The Materiality of Accounting Errors: Evidence from SEC Comment Letters

We gain unique insights into materiality judgments about accounting errors by examining SEC comment letter correspondence. We document that managers typically use multiple quantitative benchmarks in their materiality analyses, with earnings being the most common benchmark. In most of the cases we review, managers deem the error immaterial despite its exceeding the traditional “5 percent of earnings” rule of thumb, often in multiple periods and by a large degree. Instead of attempting to conceal these overages, managers tend to forthrightly acknowledge them, often asserting that the benchmark is abnormally low during the violation period. We find that 17–26 percent of these “low benchmark” assertions are suspect (although none of these “low benchmark” assertions are challenged by the SEC). We also document substantial variation in the extent to which qualitative factors are mentioned as considerations. The SEC generally is deferential toward managers' arguments and judgments but is more likely to challenge immateriality claims when managers admit there are qualitative factors that indicate errors are material.     

The Spillover Effect of SEC Comment Letters on Qualitative Corporate Disclosure: Evidence from the Risk Factor Disclosure

In this study we use the recently mandated risk factor disclosure to examine the spillover effect of the Securities and Exchange Commission (SEC) review of qualitative corporate disclosure. We find that firms not receiving any comment letter (“No‐letter Firms”) modify their subsequent year's disclosures to a larger extent if the SEC has commented on the risk factor disclosure of (i) the industry leader, (ii) a close rival, or (iii) numerous industry peers. We refer to this effect as “spillover.” Further, we find that after SEC comments on the industry leader's disclosure, No‐letter Firms also provide more firm‐specific disclosures in the subsequent year. The increased disclosure specificity reduces these firms’ likelihood of receiving SEC risk disclosure comments on their new filings. Our evidence suggests an indirect effect of the SEC review of qualitative disclosure.     

The Switch-Up: An Examination of Changes in Earnings Management after Receiving SEC Comment Letters

The SEC has long asserted that earnings management practices result in adverse consequences for investors. We examine whether SEC oversight affects firms' accounting quality in terms of earnings management trade-offs. We expect that increased firm-specific regulatory scrutiny, in the form of an SEC comment letter, will induce management to switch from accrual-based earnings management (AEM), which is a main focus of the SEC, to real-activities-based earnings management (REM), which is not likely to be commented on in the SEC's review process. Consistent with our predictions, we find that AEM is lower and REM is higher following the receipt of a comment letter, relative to non-comment-letter years and a propensity-score-matched sample of non-comment-letter firms. However, we do not find a significant difference in total earnings management (i.e., the sum of AEM and REM), suggesting that the higher REM acts as a substitute for lower AEM activity. We further find that our results are driven by accounting comments relating to estimates and accruals and not by classification-only comments, which suggests that a comment letter that does not question specific issues associated with estimates and accruals is not a strong enough signal to induce the firm to change earnings management behavior. Additionally, the shift to REM is attenuated for firms with high institutional ownership. These results collectively suggest that the comment letter process effectively constrains AEM but has the unintended consequence of firms, on average, switching to REM.     

年报问询函的监管溢出效应研究——来自企业集团A股上市子公司的证据

现有研究主要关注于年报问询函对被问询公司的影响。基于2015-2018年企业集团上市子公司样本,文章研究交易所问询在企业集团内是否具有监管溢出效应。实证研究发现,年报问询函在子公司间存在监管溢出效应,即企业集团内子公司被年报问询会引起其他子公司财务报告质量的提高。机制检验证明,内外部资本市场的信息传递是年报问询函溢出效应的主要原因。拓展性分析发现,当企业集团存在共同审计和实际控制人的控制链条更短时,年报问询函的监管溢出效应就越明显。文章扩展了年报问询函政策实施效果的相关研究,延伸了财务决策同群效应理论假说,为优化上市公司监管机制提供思路。     

Enforcement,Socioeconomic Diversity,and Tax Filing Compliance in the United States

In this article, we examine the determinants of tax filing compliance in the United States. We use county‐level data on non‐filing rates for the tax year 2000, obtained directly from the Internal Revenue Service. We include explanatory variables identified in the “rational compliance” framework, including an enforcement index against identified non‐filers, the audit rate of filers, and the average penalty rate for both filers and non‐filers. We also examine the role of socioeconomic diversity on tax compliance, testing whether within‐county heterogeneity in household income, language, race, and religion can help explain variation in non‐filing rates. We find that non‐filing is increasing with heterogeneity by race, although not by income or language, and that non‐filing is decreasing with heterogeneity by religious membership. As for enforcement variables, we find that non‐filing rates tend to fall with the enforcement index. Other variables have somewhat mixed results.     

Public Policy Environment and Entrepreneurial Activities: Evidence from China

What determines the effectiveness of government entrepreneurship policies on the regional development of entrepreneurial activities in China? Using panel data analysis, this study develops a comprehensive framework that examines the effects of various factors, including government efficiency and government support for business, finance and technology, on facilitating the creation of new ventures. Based on provincial data collected between 2009 and 2014, we find that the level of infrastructure development, government incubators and venture capital‐guided funds have positive and significant effects on entrepreneurial activities. The findings of our study suggest that local government efficiency is a fundamental precondition for entrepreneurship policies to effectively boost the regional economy.     

