fundamental difference in the structure of firms where firms following different strategies have to align their strategic objectives across their firm-wide functions (i.e., entrepreneurial, engineering, and administrative functions) to be successful (Miles and Snow 1978, 2003). Hence, a firm following a prospector strategy and a firm following a defender strategy are inherently different types of firms. Therefore, econometric corrections for self-selection such as propensity-score matching where firms are 28 matched on otherwise equal dimensions excluding strategy is inconsistent with theoretical expectations. Similarly, because firms are more likely to "adjust rather than change their strategies” (Snow and Hambrick 1980, 529, italics in text), the stickiness of the strategy measure restricts the ability to define an appropriate instrument within a two-stage regression model in order to correct for selection effects. However, because a firm’s business strategy is generally constant over time, identifying a firm’s strategy may serve as a useful context for understanding differences in the control structural arrangements and weaknesses among firms. This study contributes to the literature in several ways. First, by linking organizational theory to the accounting literature, we provide a theoretical framework for understanding determinants of material weaknesses reported in prior studies and illustrate that differences in business strategy serve as an underlying determinant of firms’ control systems. Second, our findings suggest that internal control evaluation and testing is a specific area for improvement in audit quality among prospector clients and that Auditing Standard No. 5 appears to have improved auditor detection of material weaknesses by focusing auditors on a top-down riskbased approach to auditing internal controls. These findings have important implications for stakeholders evaluating the likely strength of a firm’s internal controls, practitioners planning and performing financial statement audits, and regulators conducting risk-based inspections. 29 REFERENCES Agbejule, A., and A. Jokipii. 2009. Strategy, control activities, monitoring and effectiveness. Managerial Auditing Journal 24 (6): 500-522. American Institute of Certified Public Accountants (AICPA). 2006. AU Section 311: Planning and Supervision. New York, NY: AICPA. Ashbaugh-Skaife, H., D. W. Collins, and W. R. Kinney, Jr.,. 2007. The discovery and reporting of internal control deficiencies prior to SOX-mandated audits. Journal of Accounting and Economics 44(1-2): 166-192. Ashbaugh-Skaife, H., D. W. Collins, W. R. Kinney, Jr., and R. LaFond. 2008. The effect of SOX internal control deficiencies and their remediation on accrual quality. The Accounting Review 83 (1): 217-250. Ashbaugh-Skaife, H., D. W. Collins, W. R. Kinney, Jr., and R. LaFond. 2009. The effect of internal control deficiencies on firm risk and cost of equity. Journal of Accounting Research 47 (1): 1-43. Beard, D. W., and G. G. Dess. 1981. Corporate-level strategy, business-level strategy, and firm performance. Academy of Management Journal 24 (4): 663–688. Bell, T. B., F. O. Marrs, I. Solomon, and H. Thomas. 1997. Auditing organizations through a strategic-systems lens: The KPMG business measurement process. KPMG, LLP. Bell, T., M. Peecher, and I. Solomon. 2002. The strategic systems approach to auditing. KPMG, LLP. Beneish, M.D., M.B. Billings, and L.D. Hodder. 