A content analysis of CPA firms’ correspondence following PCAOB inspections: 2004–2010

The Public Company Accounting Oversight Board (PCAOB) has conducted well over 1000 inspections of public accounting firms since 2004, the year their inspections began. The PCAOB inspections are mandated by the Sarbanes–Oxley Act of 2002, and are designed to promote high professional audit standards and improve the audit quality of registered public accounting firms (U.S. House, 2002). Since then, a growing body of research has emerged focusing on the process, results, and decision implications of the inspections. Most of the research to date has focused on determining the impact of the inspection regimen from the perspective of regulators, clients, or markets, but there has been very little research focused on the effect of inspections on the accounting firms themselves.We evaluate the letters provided by triennial audit firms (100 or fewer issuer clients) to the PCAOB in response to their inspections. The response letters provide insight into what the firms themselves think about the value of the inspection and the results of the inspections. Our study and its findings are particularly timely in light of the PCAOB Chairman James Doty’s recent speech (Doty, 2011) in which he claimed that deficiencies were concrete instances of audit failure, and sharply criticized the responses of many audit firms who received inspection deficiency reports, most of whom maintain that their deficiency finding resulted from either differences in professional judgment or inadequate documentation, or both (but not audit deficiencies).We find that a majority of firms writing response letters (1) state they support the PCAOB’s objective of improving audit quality and (2) believe the inspection process will lead to higher audit quality. However, a substantial majority of firms that had an audit engagement deficiency disagreed with the PCAOB’s evaluation, citing differences in professional judgment and/or documentation issues. Our findings do not support but run counter to the PCAOB Chairman’s criticisms and insistence that inspection deficiencies are not attributable to professional judgment differences.     

The impact of PCAOB international registration on audit quality and audit fees: Evidence from China

Despite the importance of registration with the PCAOB, there is surprisingly little academic research on the registration process and its impact on audit outcomes (Abernathy et al., 2013). The PCAOB allows registration of audit firms from non-US countries. However, China and a few other countries do not allow the PCAOB to conduct inspections of audit firms. We take advantage of this setting to investigate whether PCAOB-registered audit firms improve audit quality in the absence of inspections and whether they charge an audit fee premium. Our findings indicate that audit quality increases following PCAOB registration and that clients pay higher audit fees for audits by PCAOB-registered firms.     

Do PCAOB Inspections Improve the Accuracy of Accounting Estimates?

Despite issuing extensive guidance related to the evaluation of accounting estimates, the PCAOB continues to identify deficiencies related to the audit of estimates through their inspections process. We examine whether PCAOB inspections lead to more accurate audited accounting estimates, defined as those that more closely match economic reality, by examining a significant estimate within the banking industry. We find that in contrast with the PCAOB's goal of more accurate and unbiased estimates, allowance for loan losses (ALL) estimates become less accurate and more conservative with higher levels of ALL‐related inspection findings for public company audits. We find no evidence of auditor response to PCAOB inspection findings for private‐company audits, which are not subject to PCAOB inspection. Overall, our findings cast doubt on the efficacy of PCAOB inspections in improving estimate accuracy and suggest that firms are managing inspection risk to the potential detriment of audit quality.     

Do PCAOB Inspections Improve the Quality of Internal Control Audits?

We investigate whether Public Company Accounting Oversight Board (PCAOB) inspections affect the quality of internal control audits. Our research design improves on prior studies by exploiting both cross‐sectional and time‐series variation in the content of PCAOB inspection reports, while also controlling for audit firm and year fixed effects, effectively achieving a difference‐in‐differences research design. We find that when PCAOB inspectors report higher rates of deficiencies in internal control audits, auditors respond by increasing the issuance of adverse internal control opinions. We also find that auditors issue more adverse internal control opinions to clients with concurrent misstatements, who thus genuinely warrant adverse opinions. We further find that higher inspection deficiency rates lead to higher audit fees, consistent with PCAOB inspections prompting auditors to undertake costly remediation efforts. Taken together, our results are consistent with the PCAOB inspections improving the quality of internal control audits by prompting auditors to remediate deficiencies in their audits of internal controls.     