Interdependence between Overseas and Domestic R&D Activities: Evidence from Taiwanese Multinationals

The purpose of the present paper is to examine the interdependence between the overseas and domestic R&D activities of Taiwanese multinational enterprises (MNEs). Because domestic (overseas) R&D activities may enter the overseas (domestic) R&D determination equation as an endogenous right‐hand side variable, the traditional estimation approach will be invalid due to the endogeneity problem. Therefore, it is proposed that the two R&D decisions be estimated using a simultaneous Tobit model. The results in this paper indicate that Taiwanese MNEs that engage in higher levels of domestic R&D activities will engage in overseas R&D activities. Interestingly, it is also found that Taiwanese MNEs increase their overseas R&D activities in developed countries instead of their domestic R&D activities, whereas Taiwanese MNEs that engage in overseas R&D activities in less‐developed countries will raise their domestic R&D activities. As for the other common determinants of the overseas and domestic R&D activities, firm size and the capital–labor ratio are found to be the main factors.     

Linguistic and Religious Influences on Foreign Trade: Evidence from East Asia*

Using a modified gravity model and the cross‐sectional data of East Asian economies, the present paper presents evidence that supports the view that the effect of distance‐related transaction costs on trade tends to fall over time. Overall religious influence on foreign trade exists in the post‐Cold War period but not during the Cold War period. The effects of language on inter‐regional trade and of religion on intra‐regional trade both weaken over time. In all cases, religion tends to have more significant influences on intra‐regional trade than language, and language tends to exert more significant influences on inter‐regional trade than religion. Finally, from 1985 to 1995 there is an indication that: (i) English becomes more important for inter‐regional trade; (ii) Bahasa, English and Khmer become less important for intra‐regional trade; and (iii) Chinese plays an increasing role in both intra‐regional and inter‐regional trade.     

医生薪酬激励的行为和实验经济学研究进展

医疗卫生行业供给侧改革的一个重要方面是医生的诊疗服务,而医生的行为受到薪酬支付方式及其激励机制的影响。近年来实验研究方法在卫生经济学领域得到了广泛运用,并在医生薪酬激励方面取得一系列重要的研究成果。主要包括关于按服务项目付费、按人头付费和固定工资三种基本的医疗行业薪酬支付方式的实验研究,以及对绩效工资这一经济性激励手段和公开报告等非经济性激励手段展开的实验研究。文章围绕基本支付方式、经济性激励和非经济性激励等三种影响医生行为的薪酬激励机制,对相关的行为和实验经济学研究进行了较为系统地梳理。同时总结了从现有的行为和实验研究中可能得到的启示,并展望了未来可能的研究方向。     

Ambient Influences on Municipal Net Assets: Evidence from Panel Data

Governments’ net assets balances are viewed as a measure of fiscal health and have been linked to municipal credit ratings. This study explores the extent to which ambient socioeconomic factors are captured in aggregated restricted and unrestricted net assets balances (termed “liquid net assets”) to understand why such balances are relevant to credit analysts and others. We model liquid net assets balances using observable nonaccounting factors (e.g., unemployment rates) to learn whether they reflect such influences. We use panel data for fiscal years 2007–2011 so our results comprehend effects of recent economic fluctuations. We find that liquid net assets balances impound a rich array of influences, bearing a positive association with the mayor‐council form of government, community wealth, the incidence of property crimes, and increases in governments’ business‐type net assets. Liquid net assets balances bear a negative association with liabilities for postemployment benefits, unemployment, and violent crime. The results indicate that net assets balances capture noteworthy debt burden, administrative, and socioeconomic influences and, as such, have meaning beyond their basic accounting interpretation.     

Regulatory Oversight of Financial Reporting: Securities and Exchange Commission Comment Letters

The Securities and Exchange Commission (SEC) reviews company filings (10‐Q, 10‐K, S‐1, etc.) submitted to them. If a review identifies potential deficiencies, the SEC staff sends the company a comment letter seeking clarification, additional information, and ultimately, perhaps, revision of the filing or future filings. We examine the content, resolution, and ensuing informational consequences of SEC comment letters. The content analysis shows that nearly half of all comments involve accounting application, financial reporting, and disclosure issues. More than 17 percent of our sample cases result in immediate amended filings to resolve the issue(s) arising from the comment letters, and financial statements and/or footnotes are frequently revised. Following comment letter resolution, the adverse selection component of the bid‐ask spread declines and Earnings Response Coefficients (ERCs) increase. Our results provide little support for the conjecture that the market interprets the receipt of a comment letter as a signal that the firm has poor reporting quality. Finally, we find no evidence that comment letter firms increase the quantity or change the type of voluntary disclosure, thereby eliminating a possible competing explanation for the improved information environment. We conclude the SEC's oversight has beneficial informational effects.     

