The Influence of Auditor and Client Section 404 Processes on Remediation of Internal Control Deficiencies at All Levels of Severity

2013 ◽  
Vol 32 (4) ◽  
pp. 45-69 ◽  
Author(s):  
Lynford Graham ◽  
Jean C. Bedard

SUMMARY This paper examines remediation of Sarbanes-Oxley Section 404 internal control deficiencies (ICDs) at all levels of severity, before the balance sheet date. While a number of studies investigate remediation of publicly disclosed material weaknesses (MWs), the activity we study takes place out of public view and occurs among companies with both clean and adverse Section 404 opinions. Using data provided by multiple auditing firms, we find that about one-fourth of detected ICDs are remediated before year-end, leaving many uncorrected. We model remediation activity with direct measures of company and auditor Section 404 processes not available to prior research. Model results show that companies' effective information technology integration and early start to control testing are positively associated with remediation. In contrast, remediation is negatively associated with discovery by auditors, discovery by substantive tests, and related financial misstatements. Following prior research on MWs, we also observe that ICD remediation is less likely for smaller companies with greater financial risk, and for certain entity-level control problems.

2019 ◽  
Vol 16 (1) ◽  
pp. 31-45
Author(s):  
Ifeoma Udeh

Purpose This paper aims to examine the effectiveness of the Committee of Sponsoring Organization’s 2013 Framework, by investigating how the number of auditor-reported material weaknesses compares for Early-, Timely- and Late-adopters of the framework, and how the number of auditor-reported material weaknesses changed for Early- and Timely-adopters following their adoption of the framework. Design/methodology/approach The paper uses regression analyses based on a sample of US firms subject to Sarbanes-Oxley Act Section 404(b). Findings Timely-adopters of the 2013 Framework continued to exhibit fewer instances of auditor-reported material weaknesses than Late-adopters, even though they had a marginal increase in the number of auditor-reported material weaknesses, in the post-2013 Framework period. Practical implications The findings suggest that the effectiveness of the 2013 Framework may lie in the iterative nature of the internal control process, and as firms remedy deficiencies they or their auditors identify, they will continuously improve the effectiveness of their internal control systems. Originality/value Unlike existing literature, this paper uses data from the pre-2013 Framework, transition and post-2013 Framework periods to examine changes in the number of auditor-reported material weaknesses, thus differentiating between Early-, Timely- and Late-adopters of the 2013 Framework. It also shows the effect of adopting the 2013 Framework on the number of auditor-reported material weaknesses.


2008 ◽  
Vol 27 (2) ◽  
pp. 161-179 ◽  
Author(s):  
Kam C. Chan ◽  
Barbara Farrell ◽  
Picheng Lee

SUMMARY: The main objectives of the Sarbanes-Oxley Act of 2002 are to improve the accuracy and reliability of corporate disclosure. Under Section 404 of the Sarbanes-Oxley Act, the external auditor has to report an assessment of the firm’s internal controls and attest to management’s assessment of the firm’s internal controls. Material weaknesses in internal controls must be disclosed in the auditor and management reports. The objective of this study is to examine if firms reporting material internal control weaknesses under Section 404 have more earnings management compared to other firms. The results provide mild evidence that there are more positive and absolute discretionary accruals for firms reporting material internal control weaknesses than for other firms. Since the findings of ineffective internal controls by auditors under Section 404 may cause firms to improve their internal controls, Section 404 has the potential benefits of reducing the opportunity of intentional and unintentional accounting errors and of improving the quality of reported earnings.


2009 ◽  
Vol 84 (3) ◽  
pp. 839-867 ◽  
Author(s):  
Udi Hoitash ◽  
Rani Hoitash ◽  
Jean C. Bedard

ABSTRACT: This study examines the association between corporate governance and disclosures of material weaknesses (MW) in internal control over financial reporting. We study this association using MW reported under Sarbanes-Oxley Sections 302 and 404, deriving data on audit committee financial expertise from automated parsing of member qualifications from their biographies. We find that a lower likelihood of disclosing Section 404 MW is associated with relatively more audit committee members having accounting and supervisory experience, as well as board strength. Further, the nature of MW varies with the type of experience. However, these associations are not detectable using Section 302 reports. We also find that MW disclosure is associated with designating a financial expert without accounting experience, or designating multiple financial experts. We conclude that board and audit committee characteristics are associated with internal control quality. However, this association is only observable under the more stringent requirements of Section 404.


2012 ◽  
Vol 32 (2) ◽  
pp. 171-188 ◽  
Author(s):  
Vishal Munsif ◽  
K. Raghunandan ◽  
Dasaratha V. Rama

SUMMARY: Hermanson and Ye (2009; hereafter, HY) find that in the initial year of SOX Section 404 implementation, only 27 percent of accelerated filer firms with an adverse Section 404(b) report had disclosed such material weaknesses (MWs) in internal control in Section 302 certifications in previous quarters of the same fiscal year. We extend HY by examining (1) a more recent time period (using data from fiscal years 2007 and 2008), and (2) both accelerated and non-accelerated filers. We find that the proportion of accelerated filers (with adverse Section 404 reports) that have early warnings (in Section 302 certifications in previous quarters of the same fiscal year) is less than 50 percent even in the fourth and fifth years of Section 404 reporting. We also find that, after controlling for other factors, non-accelerated filers were more likely to have early warnings than accelerated filers in 2008; however, the difference is not significant in 2007. Early warning is more likely for firms with (1) a higher number of MWs, (2) a new CFO, (3) more audit committee members, and (4) more frequent audit committee meetings.