2008. Internal control weaknesses and information uncertainty. The Accounting Review 83 (3): 665-703. Bentley, K.A. 2013. Antecedents to financial statement misreporting: The influence of organizational business strategy, ethical culture and climate. The University of New South Wales working paper. 30 Bentley, K. A., T. C. Omer, and N. Y. Sharp. 2013. Business strategy, financial reporting irregularities, and audit effort. Contemporary Accounting Research 30 (2): 780-817. Bruggeman, W., and W. Van der Stede. 1993. Fitting management control systems to competitive advantage. British Journal of Management 4 (3): 205-218. Dent, J. F. 1990. Strategy, organization and control: some possibilities for accounting research. Accounting, Organizations and Society 15 (1): 3-25. Dermer, J. 1977. Management Planning and Control Systems: Advanced Concepts and Cases. Homewood, IL: Irwin. Dhaliwal, D., C. Hogan, R. Trezevant, and M. Wilkins. 2011. Internal control disclosures, monitoring, and the cost of debt. The Accounting Review 86 (4): 1131-1156. Doogar, R., S. Rowe, and P. Sivadasan 2012. Asleep at the wheel (again)? Bank audits during the financial crisis. Contemporary Accounting Research (forthcoming). Doogar, R., P. Sivadasan, and I. Solomon. 2010. The regulation of public company auditing: Evidence from the transition to AS5. Journal of Accounting Research 48 (4): 795814. Doyle, J. T., W. Ge, and S. McVay. 2007a. Accruals quality and internal control over financial reporting. The Accounting Review 82 (5): 1141-1170. Doyle, J. T., W. Ge, and S. McVay. 2007b. Determinants of weaknesses in internal control over financial reporting. Journal of Accounting and Economics 44 (1-2): 193-223. Fama, E. F., and K. R. French. 1988. Permanent and temporary components of stock prices. The Journal of Political Economy 96 (2): 246–73. Feng, M., J. Gramlich, and S. Gupta. 2009. Special purpose vehicles: Empirical evidence on determinants and earnings management. The Accounting Review 84 (6): 1833-1876. Fisher, J. 1995. Contingency-based research on management control systems: categorization by level of complexity. Journal of Accounting Literature 14: 24-53. 31 Gao, P., J. Wu, and J. Zimmerman. 2009. Unintended consequences of granting small firms exemptions from securities regulation: Evidence from the Sarbanes-Oxley Act. Journal of Accounting Research 47 (2): 459-506. Ge, W., and S. McVay. 2005. The disclosure of material weaknesses in internal control after the Sarbanes-Oxley Act. Accounting Horizons 19 (3): 137-158. Goh, B. W. 2009. Audit committees, boards of directors, and remediation of material weaknesses in internal control. Contemporary Accounting Research 26 (2): 549-579. Gordon, L. A., and D. Miller. 1976. A contingency framework for the design of accounting information systems. Accounting, Organizations and Society 1 (1): 59-69. Govindarajan, V., and A. K. Gupta. 1985. Linking control systems to business unit strategy: impact on performance. Accounting, Organizations and Society 10 (1): 51-66. Govindarajan, V. 1986. Decentralization, strategy, and effectiveness of strategic business units in multi-business organizations. Academy of Management Review 11 (4): 844856. Gow, I. D., G. Ormazabal, and D. J. Taylor. 2010. Correcting for cross-sectional and timeseries dependence in accounting research. The Accounting Review 85 (2): 483-512. Gupta, P., and N. Nayar. 2007. Information content of control deficiency disclosures under the Sarbanes-Oxley Act: An empirical investigation. International Journal of Disclosure and Governance 4 (1): 3-23. Hambrick, D. C. 1983. Some tests of the effectiveness and functional attributes of Miles and Snow's strategic types. Academy of Management Journal 26 (1): 5-26. Hammersley, J. S., L. A. Myers, and C. Shakespeare. 