Guiding Through the Fog: Financial Statement Complexity and Voluntary Disclosure Wayne Guay guay@wharton.upenn.edu Delphine Samuels dels@wharton.upenn.edu Daniel Taylor dtayl@wharton.upenn.edu The Wharton School University of Pennsylvania Draft: September 25, 2015 Abstract: A growing literature documents that complex financial statements negatively affect the information environment. In this paper, we examine whether managers use voluntary disclosure to mitigate these negative effects. Employing traditional cross-sectional and within-firm designs, we find a robust positive relation between financial statement complexity and subsequent voluntary disclosure. This relation is stronger when liquidity decreases around the filing of the financial statements, is stronger when firms have more outside monitors, and is weaker when firms have poor performance and greater earnings management. We also examine the relation between financial statement complexity and voluntary disclosure using two quasi-natural experiments. Employing a generalized difference-in-differences design, we find firms affected by the adoption of complex accounting standards (e.g., SFAS 133 and SFAS 157) increase their voluntary disclosure to a greater extent than unaffected firms. Collectively, these findings suggest managers use voluntary disclosure to mitigate the negative effects of complex financial statements on the information environment. JEL classification: D82; D83; G14; M41; M45; Keywords: financial statement complexity; voluntary disclosure; information environment _______________ We thank The Wharton School for financial support. Additionally, we thank an anonymous referee, Brad Badertscher, Mary Barth, Brian Bushee, Kimball Chapman, Luzi Hail, Michelle Hanlon (co-editor), Mirko Heinle, Bradford Hepfer, John Kepler, Caleb Rawson, Katherine Schipper, Cathy Schrand, David Tsui, Andy Van Buskirk, Ro Verrecchia, Joanna Wu (co-editor), and seminar participants at the 2015 AAA annual meeting, the 2015 Penn State Accounting Research Conference, the 2015 University of Colorado Summer Accounting Research Conference, the University of Rochester and The Wharton School for helpful comments. “I am raising the question here and internally at the SEC as to whether investors need, and are optimally served, by the detailed and lengthy disclosures about all of the topics that companies currently provide in the reports they are required to prepare and file with us. […] In some cases, lengthy and complex disclosure may indeed be a direct result of the Commission’s rules.” – SEC Chair Mary Jo White, speech to the National Association of Corporate Directors, October 15, 2013 1. Introduction Financial statements provide a structured medium for firms to disclose accounting information and to supply discussion and analysis that explains financial results. However, the growing complexity of accounting rules and explanatory language surrounding firms’ financial statements has led to concerns about the effectiveness of these disclosures in communicating information to shareholders. Many scholars and practitioners argue that the increasing complexity of these disclosures makes it difficult for management to bring any given item to investors’ attention (e.g., Bloomfield, 2002; Hirshleifer and Teoh, 2003; Miller, 2010; KPMG, 2011). Consistent with these arguments, a growing literature documents that complex financial statements negatively affect the information environment. For example, experimental and empirical evidence suggests that both professional and non-professional investors fail to internalize information in complex financial statements, and that more complex financial statements reduce price efficiency and increase uncertainty.1 With respect to managing their information environment, firms have at their disposal a variety of disclosure mediums beyond financial statements that can be used to achieve an optimal information environment (e.g., management forecasts, 8-K filings, press releases). While the literature noted above documents the potential negative effects of complex financial statements, 1 For experimental evidence, see Hirst and Hopkins (1998), Maines and McDaniel (2000), and Hobson (2006); for a review see Libby et al. (2002). For empirical evidence, see You and Zhang (2009), Miller (2010), Lehavy et al. (2011), Lee (2012), Bonsall and Miller (2013), Callen et al. (2013), Lawrence (2013), Loughran and McDonald (2014), Bozanic and Thevenot (2015), and Lang and Stice-Lawrence (2015). 1 it does not explore whether managers use alternative disclosure channels to mitigate these effects. We analyze the relation between financial statement complexity and subsequent voluntary disclosure using both traditional cross-sectional and within-firm designs as well as two quasi-natural experiments. Across all tests, we find that managers release more frequent and timely voluntary disclosures when their financial statements are more complex. Collectively, our findings suggest that managers use voluntary disclosures to mitigate the negative effects of complex financial statements on the information environment. Theoretically, the relation between financial statement complexity and voluntary disclosure depends on how the complexity arises. On the one hand, complex financial statements might reflect an intentional choice by managers to obfuscate and hide information from investors, for example poor performance (e.g., Li, 2008). In this case, managers choose to accept the negative effects of financial statement