TMT异质性理论近十年研究回顾与评述

在人力资源管理或公司治理领域,高层管理团队异质性理论都是近些年研究的热点。文章选取1999-2009年时间段的研究内容作为综述对象,在回顾的基础上探讨和比较国内外研究的内在规律,并进行评述,进一步提出未来的研究方向。     

How Japanese firms can weather endaka periods: Evidence from the transportation equipment industry

Japan has experienced several appreciation episodes. These appreciations may squeeze profit margins and lower export volumes. This paper investigates whether firms can weather appreciation periods by producing differentiated rather than commoditized products. To do this it investigates different sectors within the Japanese transportation equipment industry. Results from estimating pricing-to-market (PTM) coefficients indicate that firms producing differentiated products can pass-through more of exchange rate appreciations into higher foreign currency prices and thus better preserve their profit margins. Results from estimating trade elasticities are consistent with the PTM results and indicate that the automobile industry has exported much less than predicted after the yen depreciated in 2012. Finally, estimates of the stock market exposure across sectors indicates that the profitability of firms producing differentiated products is less exposed to appreciations. Producing differentiated, knowledge-intensive goods can thus help firms to survive endaka periods.     

FDI如何影响本地企业出口——来自中国制造业的发现

文章从理论上分析了外资进入影响本地企业出口行为的机制,并在构造外资溢出三类指标的基础上,运用1998-2007年中国制造业企业数据实证检验了外资溢出对本地企业出口参与决策和出口规模的影响。研究表明：（1）外资企业通过行业内水平溢出和行业间前向关联溢出显著促进了本地企业的出口参与决策,并提高了本地企业的出口规模;（2）外资行业间后向关联溢出对本地企业出口参与决策的影响不明显,但扩大了已出口企业的出口规模,控制内生性后结论仍成立;（3）外资进入对本地企业出口行为的影响因外资来源地和本地企业所有制性质的不同而存在显著的差异性。     

Benefits and Costs of Auditor's Assurance: Evidence from the Review of Quarterly Financial Statements

Even though there is a worldwide consensus as to the necessity of an audit of annual financial statements for public companies, there is divergence of views as to the review of interim financial statements. While some jurisdictions make it mandatory (e.g., Australia, France, United States), others allow the review without requiring it (e.g., Canada, United Kingdom). Using a sample of companies listed in Canada, we examine the costs associated with these reviews and the benefits they generate in terms of improvement in the quality of interim financial statements for the years 2004 and 2005. Controlling for the decision to purchase the reviews, we find that audit fees are 18 percent higher for firms with interim reviews and, contrary to many regulators' assumption, we find no evidence that this cost increase is proportionally higher for smaller firms. Regarding the benefits of interim reviews, we find no significant association between either accruals‐ or nonaccruals‐based measures of earnings management and the fact that the interim statements are reviewed by the auditor, neither in the interim reports nor in those of the fourth quarter. The results suggest that auditors' involvement with interim reports may not be as effective as previously thought at controlling the quality of interim financial statements.     

How Aggressive Tax Planning Facilitates the Diversion of Corporate Resources: Evidence from Path Analysis

In measuring tunneling with intercorporate loans disclosed by Chinese listed companies, we analyze the underlying channels through which aggressive tax planning facilitates the diversion of corporate resources by firm insiders. Using path analysis, we document that the path from tax aggressiveness to related loans is mediated by both the additional cash flows from tax savings and the increased financial opacity from tax planning, and that additional cash flows plays a much more important role than opacity in helping controlling shareholders to divert corporate resources under the guise of tax aggressiveness. Beyond the two mediated paths, we also detect a residual, direct path from tax aggressiveness to related loans. After an exogenous shock from the government crackdown on diversionary related loans, we find the direct path is fully mediated by the two indirect paths, suggesting that tunneling via related loans only occurs at firms where insiders can mask tunneling under the cover of opacity or can justify related loans on grounds of abnormal cash flows from tax savings. Our evidence supports the notion that greater outside scrutiny increases the hurdle for, but does not entirely eradicate, diversion facilitated by tax aggressiveness. Collectively, our research lends some support to recent theory on the importance of taxes to corporate governance by demonstrating how the agency costs of tax planning allow certain shareholders to benefit from firm activities at the expense of others.     

制度如何激发社会合作--基于公共品博弈实验的前沿理论综述

公共品博弈作为刻画人类社会协调与合作这两个问题的基本模型,成为经济学、管理学、政治学、人类学等跨学科的研究热点和难点。通过分析引入激励制度的公共品博弈实验研究,比较奖和罚两种制度如何改变人们的信念并影响公共品合作供给行为。将已有公共品博弈实验研究分为外部激励和内部激励（决定赏罚规则、强度和执行方式的制度）、货币激励和非货币激励（道德劝说、训斥和社会排斥）,考察不同制度对于提升公共品合作供给水平的实际作用,特别是惩罚制度的社会净效率。在此基础上,述评已有研究成果的一般性结论和启示,展望有关个体偏好、社会合作和制度发育的理论和实证研究可能的创新。