2008. Market reactions to the disclosure of internal control weaknesses and to the characteristics of those weaknesses under Section 302 of the Sarbanes-Oxley Act of 2002. Review of Accounting Studies 13 (1): 141-165. 32 Henri, J.-F. 2006. Management control systems and strategy: A resource-based perspective. Accounting, Organizations, and Society 31 (6): 529-558. International Federation of Accountants (IFAC). 2009. International Standard on Auditing (ISA) 315: Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and Its Environment. New York, NY: IFAC. Ittner, C. D., D. F. Larcker, and M. V. Rajan. 1997. The choice of performance measures in annual bonus contracts. The Accounting Review 72 (2): 231-255. Jiang, W., and J. Wu. 2009. The impact of PCAOB Auditing Standard 5 on audit fees. The CPA Journal 79 (4): 34-38. Johnstone, K., C. Li, and K. H. Rupley. 2011. Changes in corporate governance associated with the revelation of internal control material weaknesses and their subsequent remediation. Contemporary Accounting Research 28 (1): 331-383. Joyce, W.F., and J.W. Slocum, Jr. 1990. Strategic context and organizational climate. In Organizational Culture and Climate, edited by B.Schneider, 130-150. San Francisco, CA: Jossey-Bass Publishers. Kim, J-B, B. Y. Song, and L. Zhang. 2011. Internal control weakness and bank loan contracting: Evidence from SOX Section 404 disclosures. The Accounting Review 86 (4): 1157-1188. Kinney, Jr., W. R. 2000. Research opportunities in internal control quality and quality assurance. Auditing: A Journal of Practice and Theory 19 (Supplement): 83-90. Kinney, W. R., and L. S. McDaniel. 1989. Characteristics of firms correcting previously reported quarterly earnings. Journal of Accounting and Economics 11 (1): 71-93. Langfield-Smith, K. 1997. Management control systems and strategy: A critical review. Accounting, Organizations and Society 22 (2): 207-232. 33 Li, C., L. Sun, and M. Ettredge. 2010. Financial executive quality, financial executive turnover, and adverse SOX 404 opinions. Journal of Accounting and Economics 50 (1): 93-110. Long, J.S., and J. Freese. 2006. Regression Models for Categorical Dependent Variables Using Stata. 2nd edition. College Station, TX: Stata Press. Merchant, K. A. 1981. The design of the corporate budgeting system: Influences on managerial behavior and performance. The Accounting Review 56 (4): 813-829. Merchant, K. A. 1984. Influences on departmental budgeting: An empirical examination of a contingency model. Accounting, Organizations and Society 9 (3): 291-307. Merchant, K. A. 1985. Organizational controls and discretionary program decision making: A field study. Accounting, Organizations and Society 10 (1): 67-86. Miles, R.E., and C.C. Snow. 1978. Organizational Strategy, Structure and Process. New York, NY: McGraw-Hill. Miles, R.E., and C. C. Snow. 1994. Fit, Failure, and the Hall of Fame: How Companies Succeed or Fail. New York, NY: The Free Press. Miles, R.E., and C.C. Snow. 2003. Organizational Strategy, Structure and Process. Stanford, CA: Stanford University Press. Miles, R.E., C.C. Snow, A.D. Meyer, and H. J. Coleman, Jr. 1978. Organizational strategy, structure and process. The Academy of Management Review 3 (3): 546-562. Miller, D., and P. H. Friesen. 1978. Archetypes of strategy formulation. Management science 24 (9): 921-933. Miller, D., and P. H. Friesen. 