complexity (as their personal benefits from a low quality information environment exceed the costs) and are not expected to provide investors with supplemental information outside of the required financial report. In this case, we expect no relation––or perhaps even a negative relation––between financial statement complexity and voluntary disclosure. On the other hand, complex financial statements might reflect the complexity of the firm’s business transactions (“business complexity”) and associated reporting standards (“reporting complexity”).2 In this case, the negative effects of financial statement complexity do not reflect an intentional choice by managers. Consequently, if the complexity of the financial statements causes the quality of the information environment to decline, economic theory suggests managers will use other disclosure channels to improve the information environment (e.g., Jung and Kwon, 1988; Verrecchia, 1990). For example, when firms engage in complex 2 See for example, Bloomfield (2008) and Bushee et al. (2015). 2 transactions or apply complex reporting standards, investors may have difficulty understanding the content of the 10-K. Observing these difficulties (or perhaps in some cases anticipating them), managers may provide additional disclosures to help investors understand the performance implications of these transactions. In this case, we expect a positive relation between financial statement complexity and voluntary disclosure. We examine the relation between financial statement complexity and voluntary disclosure using multiple measures of these constructs and using three distinct sets of tests. Following prior literature, we measure financial statement complexity using the readability and length of the firm’s 10-K filing (e.g., Li, 2008), and we measure voluntary disclosure using the frequency and immediacy of management forecasts (e.g., Balakrishnan et al., 2014a; Balakrishnan et al., 2014b).3 In subsequent analyses, we confirm that our results are robust to using alternative measures of financial statement complexity and to using the frequency and immediacy of 8-K filings as alternative measures of voluntary disclosure (e.g., Leuz and Schrand, 2009; Balakrishnan et al., 2014b). In the first set of tests, we examine the relation between financial statement complexity and subsequent voluntary disclosure using both traditional cross-sectional and within-firm designs. A key advantage of using a within-firm design is that it helps alleviate concerns that our measures of financial statement complexity capture omitted firm-specific characteristics (e.g., industry practices). We find robust evidence that complex financial statements are associated with more frequent and more immediate management forecasts over periods ranging from one month to twelve months after the filing of the 10-K. 3 With regard to financial statement complexity, an extensive prior literature uses both readability and length of the firm’s 10-K to measure financial statement complexity, and finds these measures are positively associated with information processing costs (e.g., You and Zhang, 2009; Miller, 2010; Lehavy et al., 2011; Lee, 2012; Bonsall and Miller, 2013; Lawrence, 2013; Bozanic and Thevenot, 2015). With regard to voluntary disclosure, management forecasts are generally considered to be among the most informative forms of voluntary disclosure (see Beyer et al., 2010 for a review). 3 We assess the robustness of these results to controlling for voluntary disclosure issued prior to the 10-K and to time trends in both financial statement complexity and voluntary disclosure. We find (i) a positive relation between financial statement complexity and voluntary disclosure immediately before the 10-K filing, and (ii) an incremental positive relation between financial statement complexity and voluntary disclosure after the filing. These findings suggest that managers appear to anticipate some––but not all––of the information problems related to complex financial statements. We also find (iii) that our results are robust to estimating annual cross-sectional regressions, and (iv) that the relation between financial statement complexity and voluntary disclosure is strongest after RegFD. These findings suggest that our results are robust to controlling for time-trends in financial statement complexity and voluntary disclosure, and are consistent with the notion that prior to RegFD, managers could use an alternative channel (“selective disclosure”) to clarify information in financial statements. In our second set of tests, we examine cross-sectional variation in the relation between financial statement complexity and voluntary disclosure. In particular, we examine how this relation varies with: (1) the change in liquidity at the time the 10-K is filed, (2) the intensity of external monitoring, and (3) firm performance and earnings management. Such tests are helpful because, although our main tests examine voluntary disclosure locally around 10-K filings, one might still harbor a concern that a correlated omitted variable (e.g., a merger) might explain both complexity of the financial statements and the demand for voluntary disclosure. Testing multiple predictions, and finding consistent evidence across these predictions, makes it less likely that our collective results are attributable to alternative explanations. We find that the relation between financial statement complexity and voluntary disclosure is stronger when there is a greater reduction in liquidity around