How does firm-level business strategy affect internal control

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