The effect of small audit firms’ failure to remediate the PCAOB’s quality control criticisms on audit market segmentation

This paper examines the role of the Public Company Accounting Oversight Board (PCAOB) quality control inspection program on market segmentation of small firms’ audit services. Specifically, we investigate how non-remediation of quality control criticisms (QCCs) affects the supply and demand of low-quality audits. We find that remediation of QCCs improves audit quality for small accounting firms. However, some small accounting firms do not remediate QCCs (NR firms) and continue to provide low audit quality. We investigate how NR clients react to the disclosure of non-remediation of QCCs. We find that NR clients with low agency costs are more likely to retain NR firms after the disclosure of non-remediation. This finding is consistent with our expectation that voluntary QCC remediation creates a low-quality audit market segment for NR firms. Our findings suggest that the public disclosure of QCCs is not sufficient to remove low-quality auditors. Instead, NR clients use the disclosure of non-remediation of QCCs as a signal to sort themselves into segments based on their demand for audit quality. We are the first to study and find that PCAOB inspections, and specifically the voluntary nature of remediation and public disclosure of lack of remediation, create market segmentation.     

Auditors’ Use of In-House Specialists

Using Public Company Accounting Oversight Board (PCAOB) inspection data from 2006 to 2018, we examine the use of auditor-employed specialists in audit engagements. First, we find that the use of specialists is increasingly prevalent and related to clients’ size and complex accounting estimates. Second, the use of specialists is positively associated with the incidence of audit process deficiencies (identified by PCAOB inspections) but is not associated with output-based audit-quality proxies (restatements or absolute discretionary accruals). Hence, although process deficiencies are more likely to occur in engagements with higher use of specialists, financial reporting quality is not negatively impacted. Third, the use of specialists is positively associated with the likelihood of goodwill impairments and negatively associated with engagement profitability. Finally, cross-sectional tests suggest that board accounting expertise is a salient condition for more effective use of specialists. Collectively, our findings align with concerns noted by the PCAOB and prior experimental and survey studies. Although specialists assist auditors with the audit of complex estimates, engagements with comparatively high specialist use entail an incremental risk of audit process deficiencies.     

The cost stickiness of information technology material weaknesses: An intertemporal comparison between it-related and other material weaknesses

The PCAOB's audit firm inspections drive audit focus and costs. The PCAOB's 2010-initiated increased emphasis on internal control audit work intensified concern over internal control weaknesses (ICW). IT-related material weaknesses (ITMW) have emerged as particularly significant with PCAOB reports (2008, 2012) highlighting on-going deficiencies in IT controls auditing and the 2015 PCAOB brief noting an on-going focus on recurring audit deficiencies. We explore how ICW affect audit fees and how alternative types of ITMW lead to varying degrees of persistence in fee premiums. Using propensity score matched samples, we find fee premiums associated with ITMW linger longer than premiums for non-IT entity-level material weaknesses (ELMW) or firms reporting account-specific material weaknesses. Moreover, we find that audit fee premiums by type of ICW remediated is overall strongest for ITMW linked to data processing integrity. Our findings underscore the importance of distinguishing not only between non-IT ELMW and ITMW but also types of ITMW as identified in data quality research.     

PCAOB inspection reports and audit quality

With the creation of the Public Company Accounting Oversight Board (PCAOB), audit firm oversight shifted away from self-regulation to independent regulation. The inspections program is the central feature of the PCAOB. We examine whether PCAOB inspections are able to distinguish actual audit quality (as opposed to perceived) during the period inspected to better understand this important regulatory tool. We use three measures that proxy for actual audit quality: abnormal accruals, restatements, and the propensity to issue a going concern opinion. For triennially inspected auditors, we find that PCAOB inspections are associated with lower audit quality when the reports are seriously deficient (weaker results for deficient reports). More specifically, we find clients of triennially inspected auditors that receive a deficient or seriously deficient report are associated with significantly higher abnormal current accruals and clients of auditors that receive a seriously deficient report are associated with a greater propensity to restate. Our evidence is subject to the caveat that PCAOB reports for triennially inspected auditors do not capture the going concern aspect of audit quality. For annually inspected auditors, the results are conflicting and suggest PCAOB inspection reports do not distinguish audit quality during the period inspected for annually inspected auditors.     