the filing of the 10-K, and when firms have more outside monitors. We also find that the relation between financial 4 statement complexity and voluntary disclosure is weaker when firms have poor performance and greater earnings management. Collectively, these findings suggest that managers give specific consideration to the informational problems created by complex financial statements, and suggest that the positive relation between financial statement complexity and voluntary disclosure is strongest (weakest) in settings where managers have greater (lesser) incentives to mitigate the informational problems created by complex financial statements. In our third set of tests, we examine the relation between financial statement complexity and voluntary disclosure using two quasi-natural experiments. Specifically, we use a generalized difference-in-differences design to examine changes in voluntary disclosure around the adoption of SFAS 133 (Accounting for Derivatives) and the adoption of SFAS 157 (Fair Value Measurements). The advantages of this analysis are two-fold. First, because these are two of the more complex accounting standards (KPMG, 2011), this analysis allows us to validate that our text-based measures of financial statement complexity reflect, at least in part, the complexity of the underlying accounting rules. Second, we can use the adoption of these accounting standards to isolate the effect of reporting complexity on financial statement complexity, and in turn voluntary disclosure. These tests provide additional direct evidence on whether managers give specific consideration to the informational problems created by complex accounting standards. We find that the adoptions of both SFAS 133 and SFAS 157 are associated with an increase in financial statement complexity for affected firms, and in turn, an increase in the firms’ voluntary disclosure. These results suggest managers give specific consideration to the complexity of accounting standards, and help alleviate concerns that a correlated omitted variable explains both complexity of the financial statements and the demand for voluntary disclosure (e.g., that a merger may increase the complexity of the 10-K filing and simultaneously create a demand for voluntary disclosure). To explain our results, an omitted variable would need 5 to be positively correlated with financial statement complexity, with voluntary disclosure, with the timing of the rule changes, and with the likelihood of being affected by the new rules. Taken together, our results suggest a more nuanced view of how complex financial statements affect the mosaic of public information about the firm––while prior research documents that complex financial statements negatively affect the information environment, our results suggest that some firms attempt to mitigate these effects using voluntary disclosure. Our study contributes to the literature that examines how managers use different disclosure mediums to manage the information environment, and our findings are consistent with predictions from extant theory that managers trade-off various disclosure mediums in attempting to achieve an optimal information environment. The remainder of the paper proceeds as follows. Section 2 reviews the related theoretical and empirical literature on financial statement complexity and the relation between mandatory and voluntary disclosure. Section 3 describes the research design and measurement choices. Section 4 describes the sample. Section 5 presents the results and discusses our robustness tests. Section 6 discusses several supplemental analyses, and Section 7 provides concluding remarks. 2. Literature review 2.1 Theory Literature More complex financial statements require more time and effort to extract relevant information, which makes them more costly to parse by investors (e.g., Bloomfield, 2002). Regulators have long voiced concerns about excessively lengthy and complex financial statements. In 1969, the SEC published the “Wheat Report,” which noted that the average investor was unable to readily understand firms’ prospectuses, and recommended that companies avoid unnecessarily complex, lengthy or verbose writing. More recently, the SEC adopted the 6 “plain English” rule in an effort to increase disclosure readability (SEC Rule 421(d)).4 Despite these efforts, concerns remain that financial statement complexity adversely affects both unsophisticated and sophisticated investors. For example, a recent study by KPMG finds that the complexity of financial statements and associated information processing costs have continued to grow––primarily due to changes in disclosure requirements related to fair value accounting, derivatives, and hedging (KPMG, 2011).5 It is well known that an increase in information processing costs leads to a decrease in the average precision of investors’ beliefs about future cash flow (e.g., Grossman and Stiglitz, 1980; Kim and Verrecchia, 1991). In early theory papers on voluntary disclosure, Jung and Kwon (1988) and Verrecchia (1990) show that voluntary disclosure depends on the precision of investors’ beliefs about future cash flow—an increase in uncertainty about future cash flow (i.e., a reduction in precision) causes an increase in disclosure. Our paper focuses on financial statement complexity as it relates to information uncertainty. Taylor and Verrecchia (2015) discuss how uncertainty about future cash flow is driven by the sum of two forces––the real volatility of future cash flow (fundamental uncertainty) and common knowledge about that cash flow (information uncertainty). Either an increase in fundamental uncertainty or an increase in information uncertainty works to increase total uncertainty about future cash flow. Managers may not be able to reduce fundamental uncertainty using voluntary disclosure (i.e., reduce the real volatility of cash flow), but may be able to reduce information uncertainty using voluntary disclosure (i.e., increase common 4 Additional initiatives include the SECs “21st Century Disclosure Initiative” in 2008, the FASBs “Disclosure Framework Project” in 2011, and the UK Financial Reporting Council’s “Cutting Clutter” initiative in 2011. 