1982. Innovation in conservative and entrepreneurial firms: Two models of strategic momentum. Strategic Management Journal 3 (1): 1-25. Mintzberg, H. 1978. Patterns in strategy formation. Management Science 24 (9): 934-948. 34 Otley, D. T. 1980. The contingency theory of management accounting: Achievement and prognosis. Accounting, Organizations and Society 5 (4): 413-428. Porter, M.E. 1980. Competitive Strategy: Techniques for Analyzing Industries and Competitors. New York, NY: The Free Press. Public Company Accounting Oversight Board (PCAOB). 2004. Auditing Standard No. 2: An Audit of Internal Control Over Financial Reporting That Is Integrated with an Audit of Financial Statements. PCAOB Release No. 2004-001. Washington, DC: PCAOB. Public Company Accounting Oversight Board (PCAOB). 2007. Auditing Standard No. 5: An Audit of Internal Control over Financial Reporting That Is Integrated with an Audit of Financial Statements and Related Independence Rule and Conforming Amendments. PCAOB Release No. 2007-005A, June 12. Washington, DC: PCAOB. Rajagopalan, N. 1997. Strategic orientations, incentive plan adoptions, and firm performance: Evidence from electric utility firms. Strategic Management Journal 18 (10): 761-785. Rice, S. C., and D. P. Weber. 2012. How effective is internal control reporting under SOX 404? Determinants of the (non-) disclosure of existing material weaknesses. Journal of Accounting Research 50 (3): 811-843. Schneider, A., A. A. Gramling, D. R. Hermanson, and Z. Ye. 2009. A review of academic literature on internal control reporting under SOX. Journal of Accounting Literature 28: 1-46. Securities and Exchange Commission (SEC). 2002. Certification of Disclosure in Companies' Quarterly and Annual Reports. Release No. 33-8124. Washington, DC.: SEC. Securities and Exchange Commission (SEC). 2003. Management's Reports on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports. Release No. 33-8238. Washington, DC.: SEC. 35 Securities and Exchange Commission (SEC). 2004. Management's Reports on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports--Frequently Asked Questions. (October 6) Washington, DC.: SEC. Seifzadeh, P. 2011. Business strategy and the synergistic combination of exploration and exploitation. University of Western Ontario Working Paper. Shumway, T. 2001. Forecasting bankruptcy more accurately: A simple hazard model*. The Journal of Business 74 (1): 101-124. Simons, R. 1987. Accounting control systems and business strategy: An empirical analysis. Accounting, Organizations and Society 12 (4): 357-374. Singh, P., and N. C. Agarwal. 2002. The effects of firm strategy on the level and structure of executive compensation. Canadian Journal of Administrative Sciences 19 (1): 42-56. Smith, K. G., J. P. Guthrie, and M-J. Chen. 1989. Strategy, size and performance. Organization Studies 10 (1): 63-81. Snow, C. C., and D. C. Hambrick. 1980. Measuring organizational strategies: Some theoretical and methodological problems. Academy of Management Review 5 (4): 527-538. Thomas, A. S., and K. Ramaswamy. 1994. Matching managers to strategy: An investigation of performance implications and boundary conditions. Australian Journal of Management 19 (1): 73-93. Thomas, A.S., and K. Ramaswamy. 1996. Matching managers to strategy: Further tests of the Miles and Snow typology. British Journal of Management 7: 247-261. Zahra, S. A., and J. A. Pearce. 1990. Research evidence on the Miles-Snow typology. Journal of Management 16 (4): 751-768. 