The effect of disclosing audit quality control deficiencies on non-audit tax services: Evidence from Deloitte’s 2007 PCAOB Part II inspection report

We examine whether public disclosure of Deloitte 2007 PCAOB Part II report, which identifies quality control deficiencies related to audits of income tax accounts, affects Deloitte’s auditor-provided tax services (APTS). Using a difference-in-differences model, we document a 17 percent lower likelihood of Deloitte’s audit clients employing APTS relative to clients of other annually inspected firms when the report is made public. We also find that the dampening effect of publicly disclosing the Part II report on Deloitte’s APTS is more evident among audit clients paying higher non-audit fees to auditors and those with more complex tax planning. These results suggest that revealing income tax-specific quality control deficiencies prompts audit clients to revise upward (downward) their expected costs (benefits) of perceived auditor independence impairment (knowledge spillover) stemming from APTS. Overall, our study suggests that public disclosure of audit firm-wide quality control deficiencies pertaining to audits of income tax accounts imposes a collateral damage to the inspected firm’s non-audit tax services, thereby providing a more complete understanding of the consequences of the PCAOB’s communications about quality control deficiencies in Part II reports.     

The Unintended Consequences of the Frequency of PCAOB Inspection

After more than 50 years of self‐regulation of the US auditing profession, the Sarbanes‐Oxley Act of 2002 (SOX) created the Public Company Accounting Oversight Board (PCAOB) as a quasi‐governmental entity with statutory authority to inspect accounting firms that audit public clients. The frequency of this inspection is annual or triennial, based upon the number of public clients the firm audits. We examine the effects of these two levels of inspection frequency on financial reporting quality and audit fees for clients of small and midsize public accounting firms. Our findings provide evidence of significantly higher audit quality and audit fees for clients of annually inspected firms relative to clients of triennially inspected firms. These findings are robust to auditor‐client alignment analyses, propensity score matching, time‐series analyses, examination of firms that have changed from triennial to annual inspection, and particular examination of firms with inspection deficiencies. Overall, our study suggests that the two‐tier frequency system of PCAOB inspection may have also resulted in two‐tier audit quality and audit fee systems for small and midsize public accounting firms, with more frequent inspection leading to more rigorous and informed auditor decisions. We discuss the implications of our results for the Board and the profession at large.     

Does the signature of a CPA matter? Evidence from Taiwan

This paper employed aquestionnaire survey to investigate the opinions of audit report stakeholders in Taiwan regarding the regulation of signatures in audit reports. The Public Company Accounting Oversight Board (PCAOB) proposed these regulations in 2009, and again in 2011 with a slight alteration. Most respondents agree that having the engagement partner sign the audit report could increase the accountability of CPAs. In addition, the participants believed that knowledge of the name of the engagement partner is important for the users of audit reports. Both of these views are consistent with the views voiced by the PCAOB. Most of the respondents also believe that the regulation of signatures would increase the legal responsibility of the engagement partner and minimize the role of firms in the auditing process. Finally, the respondents felt that the engagement partner has a much greater responsibility when their signature is in the audit report than when it is disclosed elsewhere, indirectly supportingthe second proposal of the PCAOB, which, rather than having the engagement partner sign their name on the audit report, simply lists the names of engagement partners elsewhere.     

The effect of SOX on small auditor exits and audit quality

We find that over six hundred auditors with fewer than 100 SEC clients exit the market following SOX. Compared to the non-exiting auditors, the exiting auditors are lower quality, where quality is gauged by: (1) avoidance of AICPA peer reviews and failure to comply with PCAOB rules, and (2) severity of the peer review and inspection reports. In addition, clients of exiting auditors receive higher quality auditing from successor auditors, as captured by a greater likelihood of receiving going concern opinions. Our results suggest that the PCAOB inspections improve audit quality by incentivizing low quality auditors to exit the market.     