5 As an example of a practitioner-oriented perspective on financial statement complexity, see “The 109,894-Word Annual Report,” Wall Street Journal, June 2, 2015. 7 knowledge).6 This motivates our focus on financial statement complexity, and on alleviating “informational problems.” We make two additional points regarding the content and timing of firms’ voluntary disclosures. First, although economic theory predicts managers use voluntary disclosure to alleviate the informational problems associated with complex financial statements, the theory provides little guidance on the content or medium of the voluntary disclosure. For example, suppose that in the year of adoption, SFAS 133 created some uncertainty about the hedging aspects of a firm’s derivatives positions. Further, assume that observing this confusion, management decides to provide voluntary disclosure to assist investors in sorting out the implications of SFAS 133 for future cash flow. One possibility might be to issue a press release or hold a conference call to provide additional detail on the derivatives positions. Another possibility, however, might be to issue a management forecast of earnings, thereby helping investors synthesize the information that was provided in the 10-K (i.e., effectively showing investors how the derivatives disclosures map into future earnings). This example illustrates that our empirical predictions do not require that the additional voluntary disclosure be verbiage that is directly tied to the source of increased uncertainty. Second, the theory provides little guidance on the timing of voluntary disclosures. When managers anticipate informational problems, they could conceivably pre-empt these problems–– either by altering the content of the financial statements or increasing voluntary disclosure prior to filing the financial statements. However, the fact that prior research finds complex financial statements negatively affect the information environment suggests managers are unable (or unwilling) to mitigate these effects by altering the content of the financial statements themselves. This is perhaps not surprising given that predicting precisely where and when investors will 6 For example, several papers suggest that firms with more volatile fundamentals are less likely to provide voluntary disclosure (e.g., Waymire, 1985; Chen et al., 2011). 8 struggle to understand a given set of financial statements is likely to prove difficult.7 Hence, managers may need to observe analysts’ and investors’ interpretation of financial statement information before understanding the source of uncertainty and how to resolve it. Consequently, attempts to mitigate informational problems created by complex financial statements are likely to, in large part, occur after the financial statements are filed. However, the expected timing of any subsequent voluntary disclosure is not clear. We therefore tabulate our results over several windows following the 10-K filing. 2.2 Empirical literature Consistent with concerns in regulatory and practitioner circles that an increase in financial statement complexity negatively affects the information environment, empirical research shows that complex financial statements are associated with lower trading volume and ownership among retail investors (e.g., Miller, 2010; Lawrence, 2013), increased analyst forecast dispersion and reduced analyst forecast accuracy (e.g., Lehavy et al., 2011; Bozanic and Thevenot, 2015), disagreement among credit rating agencies (e.g., Bonsall and Miller, 2013), reductions in the extent to which prices impound information (e.g., You and Zhang, 2009; Lee, 2012; Callen et al., 2013), and increased idiosyncratic volatility (e.g., Loughran and McDonald, 2014). While the extant literature documents the potential negative effects of financial statement complexity, it does not examine whether managers use alternative disclosure channels to mitigate these effects. One view of complex financial statements is that they reflect an information-based agency problem. While the theoretical models discussed earlier are predicated on the notion that managers seek to maximize firm value, this need not be the case. Managers may intentionally 7 Academic authors will appreciate the challenge in conveying complex information. Even when authors are using their best efforts to be transparent, it may nevertheless be difficult to anticipate where a reader will struggle with the material. 