36 APPENDIX Variable Definitions Variable Definition STRATEGY Discrete score with values ranging from 6 to 30 where high (middle) [low] values indicate prospector (analyzer) [defender] firms, respectively; Refer to Bentley et al. (2013) for score construction. MW Indicator variable equal to 1 when the firm’s auditor reports a material weakness under SOX Section 404. MW_COUNT The number of material weaknesses reported under SOX Section 404 in year t. REMEDIATE Indicator variable equal to 1 when the firm’s auditor reports no SOX Section 404 material weaknesses in year t+1 after having reported a material weakness in year t. MW_TIMELINESS Indicates when a MW is reported: set to 0 if year t is never associated with a MW, set to 1 if a MW is reported in connection with the filing of year t’s financial statements (considered a timely report), and set to 2 if a MW is revealed through a restated SOX section 404 disclosure or in the aftermath of a future restatement of year t’s financial statements (considered a late report). LnMVE The natural log of the firm’s market capitalization (shares outstanding times price per share as of year-end). AGE The number of years since the firm first appeared on CRSP. AGGR_LOSS Indicator variable equal to 1 if the sum of income before extraordinary items in years t-1 and t is less than zero. BANKRUPTCY The probability of bankruptcy, following Shumway (2001). SPE The natural log of the number of special purpose entities reported on Exhibit 21 of the firm’s 10-k. SEGMENTS The natural log of the sum of the firm’s business and geographic segments reported on Compustat. FOREIGN Indicator variable equal to 1 if the firm had foreign income. ACQ_VALUE The value of acquisitions in the current and prior-year scaled by the firm’s market capitalization. EXTREME_GROWTH Indicator variable equal to one if change in industry-adjusted sales growth is in the largest quintile. RESTRUCTURING The total restructuring charges in the current and prior year scaled by the firm’s market capitalization. RESTATEMENT Indicator variable equal to 1 if the firm announces a restatement during year t. BIGN Indicator variable equal to 1 if the company is audited by a Big 4 audit firm. EXEC_TURN Indicator variable equal to 1 if the firm experiences turnover of the CEO or CFO during year t as indicated by Audit Analytics. BOD_TURN Indicator variable equal to 1 if the firm experiences turnover on the board of directors during year t as indicated by Audit Analytics. INST_OWN The percentage of the firm’s shares owned by institutional owners. 37 TABLE 1 Sample Selection Internal control opinion data 2004-2011 41,513 Exclude firm years lacking COMPUSTAT data to construct control variables (6,553) Exclude firm years lacking CRSP data to construct control variables (3,750) Exclude firm years lacking Audit Analytics data to construct control variables (26) Exclude firm years lacking data to construct STRATEGY measure (12,617) Exclude Section 302 MWs/significant deficiencies without corresponding Section 404 MWs (1,069) Exclude firm years claiming a SOX 404 exemption (3,844) Final Sample 13,654 38 TABLE 2 Descriptive Statistics Panel A: Comparative Descriptive Statistics Variable STRATEGY MW MW_COUNT REMEDIATE LnMVE AGE AGGR_LOSS BANKRUPTCY SPE SEGMENTS FOREIGN ACQ_VALUE EXTREME_GROWTH RESTRUCTURING RESTATEMENT BIGN EXEC_TURN BOD_TURN INST_OWN Mean 18.168 0.081 0.153 0.681 6.915 2.841 0.260 4.501 1.008 1.521 0.162 0.054 0.200 0.015 0.073 0.860 0.237 0.470 0.604 Full Sample (N=13,654) Med. Q1 Q3 18.000 16.000 21.000 0.000 0.000 0.000 0.000 0.000 0.000 1.000 0.000 1.000 