Audit quality indicators: Perspectives from Non-Big Four audit firms and small company audit committees

Through a combined study, we explore the professional perspectives of two distinct PCAOB constituent groups related to the PCAOB's proposed regulatory approach for audit quality indicators. First, we examine the comment letters of Non-Big Four audit firms and find that this specific constituent group views most of the PCAOB's proposed audit quality indicators as infeasible and redundant. Further, Non-Big Four audit firms contend that the indicators require greater clarification from the regulator as well as substantial accompanying qualitative context to avoid misinterpretation that may lead to unintended consequences. Second, we survey a collection of audit committee members from small, publicly-traded companies regarding the current evaluation and perceived effectiveness of eleven specific PCAOB audit quality indicators, each of which is well-established in the extant audit quality literature. We find indicators related to auditor personnel with specialized skill and knowledge, experience of audit personnel, and the timely reporting of internal control issues are perceived to possess the highest level of effectiveness in the evaluation of audit quality.     

Alternatives for addressing major challenges in teaching introductory auditing courses

Due to the numerous and extensive recent changes in business, regulatory, and auditing environments, instructors are faced with difficult choices when designing an introductory auditing course that sufficiently meets the needs of students and the firms that will employ them. Instructors whose students are primarily hired by firms that audit SEC registered companies, for example, might allocate significant class time to PCAOB Auditing Standard No. 5 [Public Company Accounting Oversight Board (2007). Board proposes new standard on internal control over financial reporting. www.pcaob.com]. On the other hand, instructors whose students are primarily hired by firms that audit non-SEC registered companies, might allocate significant class time to reviews and agreed-upon procedure services. This paper presents four alternatives for designing introductory auditing courses, and discusses some of the major issues and constraints that instructors should consider in choosing which alternative best suits their needs. Finally, the paper provides an example that illustrates the differences among the four alternatives by discussing how each might incorporate one such specific regulatory change—PCAOB Auditing Standard No. 5.     

The credibility of self-regulation: Evidence from the accounting profession's peer review program

Following the Sarbanes–Oxley Act, self-regulated peer reviews at accounting firms were replaced by independent inspections conducted by the Public Company Accounting and Oversight Board. Critics of self-regulation had argued that the peer review program lacked credibility. This paper tests whether the opinions issued by the peer reviewers provided credible information to clients about audit firm quality. We find audit firms gained clients after receiving clean opinions from their reviewers and lost clients after receiving modified or adverse opinions. This suggests peer review opinions provided credible information about quality differences between audit firms.     

Comparing self-regulation and statutory regulation: Evidence from the accounting profession

The accounting profession in the United States recently shifted from self-regulation by peer review to statutory regulation by the Public Company Accounting Oversight Board (PCAOB). Using this shift, I compare outcomes from self-regulation and statutory regulation for the same group of firms. I find that firms choosing their own reviewers, and firms choosing reviewers likely to be connected through prior relationships, tend to receive peer review opinions more favourable than their subsequent PCAOB reports, suggesting that some firms obtained ‘friendly’ reviews in the peer review era. On the other hand, reviewers with relevant industry knowledge are less likely to give such favourable reviews. Further, reviewers from the same geographic area are likely to give peer reviews that are more negative than the subsequent PCAOB reports. Additional analysis suggests that peer reviewers from similar industry or geographic areas bring greater firm-specific expertise to the reviewing process. In the PCAOB regime, I find that firms inspected later tend to receive PCAOB reports more favourable than their peer reviews, suggesting some trends over time in PCAOB reporting. Overall, the findings help in understanding the influences on each approach to regulation, and suggest a nuanced understanding of both approaches as having strengths as well as weaknesses.     