9 choose to add (unnecessary) complexity to financial statements if the personal benefits from doing so exceed the costs. For example, Li (2008) interprets the negative relation between firm performance and financial statement complexity as evidence that managers intentionally increase financial statement complexity to obfuscate poor performance. If high levels of financial statement complexity reflect an intentional choice to obfuscate information, then it seems unlikely that these managers would use alternative disclosure channels to increase the quality of the information environment. An alternative view of complex financial statements is that they reflect the complexity of the firm’s business transactions and associated reporting and disclosure rules. That is, managers attempt to avoid unnecessary complexity when preparing financial statements, but complex transactions, complex reporting and mandatory disclosure rules (e.g., consolidation accounting, hedge accounting, or accounting for financial assets) may necessitate complex financial statements. In this case, as suggested by extant theory, voluntary disclosure may be a supplemental medium that allows managers to communicate information to investors, and thereby mitigate the negative effects of complex financial statements on the information environment. To be clear, the notion that financial statement complexity might not be the result of intentional obfuscation is not new. Antecedent work that makes this point includes Bloomfield (2008) and Bushee et al. (2015).8 The distinguishing feature of our study is that we examine how financial statement complexity relates to voluntary disclosure, where this relation is predicted to depend on the source of the complexity. While prior literature has examined the complexity of 8 Bloomfield (2008) suggests an alternative explanation for the negative relation between firm performance and financial statement complexity is that poor performance requires managers to provide more detailed explanations. Bushee et al. (2015) examines the complexity of language used in quarterly conference calls and compares the complexity of language used by analysts on the call with that of managers. Conditional on analysts using complex language on the call, Bushee et al. (2015) finds that managers use complex language to convey (rather than obfuscate) information––when analysts ask complex questions, a complex response is more informative. 10 financial statements in isolation or voluntary disclosure in isolation, it has generally not sought to link the two. In this regard, our paper is related to Lehavy et al. (2011) who examine how analysts respond to the informational problems created by complex financial statements. In the same vein, we examine how managers respond to the informational problems created by complex financial statements. Several related studies examine the interplay between firms’ mandatory and voluntary disclosure. For the most part, these studies focus on measures of earnings quality and document a positive relation between earnings quality and the incidence, frequency, and accuracy of voluntary disclosure (e.g., Lennox and Park, 2006; Francis et al., 2008; Gong et al., 2009). One notable exception is Ball et al. (2012), who find that more “verifiable” mandatory disclosures, as measured by higher audit fees, are positively associated with the frequency and quality of management forecasts.9 In contrast to these studies, we show that voluntary disclosure is sometimes negatively related to the quality of mandatory disclosure. That is, lower information accessibility in mandatory disclosure (in the form of complexity) is associated with more information being released through voluntary disclosure. Similar to Balakrishnan et al. (2014a) who find that managers respond to a reduction in analyst coverage by increasing voluntary disclosure, our results suggest managers respond to an increase in financial statement complexity by increasing voluntary disclosure. 3. Research design 3.1 Financial statement complexity and voluntary disclosure We examine the relation between financial statement complexity and voluntary disclosure by estimating regressions of the form: 9 Note that one interpretation of these results is that audit fees proxy for the complexity of the financial statements (auditors charge a higher fee for more complex financial statements), in which case their results could be interpreted as consistent with our evidence that financial statement complexity is positively associated with voluntary disclosure. 11 VoluntaryDisct+1 = φ0 + φ1 FS_Complexityt + θ Controlst + εt, (1) where FS_Complexity is a measure of financial statement complexity (ReadIndex or Length), VoluntaryDisc is a measure of voluntary disclosure (Frequency, Frequency90, Frequency60, Frequency30, or Immediacy), and Controls is a vector of control variables. Similar to prior research, we measure voluntary disclosure using the frequency and immediacy of management forecasts. We define Frequency as the number of management forecasts (including forecasts of EPS, cash flows, sales, etc.) issued during the 12-months following the filing of the 10-K. To ensure that our results are not specific to a particular window of disclosure, we also measure the frequency of forecasts over the 90, 60, and 30 days after the filing of the 10-K, Frequency90, Frequency60, Frequency30, respectively. These narrower windows allow us to sharpen identification that the disclosure serves as follow up to the 10-K, but reduce the power of our tests.10 Regarding the immediacy of management forecasts, we define Immediacy as the number of days between a firm’s 10-K filing and the first management forecast thereafter. We multiply by negative one to obtain a measure that is increasing in immediacy. For example, an immediacy of –118 implies the first forecast occurred 118 days after the 10-K was filed. Collectively, these measures capture