6.753 5.599 8.036 2.773 2.398 3.332 0.000 0.000 1.000 5.000 2.000 7.000 0.693 0.000 1.792 1.609 1.099 1.946 0.000 0.000 0.000 0.001 0.000 0.038 0.000 0.000 0.000 0.000 0.000 0.007 0.000 0.000 0.000 1.000 1.000 1.000 0.000 0.000 0.000 0.000 0.000 1.000 0.707 0.377 0.870 Std. Dev. 3.591 0.273 0.649 0.466 1.776 0.687 0.439 2.871 1.203 0.574 0.368 0.168 0.400 0.075 0.261 0.347 0.425 0.499 0.328 39 Prospectors (N=1,015) Mean Med. 25.136 25.000 0.106 0.000 0.233 0.000 0.600 1.000 6.572 6.339 2.481 2.398 0.500 1.000 4.916 5.000 0.726 0.000 1.474 1.609 0.158 0.000 0.055 0.001 0.365 0.000 0.000 0.012 0.064 0.000 0.834 1.000 0.249 0.000 0.488 0.000 0.521 0.600 Defenders (N=738) Mean Med. 10.959 11.000 0.046 0.000 0.095 0.000 0.769 1.000 6.505 6.390 2.875 2.833 0.234 0.000 5.102 5.000 1.129 1.099 1.490 1.609 0.146 0.000 0.053 0.000 0.198 0.000 0.000 0.025 0.070 0.000 0.851 1.000 0.215 0.000 0.432 0.000 0.616 0.704 TABLE 2 (Continued) Panel B: Industry Composition Industry Consumer Non-durables Full Sample (N=13,654) 915 6.7% Prospectors (N=1,015) 41 4.04% Defenders (N=738) 25 3.39% Consumer Durables 464 3.4% 15 1.48% 25 3.39% Manufacturing 1,808 13.2% 132 13.00% 140 18.97% Energy 902 6.6% 70 6.90% 57 7.72% Chemicals 466 3.4% 2 0.20% 120 16.26% 3,325 24.4% 307 30.25% 78 10.57% Business Equipment Telecom 553 4.1% 20 1.97% 33 4.47% Wholesale and Retail 1,859 13.6% 90 8.87% 43 5.83% Healthcare 1,439 10.5% 261 25.71% 48 6.50% Other 1,923 14.1% 77 7.59% 169 22.90% Note: The appendix provides definitions of variables in this table. The descriptive statistics in Panel A are shown for the full set of observations and separately for prospectors and defenders. The sample sizes for the variable REMEDIATE are 827, 70, and 26 for the full, prospector, and defender samples. All other sample sizes are indicated in the table. Bolded means and medians are significantly different between prospectors and defenders at the 5 percent level. The industry composition in Panel B is based on the 12 industries in Fama and French (1988). 40 TABLE 3 Correlation Table (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) Variable STRATEGY MW MW_COUNT REMEDIATE LnMVE AGE AGGR_LOSS BANKRUPTCY SPE SEGMENTS FOREIGN ACQ_VALUE EXTREME_GROWTH RESTRUCTURING RESTATEMENT BIGN EXEC_TURN BOD_TURN INST_OWN (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) 0.05 0.05 -0.08 0.03 -0.16 0.13 -0.04 -0.08 0.00 0.02 0.01 0.11 -0.03 0.00 -0.01 0.03 0.02 -0.06 0.79 N/A -0.14 -0.08 0.12 0.12 -0.07 0.00 0.02 0.01 0.02 0.02 0.21 -0.06 0.08 0.01 -0.08 -0.32 -0.12 -0.08 0.12 0.12 -0.06 0.01 0.03 0.00 0.01 0.02 0.24 -0.05 0.09 0.02 -0.08 0.03 -0.01 -0.04 -0.03 0.02 -0.11 -0.01 0.03 -0.02 0.01 -0.09 0.04 -0.01 0.00 0.08 0.27 -0.38 -0.56 0.27 0.26 0.09 -0.11 0.01 -0.16 -0.07 0.34 -0.07 0.03 0.18 -0.16 -0.14 0.17 0.22 0.01 -0.01 -0.15 0.00 -0.03 0.06 0.01 0.09 0.15 0.45 -0.06 -0.07 -0.01 0.07 -0.01 0.22 0.05 -0.09 0.11 0.07 -0.21 -0.05 -0.14 -0.04 0.10 -0.10 0.18 0.07 -0.11 0.08 0.01 -0.20 0.04 -0.05 0.10 -0.08 0.02 -0.03 0.17 0.04 0.12 0.16 0.19 0.01 -0.01 0.04 -0.02 0.10 -0.01 0.01 -0.01 -0.01 0.01 0.02 0.00 0.04 -0.03 -0.05 -0.05 0.08 0.13 0.00 0.00 0.03 0.02 -0.01 -0.06 -0.01 -0.05 -0.04 -0.03 -0.04 0.01 0.02 0.06 0.05 -0.08 -0.01 0.06 0.03 -0.01 -0.01 0.03 0.15 0.27 0.02 0.11 Note: The appendix provides definitions of variables in this table. The table shows Pearson correlations among regression variables. Bolded correlations are significant at the 5 percent level. The variable REMEDIATE is constructed conditional on the existence of a material weakness (MW) in year t, thus the correlation between these two variables is omitted. 