FRC intervention,financial reporting quality and due diligence

This study provides evidence of the relationship between government intervention, financial reporting quality and due diligence. Specifically, the authors examine the consequences of the disclosure of inspection reports by the Financial Reporting Council (FRC) for individual audit firms inspected in the UK. Using a difference-in-differences design, it is found that clients are more likely to receive qualified audit opinions during the post-disclosure period. This significant impact on reporting decisions is more concentrated among clients of small audit firms. Moreover, despite general efficiency during the sample period, clients affected by an FRC intervention experience longer delays in receiving their audit reports. Overall, this study contributes to literature on corporate governance and audit regulation, and has implications for policy making. FRC inspections are of greater concern to small audit firms than large firms, as the latter have already built a strong reputation. In general, the transparent inspection process may be beneficial in enhancing auditor oversight.     

U.S. Audit partner identification and auditor reporting

After a lengthy and protracted debate, the Public Company Accounting Oversight Board (PCAOB) adopted new rules requiring disclosure of the engagement partner’s name and information about other accounting firms on the new PCAOB Form AP, Auditor Reporting of Certain Audit Participants. We investigate the impact of this regulation on auditor behavior in the context of the auditor’s going concern report modification propensity. We document an increase in the propensity to issue a going concern report modification in the disclosure regime, accompanied by a corresponding increase in the Type I (‘false positives’) error rate. Thus, an unintended consequence of Rule 3211 is the potential reduction in the audit report's informativeness. Conceivably, a more significant repercussion is that going concern modifications can hasten bankruptcy for firms since financial institutions may be reluctant to lend money to firms with modified audit reports. An unjustified increase in the going concern modification rate as evinced in our paper may make U.S. capital markets potentially less attractive to young, upstart, albeit financially-distressed, companies.     

Group audits: Are audit quality and price associated with the Lead auditor’s decision to accept responsibility?

Lead auditors frequently rely on work performed by Other auditors, especially when auditing clients with operations in multiple countries. The PCAOB has expressed concern that the quality of such group audits may differ depending on whether the Lead auditor accepts or declines responsibility for work done by Other auditors. The PCAOB also has been concerned with the venue through which Lead auditors and Other auditors disclose their participation in group audits, including disclosure of whether Lead auditors accept or decline responsibility. To investigate these issues, we employ a sample consisting entirely of group audit engagements. We identify Lead auditors taking responsibility from PCAOB Form 2, filed by Other auditors of U.S. registrants for fiscal years 2009 to 2017. We identify Lead auditors not accepting responsibility from audit report disclosures during the same period. The results suggest that Lead auditors accepting responsibility charge higher audit fees but provide audits of no higher quality, and possibly of even lower quality. These results are robust to various additional analyses. Our research contributes to the ongoing debate over how the participation of Other auditors affects audit quality.     

The effect of non-audit services on client risk, acceptance and staffing decisions

The Sarbanes Oxley Act of 2002 prohibited auditing firms from providing certain non-audit services to audit clients and left open the possibility that other currently non-prohibited services could also be banned. This prohibition hinges, in part, on regulatory concerns that auditors were willing to accept prospective higher risk clients in order to obtain more profitable non-audit service engagements. Accounting firms rejected this claim. Given the prospect that more non-audit services could be prohibited, we revisit this debate by examining these competing claims in an experiment in which we manipulate risk and the potential to sell non-audit services and then observe the impact of these variables on auditors’ client acceptance and subsequent staffing decisions. Specifically, audit partners received client information and were asked to make an acceptance decision and propose a staffing plan for a potential engagement. We find that a higher (lower) level of risk decreased (increased) the likelihood of acceptance and this relation did not vary with the potential to provide non-audit services. These results do not support the regulators’ claims but are consistent with the firms’ claims. Further, we found that more experienced auditors were assigned to the prospective client whose management had lower integrity. This staffing plan is consistent with a risk adaptation strategy for the client with lower integrity. The prohibition of certain non-audit services has been justified on the grounds that auditors might engage in systematic opportunistic behavior. However, our results do not find such behavior which should inform the current PCAOB deliberation over whether additional services should be banned. Alternatively, different justification must be found for the prohibitions.