management’s use of voluntary disclosure to supply investors with additional information after the 10-K, as well as how quickly such information is forthcoming.11 10 It is well established that management forecasts represent an important source of firm disclosure (Beyer et al., 2010), and prior research suggests that managers who wish to improve the information environment issue more frequent forecasts (see Hirst et al. (2008) for an overview of management guidance practices). We focus our measures on frequency because such measures can be calculated for all firms, and because these measures capture all forms of management guidance (e.g., EPS, cash flows, sales, etc.). Inferences are unchanged if we focus specifically on earnings forecasts 11 From the incidence and timing of voluntary disclosure, it is difficult to infer when managers learned the private information revealed in their forecast. As a result, we are not able to make statements about when managers obtain their private information. Our tests rely only on the notion that disclosure reveals private information and improves the information environment. 12 Following an extensive prior literature, we measure financial statement complexity using the readability (ReadIndex) and length (Length) of the firm’s 10-K.12 While much of the prior literature in accounting uses the Fog index to measure readability, to ensure that our results are not specific to any single measure of readability, and to mitigate the influence of idiosyncratic measurement error in any given measure, we construct a readability index that combines several established measures of readability.13 ReadIndex is the first principal component of the following measures of readability: Flesch-Kincaid readability, LIX readability, RIX readability, Gunning Fog readability, ARI readability, and SMOG readability. Each of these measures is effectively a function of word complexity and sentence length, and higher values correspond to less readable text.14 Appendix B provides detailed definitions of these variables, present the results from our principal component analysis, as well as the correlations among the six measures of readability and ReadIndex. The analysis shows that only a single factor has an eigenvalue greater than one, that this factor (ReadIndex) explains 94% of the variation in these measures, and that all measures of readability are highly correlated with each other and with ReadIndex. We measure length of the firm’s 10-K, Length, as the natural logarithm of the number of words. Because the costs of processing longer documents are presumably higher, longer documents can be more difficult to read. Consistent with the prior literature, we use the natural logarithm rather than the raw number of words to reduce the impact of extreme values and skewness in the number of words across firms.15 12 Several prior papers use readability and length interchangeably as proxies of financial statement complexity. See, for example, Li (2008), Miller (2010), Lee (2012), Bonsall and Miller (2013), Lawrence (2013). 13 Results are robust to measuring readability using the Fog index, and in some cases stronger. 14 See Jones and Shoemaker (1994) and Moffit and Burns (2009) for reviews of studies using each of these measure of readability. 15 In untabulated analyses, we find results are robust to using electronic file size of the 10-K filing to measure financial statement complexity (e.g., Loughran and McDonald, 2014) and to including Length as an additional variable in the construction of ReadIndex (see Section 6 for more details). 13 In all of our regression specifications, we include the following variables as controls. Size is the natural logarithm of market value of equity as of the fiscal year-end, ROA is the industryyear adjusted return on assets, measured as income before extraordinary items scaled by total assets, Loss is an indicator variable equal to one if net income is negative and zero otherwise, Leverage is long-term debt plus short-term debt scaled by total assets, MTB is the market value of equity plus book value of liabilities divided by book value of assets, SpecialItems is special items scaled by total assets, Returns is the buy and hold return over the 12 months prior to the 10-K filing date, and σReturns is the standard deviation of monthly returns over the 12 months prior to the filing date. See Appendix A for variable definitions. Note that all independent variables are measured prior to our measures of voluntary disclosure (the dependent variable). Throughout all of our analyses, we base inferences on standard errors clustered by firm and filing date, and estimate regressions using the decile ranks of the independent variables scaled to range from 0 to 1. We use the decile ranks of each independent variable to ensure that all independent variables are of similar scale. As a result, each coefficient measures the change in the respective measures of voluntary disclosure when moving from the bottom decile to the top decile of the respective independent variable, ceteris paribus. This, in turn, allows us to meaningfully compare the relative economic significance of each variable. The ranked specification has the added advantage of being robust to both outliers and nonlinearities.16 The theoretical arguments for why financial statement complexity engenders subsequent voluntary disclosure predict not only that variation in complexity across firms is related to voluntary disclosure, but also that, within the firm, time-series variation in complexity should be associated with time-series variation in voluntary disclosure (e.g., Verrecchia, 1990). To determine whether within-firm variation in financial statement complexity explains within-firm 16 Inferences are robust to using raw values. 