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External Auditor Reassessment of Client Business Risk Following the Issuance of a Comment Letter by the SEC

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  • Miles B. Gietzmann
  • Angela K. Pettinicchio

Abstract

Following Arthur Andersen's conviction for obstructing justice, auditors faced a one-time significant change in their regulatory environment because it was clear that (i) major audit partnerships could be closed and (ii) post Sarbanes-Oxley Act (SOX), regulators would take a far more attentive (aggressive) role. In response auditors considered whether the pricing of audits should be revised to take account of the increased risk of regulatory intervention and litigation. Obviously such re-pricing would need to be targeted at those firms for which the risks were greatest. One early warning signal of such events occurring is the issuance by the Security Exchange Commission (SEC) of a Comment Letter (CL). We investigate whether there is any evidence that if a client receives a CL this is used to re-price audit services. Specifically, we investigate whether issuance resulted in upward pressure on audit fees, and whether this effect was simply transient around the issuance period or alternatively persisted some years into the future. This research finds that after a client receives a CL, auditors adjust audit fees upwards in the period in which the CL is received. In addition it is shown that for subsequent periods in which the auditor does not spend time assisting the client respond to a specific CL, an initial rise in audit fee persists. This is consistent with the hypothesis that auditors reassess the reputation and litigation risk of the client on the basis of the SEC issuance of a Comment Letter.

Suggested Citation

  • Miles B. Gietzmann & Angela K. Pettinicchio, 2014. "External Auditor Reassessment of Client Business Risk Following the Issuance of a Comment Letter by the SEC," European Accounting Review, Taylor & Francis Journals, vol. 23(1), pages 57-85, May.
    • Handle: RePEc:taf:euract:v:23:y:2014:i:1:p:57-85
    DOI: 10.1080/09638180.2013.774703
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    Citations

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    Cited by:

    1. Wu, Bin & Li, Anqi & Zhang, Wen, 2024. "Clients' strategic change and auditor behavior: Evidence from audit adjustments and audit fees," Advances in accounting, Elsevier, vol. 64(C).
    2. Stergios Leventis & Emmanouil Dedoulis & Omneya Abdelsalam, 2018. "The Impact of Religiosity on Audit Pricing," Journal of Business Ethics, Springer, vol. 148(1), pages 53-78, March.
    3. Liao, Feimei & Sun, Yinghao & Xu, Shulin, 2023. "Financial report comment letters and greenwashing in environmental, social and governance disclosures: Evidence from China," Energy Economics, Elsevier, vol. 127(PB).
    4. Mark E. Lokanan & Prerna Sharma, 2023. "Two Decades of Accounting Fraud Research: The Missing Meso-Level Analysis," SAGE Open, , vol. 13(3), pages 21582440231, September.
    5. Yu Flora Kuang & Gladys Lee & Bo Qin, 2021. "Whistleblowing Allegations, Audit Fees, and Internal Control Deficiencies," Contemporary Accounting Research, John Wiley & Sons, vol. 38(1), pages 32-62, March.
    6. Hong, Yun & Yao, Youfu, 2024. "Can comment letters impact excess perks? Evidence from China," International Review of Financial Analysis, Elsevier, vol. 91(C).
    7. Yunsen Chen & Yilu Deng & Yufang Jin & Hetong Lou & Xin Zhang, 2020. "Political Connection and Regulatory Scrutiny through Comment Letters: Evidence from China," International Review of Finance, International Review of Finance Ltd., vol. 20(3), pages 789-798, September.
    8. Masoud, Najeb & Al-Utaibi, Ghassan, 2022. "The determinants of cybersecurity risk disclosure in firms’ financial reporting: Empirical evidence," Research in Economics, Elsevier, vol. 76(2), pages 131-140.
    9. Yao, Youfu & Hong, Yun, 2023. "Can comment letters impact excess cash holdings? Evidence from China," International Review of Economics & Finance, Elsevier, vol. 83(C), pages 900-922.
    10. Wanyi Chen & Ning Hu & Xiangfang Zhao, 2022. "Information asymmetry, regulatory inquiry, and company mergers and acquisitions: evidence from Shenzhen Stock Exchange comment letters," Accounting and Finance, Accounting and Finance Association of Australia and New Zealand, vol. 62(2), pages 2497-2542, June.
    11. Ormazabal, Gaizka & Duro, Miguel & Heese, Jonas, 2017. "Does the Public Disclosure of the SEC’s Oversight Actions Matter?," CEPR Discussion Papers 12145, C.E.P.R. Discussion Papers.
    12. Cao, Viet Nga & Pham, Anh Viet, 2021. "Behavioral spillover between firms with shared auditors: The monitoring role of capital market investors," Journal of Corporate Finance, Elsevier, vol. 68(C).
    13. Yan Yu & Yi-Tsung Lee, 2022. "Do Inquiry Letters Curb Corporate Catering Motives of High Sustainable R&D Investment? Empirical Evidence from China," Sustainability, MDPI, vol. 14(12), pages 1-17, June.
    14. Hu, Ning & Xu, Jiayi & Xue, Shuang, 2022. "Mandatory disclosure of comment letters and analysts' forecasts," International Review of Financial Analysis, Elsevier, vol. 84(C).

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