41 TABLE 4 Business Strategy and the Probability of Reporting and Remediating a Material Weakness STRATEGY LnMVE AGE AGGR_LOSS BANKRUPTCY SPE SEGMENTS FOREIGN ACQ_VALUE EXTREME_GROWTH RESTRUCTURING RESTATEMENT BIGN EXEC_TURN BOD_TURN INST_OWN (1) MW (2) MW_COUNT (3) REMEDIATE 0.033*** (3.273) -0.194*** (-3.702) -0.234*** (-3.538) 0.248* (1.880) 0.056 (1.552) -0.093*** (-3.547) 0.284*** (2.603) 0.226 (1.521) -0.152 (-0.791) 0.147* (1.762) -0.623*** (-2.855) 1.643*** (11.566) -0.137 (-0.886) 0.471*** (3.581) -0.032 (-0.323) -0.305* (-1.774) 0.038*** (3.300) -0.230*** (-6.183) -0.166** (-2.296) 0.273*** (2.860) 0.073*** (4.044) -0.095** (-2.169) 0.374*** (4.381) 0.325*** (3.265) 0.154 (0.776) 0.151* (1.701) -0.208 (-0.523) 1.482*** (17.840) -0.273** (-2.275) 0.526*** (6.880) 0.031 (0.410) -0.309** (-2.273) -0.055* (-1.828) 0.066 (0.843) -0.281*** (-3.037) -0.012 (-0.047) -0.009 (-0.251) 0.011 (0.135) -0.362* (-1.892) -0.026 (-0.275) 0.101 (0.479) -0.327** (-1.981) 0.047 (0.058) -0.063 (-0.510) 0.204 (0.819) -0.383 (-1.553) 0.169 (0.694) 0.185 (0.430) -0.452*** (-7.527) Yes No Firm / Year 13,654 Yes Yes Firm 13,654 MW_COUNT Industry Indicators Year Indicators Cluster Observations Pseudo R2 Wald p-value ROC Curve 0.115 Yes No Firm / Year 827 0.113 <0.000 0.749 42 0.727 Note: The appendix provides definitions of variables in this table. The table shows coefficients (z-statistics) from regressions examining the association of STRATEGY with reporting a MW (column 1), the number of MWs reported (column 2), and the remediation of a reported MW (column 3). Columns (1) and (3) use logistic regression, and Column (2) uses negative binomial regression. In Column (3) the following independent variables are averaged over the remediation period (see Goh 2009): lnMVE, AGGR_LOSS, BANKRUPTCY, SPE, SEGMENTS, FOREIGN, ACQ_VALUE, EXTREME_GROWTH, RESTRUCTURING, and INST_OWN. BIGN, EXEC_TURN, and BOD_TURN represent the auditor or turnover occurring during the remediation period, and STRATEGY, AGE, RESTATEMENT, and MW_COUNT are the values as of the end of year t when the MW is reported. ***, **, and * indicate statistical significance at the 1, 5, and 10 percent levels, respectively based on two-tailed tests except where indicated by a sign prediction. 43 TABLE 5 Business Strategy and the Timeliness of Reporting a Material Weakness Variables STRATEGY LnMVE AGE AGGR_LOSS BANKRUPTCY SPE SEGMENTS FOREIGN ACQ_VALUE EXTREME_GROWTH RESTRUCTURING RESTATEMENT BIGN EXEC_TURN BOD_TURN INST_OWN (1) TIMELY 0.026* (1.841) -0.227*** (-5.192) -0.101 (-1.138) 0.363*** (3.157) 0.063*** (2.984) -0.074 (-1.473) 0.390*** (4.019) 0.496*** (4.472) 0.112 (0.487) 0.172 (1.588) 0.139 (0.360) 1.128*** (9.669) -0.418*** (-3.098) 0.557*** (5.974) 0.030 (0.345) -0.385** (-2.494) Industry & Year Indicators Yes Cluster Firm Observations 13,654 Pseudo R2 0.155 (2) LATE 0.048*** (2.755) -0.220*** (-4.000) -0.112 (-1.158) 0.274** (1.981) 0.045* (1.939) -0.014 (-0.241) 0.197* (1.681) -0.020 (-0.149) 0.034 (0.142) 0.209* (1.707) -0.194 (-0.277) 1.499*** (13.471) 0.171 (0.986) 0.358*** (3.424) -0.046 (-0.478) 0.213 (1.043) Note: The appendix provides definitions of variables in this table. The table shows coefficients (z-statistics) from multinomial logistic regressions examining the association between business STRATEGY and the timeliness of reported material weaknesses. The dependent variable is MW_TIMELINESS. The base group includes all observations where a MW for year