14 variation in voluntary disclosure, we estimate an augmented version of equation (1) that includes firm fixed effects. This research design eliminates the cross-sectional variation in financial statement complexity and voluntary disclosure, and relies on within-firm time-series variation to identify the coefficient on FS_Complexity. If the relation between financial statement complexity and voluntary disclosure is driven exclusively by cross-sectional differences in firm characteristics, then holding the firm constant, we expect to find no evidence of a relation between financial statement complexity and voluntary disclosure. We present results separately, with and without fixed effects, because the underlying theory we use to motivate our analysis predicts both cross-sectional and temporal relations with voluntary disclosure, and we wish to show that both results are observed in the data.17 3.2 Cross-sectional variation in the relation between financial statement complexity and voluntary disclosure In this section we describe the research design used to test our cross-sectional predictions. We first examine how the relation between financial statement complexity and voluntary disclosure varies with the change in liquidity at the time the financial statements are filed. More complex financial statements require greater information processing which reduces liquidity, and extant research suggests that managers use voluntary disclosure to achieve a target level of liquidity.18 Consequently, we predict that the greater the reduction in liquidity when the financial statements are filed, the more likely managers are to provide voluntary disclosure subsequent to filing complex financial statements. 17 For example, the theory that underlies our analysis predicts: (i) industries with more complex financial statements have more voluntary disclosure and (ii) as financial statement complexity increases over time, so too should voluntary disclosure. We provide some evidence of these cross-sectional and time-series relations in our two quasinatural experiments. In this regard, controlling for firm fixed effects and temporal trends in complexity can be viewed as over-controlling. Nevertheless, in untabulated analysis, we find inferences are robust to including industry fixed effects and year fixed effects. Inferences are also robust to restricting our sample to those firms that have more than one CEO during our sample period and including both firm and manager fixed effects (e.g., Bamber et al., 2010; Brochet et al., 2011). 18 See for example, Coller and Yohn (1997), Figure 10 of Graham et al. (2005), and Balakrishnan et al. (2014a). 15 To test this prediction, we interact FS_Complexity in equation (1) with two measures of the changes in illiquidity around the filing date of the 10-K, and predict positive coefficients on the interaction terms. We measure the change in illiquidity using both the Amihud (2002) measure of illiquidity: Illiquidityt = Rt DVolumet ×106 (2) where Rt is the daily return and DVolumet is the daily dollar volume (in millions), and the bid-ask spread: Spread t = Ask t − Bid t × 100 price t (3) where Askt (Bidt) is the quoted closing ask (bid) on day t, and pricet is the closing price on day t from CRSP. We calculate the Amihud (2002) measure of illiquidity and the bid-ask spread at the daily level and then calculate the change around the filing date, ∆Illiquidity and ∆Spread, as the difference between the average value on the day of and after the filing (t = 0, 1) and the average value over the window beginning fifty days prior to the filing and ending five days prior to the filing (t = –50, …, –5). To compute ∆Illiquidity and ∆Spread, we require non-missing data on the daily CRSP file for at least 20 days prior to, the day of, and the day after the 10-K filing date. Our second set of cross-sectional tests examines how the relation between financial statement complexity and voluntary disclosure varies with scrutiny from external monitors. On the one hand, managers under a high degree of scrutiny from external monitors may have stronger incentives to mitigate the negative informational effects of complex financial statements and maintain the quality of the information environment (e.g., Ajinkya et al., 2005; Armstrong et al., 2010). On the other hand, in the absence of agency conflicts, a higher level of external 16 monitors might indicate a rich information environment which could decrease managers’ incentives to provide additional disclosure. To examine whether the relation between financial statement complexity and voluntary disclosure varies with external monitoring, we interact FS_Complexity in equation (1) with two measures of external monitoring. We measure external monitoring using the number of analysts following the firm as of the filing date of the 10-K (NAnalysts) and the number of institutional investors in the firm as of the latest calendar quarterend prior to the 10-K filing date (NInstitutions).19 Our third set of cross-sectional tests examines how the relation between financial statement complexity and voluntary disclosure varies with firm performance and the level of earnings management. Conditional on either poor firm performance or earnings management, the benefits of a low quality