2009 ◽  
Vol 23 (2) ◽  
pp. 1-23 ◽  
Author(s):  
Bonnie K. Klamm ◽  
Marcia Weidenmier Watson

ABSTRACT: This paper examines internal controls, from both an information technology (IT) and non-IT perspective, in relation to the five components of the Committee of Sponsoring Organization's Internal Control-Integrated Framework (COSO 1992), as well as the achievement of one of COSO's three objectives-reporting reliability. Our sample consists of 490 firms with material weaknesses reported under Sarbanes-Oxley Section 404 during the first year of compliance. We classify the weaknesses by COSO component and as IT-related or non-IT-related. Our results support the interrelationships of the COSO Framework. The results also show that the number of misstated accounts is positively related to the number of weak COSO components (i.e., scope) and certain weak COSO components (i.e., existence). Firms with IT-related weak components report more material weaknesses and misstatements than firms without IT-related weak components, providing evidence on the pervasive negative impact of weak IT controls, especially in control environment, risk assessment, and monitoring.


2013 ◽  
Vol 33 (1) ◽  
pp. 93-116 ◽  
Author(s):  
Emma-Riikka Myllymäki

SUMMARY This study examines whether Sarbanes-Oxley (SOX) Section 404 material weakness (MW404) disclosures are predictive of future financial reporting quality. I find evidence that for companies with a history of MW404s, the likelihood of misstatements in financial information continues to be significantly higher for two years after the last MW404 report compared to companies without a history of reported MW404s. The magnitude of the effect decreases non-linearly with decreasing speed. The findings further imply that the reason for the misstatement incidences is the unacknowledged pervasiveness of control problems. In particular, it appears that in many cases, the future misstatements are unrelated to the MW types disclosed in the last MW404 report, suggesting that some MW types are unacknowledged and, hence, control problems are even more pervasive than what was identified. Overall, the findings of this study highlight the importance of discovering and disclosing material weaknesses in internal control over financial reporting.


2011 ◽  
Vol 86 (1) ◽  
pp. 287-323 ◽  
Author(s):  
Shu Lin ◽  
Mina Pizzini ◽  
Mark Vargus ◽  
Indranil R. Bardhan

ABSTRACT: This study investigates the role that a firm’s internal audit function (IAF) plays in the disclosure of material weaknesses reported under Section 404 of the Sarbanes-Oxley Act of 2002 (U.S. Congress 2002). Using data from 214 firms, we examine the relation between material weakness (MW) disclosures and various IAF attributes and activities. Our results indicate that MW disclosures are negatively associated with the education level of the IAF and the extent to which the IAF incorporates quality assurance techniques into fieldwork, audits activities related to financial reporting, and monitors the remediation of previously identified control problems. The timing of Section 404 work and the nature of follow-up monitoring suggests that these aspects of IAF quality help prevent MWs from occurring. We find that MW disclosures are positively associated with the IAF practice of grading audit engagements and external-internal auditor coordination, suggesting that these activities increase the effectiveness of Section 404 compliance processes.


2012 ◽  
Vol 31 (3) ◽  
pp. 203-218 ◽  
Author(s):  
Vishal Munsif ◽  
K Raghunandan ◽  
Dasaratha V. Rama

SUMMARY Internal control reporting continues to be of significant interest to regulators and legislators, as evidenced by the internal control-related requirements of the Dodd-Frank Act (2010) and the JOBS Act (2012) to exempt smaller firms from the requirements of Section 404. We extend prior research on the association between internal control weaknesses and audit report lag by (1) using data from 2008 and 2009, (2) comparing accelerated and non-accelerated filers, and (3) examining the impact of remediation of previously disclosed internal control problems. We find that (1) in 2008, the increase in audit report lag in the presence of material weaknesses in internal control is lower for non-accelerated filers as compared to accelerated filers, and (2) while the effect of a material internal control weakness on audit report lag is significantly lower in 2009 than in 2008 for accelerated filers, there is no such change for non-accelerated filers. We also find that for firms remediating previously disclosed internal control problems, there is a significant decline in audit report lag; yet, the remediating firms continue to have higher reporting lags than firms that had clean Section 404 opinions in both years. We also find that, at least with respect to the effect of internal control problems on audit report lag, the “small accelerated filers” (defined as those with market capitalization less than $250 million) are treated by the auditors as being (1) substantively similar to other accelerated filers, and (2) quite distinct from non-accelerated filers.


2015 ◽  
Vol 29 (4) ◽  
pp. 917-942 ◽  
Author(s):  
Lynford Graham ◽  
Jean C. Bedard

SYNOPSIS Prior research, using data from Sarbanes-Oxley Act Sections 302/404 (SOX, U.S. House of Representatives 2002) disclosures, finds that material weaknesses (MWs) in internal controls over financial reporting of taxes are more frequent and consequential than other account-specific MWs. Understanding internal control deficiencies (ICDs) in tax reporting is important but public information is limited, as MWs comprise only control flaws remaining unremediated at year-end and few details on their nature are available from SEC filings. We supplement prior studies by providing a detailed look at all Section 404 control deficiencies in tax reporting in a proprietary sample of engagements in 2004–2005 from several large auditing firms. We find that tax ICDs are less likely to be remediated between discovery and fiscal year-end, more likely to be severe, and more likely to have caused a financial misstatement. Remediation failure for tax ICDs is greater when management missed detecting the problem, and more prevalent for poorly designed controls, controls over the tax provision, and monitoring control activities. Auditors' severity classifications imply that ICDs relating to the tax provision and deferred taxes, and those that failed in operation, have higher potential for producing misstatements. Overall, our results underscore the importance of auditor involvement in internal control reporting in the tax area. Data Availability: Data used for this study were provided under confidentiality agreements, and cannot be shared.


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