t is never reported. Column (1) compares the base group to observations where a MW is reported for year t at the end of year t, and Column (2) compares the base group to observations where a MW is revealed in association with the restatement of year t’s SOX 404 opinion or the restatement of financial statements in a later year. 44 TABLE 6 The Effect of AS No. 5 on the Relation between Business Strategy and Material Weaknesses Panel A – Strategy and MWs in the Pre and Post-AS5 Periods Variables STRATEGY LnMVE AGE AGGR_LOSS BANKRUPTCY SPE SEGMENTS FOREIGN ACQ_VALUE EXTREME_GROWTH RESTRUCTURING RESTATEMENT BIGN EXEC_TURN BOD_TURN INST_OWN Industry Indicators Cluster Observations Pseudo R2 ROC Curve (1) Pre AS 5 (2) Post AS 5 0.020*** (2.602) -0.338*** (-17.116) -0.110** (-2.285) 0.446*** (4.228) 0.009 (0.254) -0.042 (-1.538) 0.472*** (3.271) 0.257 (1.421) 0.191 (0.898) 0.143*** (2.951) 1.497 (0.978) 1.328*** (6.182) -0.035 (-0.337) 0.404*** (3.567) -0.058 (-0.844) -0.043 (-0.221) 0.046** (2.350) -0.132*** (-2.971) -0.208** (-2.070) 0.207* (1.825) 0.091*** (3.126) -0.072 (-1.193) 0.180* (1.871) 0.440* (1.688) 0.142 (0.770) 0.237 (1.472) -0.055 (-0.381) 1.615*** (9.249) -0.460*** (-2.774) 0.604*** (3.187) 0.005 (0.027) -0.469* (-1.741) Yes Firm / Year 4,983 0.123 0.744 Yes Firm / Year 8,671 0.116 0.768 Test of coefficients: STRATEGY in PRE vs. POST periods: Chi-square = 1.38, p = 0.2395 45 Panel B – The Timeliness of MW Reporting in the Pre and Post-AS5 Periods Variables STRATEGY LnMVE AGE AGGR_LOSS BANKRUPTCY SPE SEGMENTS FOREIGN ACQ_VALUE EXTREME_GROWTH RESTRUCTURING RESTATEMENT BIGN EXEC_TURN BOD_TURN INST_OWN Industry & Year Indicators Cluster Observations Pseudo R2 Pre AS 5 TIMELY LATE Post AS 5 TIMELY LATE 0.015 (0.922) -0.319*** (-5.861) -0.050 (-0.501) 0.398*** (2.659) 0.050* (1.952) -0.059 (-0.981) 0.541*** (4.332) 0.413*** (2.926) 0.709 (1.258) 0.172 (1.229) 1.839 (1.157) 1.004*** (7.013) -0.294* (-1.820) 0.595*** (4.869) 0.013 (0.116) -0.167 (-0.886) 0.042* (1.826) -0.129** (-2.166) -0.167 (-1.198) 0.320* (1.798) 0.062* (1.773) -0.060 (-0.810) 0.166 (1.199) 0.582*** (3.582) 0.018 (0.063) 0.121 (0.729) 0.187 (0.413) 1.394*** (7.321) -0.608*** (-3.172) 0.507*** (3.617) 0.071 (0.500) -0.641*** (-2.843) 0.045** (2.362) -0.274*** (-3.982) -0.078 (-0.698) 0.365** (2.243) 0.013 (0.457) 0.002 (0.032) 0.267* (1.942) -0.081 (-0.467) -0.422 (-0.600) 0.054 (0.350) -2.121 (-0.983) 1.517*** (11.590) 0.251 (1.209) 0.340*** (2.716) -0.019 (-0.167) 0.429* (1.773) Yes Firm 4,983 Yes Firm 8,671 0.116 0.118 0.051 (1.494) -0.159** (-2.072) -0.128 (-0.811) 0.167 (0.747) 0.122*** (3.114) -0.002 (-0.025) 0.135 (0.708) 0.065 (0.299) 0.031 (0.134) 0.496** (2.560) 0.061 (0.099) 1.450*** (6.694) 0.090 (0.335) 0.385** (2.008) -0.058 (-0.312) -0.048 (-0.143) Note: The appendix provides definitions of variables in this table. Panel A shows coefficients (z-statistics) from logistic regressions examining the association between reported material weaknesses and business STRATEGY before and after implementation of Audit Standard No. 5. We perform the test of coefficient equivalence across the two models using seemingly unrelated estimation. Panel B shows coefficients (z-statistics) from multinomial logistic regressions examining the association between business STRATEGY and the timeliness of reported material weaknesses before and after implementation of Audit Standard No. 5. ***, **, and * indicate statistical significance at the 1, 5, and 10 percent levels, respectively based on two-tailed tests. 46
© Copyright 2025