information environment accrue to the manager (e.g., a reduced likelihood of termination or reputational damage, inflated stock price, inflated compensation) whereas the costs are borne by shareholders (e.g., reduction in liquidity, greater cost of capital). Consequently, we predict that the positive relation between complexity and voluntary disclosure is weaker when the firm underperforms its industry peers, posts a loss, and has large abnormal accruals. To test this prediction, we interact FS_Complexity in equation (1) with two measures of firm performance, ROA and Loss (as previously defined), and the firm’s performance-matched abnormal accruals, AbAcc (e.g., Kothari et al., 2005).20 3.3 Two quasi-natural experiments 19 Results are robust to using percent of institutional ownership or the number of large blockholders (those with 5% or more ownership) to measure external monitoring. 20 Firms are matched to a respective industry-year peer on Compustat by minimizing the absolute difference in ROA. In untabulated analyses, we examine two additional measures of earnings management: (1) size-age-growth matched accruals (e.g., Armstrong et al., 2015) and (2) an indicator for meeting-or-beating analyst earnings targets by $0.01/share or less. While we find inferences are robust to (1), we find the interaction between financial statement complexity and (2) is statistically insignificant at conventional levels. It is unclear how to interpret this finding in light of the fact that analyst forecast accuracy is itself affected by both complexity and voluntary disclosure (see discussion in Section 6.2). 17 In this section, we examine changes in financial statement complexity and voluntary disclosure around the adoption of SFAS 133 (Accounting for Derivatives) and the adoption of SFAS 157 (Fair Value Measurements) using a generalized difference-in-differences design.21 Both rules require extensive disclosures about fair value measurements, which we expect will increase the complexity of affected firms’ financial statements––and if our hypotheses above are correct––will also increase voluntary disclosure.22 The advantage of focusing on these two changes in accounting standards are two-fold. First, because these are two of the more complex accounting standards, the analysis allows us to validate that our text-based measures of financial statement complexity reflect, at least in part, complexity of the underlying accounting and mandatory disclosure rules. Second, we can use the adoption of these accounting standards to isolate the effect of reporting complexity on financial statement complexity, and in turn voluntary disclosure. These tests provide direct evidence on whether managers give specific consideration to the complexity of accounting standards. Regulators’ motives for the passage of fair value accounting standards such as SFAS 133 and SFAS 157 primarily relate to providing users with an understanding of the value of complex assets and the sources of information used to estimate these values (see FASB, Appendix C of SFAS 133 and Appendix C of SFAS 157). However, anecdotal evidence and academic studies suggest that, to this day, the complexity associated with these standards impairs market 21 For a difference-in-differences design to provide meaningful estimates, the assignment variable needs to be exogenous. The adoption of these accounting standards is “plausibly exogenous” with respect to the average firm’s voluntary disclosure and financial statement complexity. So long as the change in standards is not the result of actions on the part of the average firm, the change in standards can be treated as exogenous for the purposes of econometric analysis (see for example, Larcker et al., 2011). 22 SFAS 133, Accounting for derivative instruments and hedging activities, was adopted for fiscal periods beginning after June 15, 2000, and mandates that a firm record changes in the fair value of its cash flow hedges in accumulated other comprehensive income (AOCI), a component of shareholders’ equity. As such, unrealized changes in fair value appear on the balance sheet but do not appear on the income statement until they are realized. SFAS 157, Fair value measurements, effective for fiscal periods beginning after November 15, 2007, provides a framework for the measurement of financial assets and liabilities at fair value. Specifically, it distinguishes between three levels of inputs used to derive fair value estimates: level 1 inputs consist of observable quoted prices in active markets for identical assets or liabilities; level 2 inputs consist of observable sources other than quoted prices; and level 3 inputs consist of unobservable, firm-supplied sources. 18 participants’ ability to understand and price this information (e.g., Riedl and Serafeim, 2011; Campbell, 2015). For example, a recent KPMG survey seeking to identify sources of disclosure overload and complexity concludes that “fair value, derivatives and hedging are the most significant sources of disclosure complexity under specific GAAP requirements” (KPMG, 2011, page 18).23 We identify the firms affected by the adoption of SFAS 133 and the adoption of SFAS 157 in our sample (treatment or affected group), and construct matched samples of unaffected firms using propensity score matching (control or unaffected group). Specifically, we form oneto-one matched-pairs by estimating a propensity score in the year prior to the respective change in accounting standards as a function of the control variables in equation (1). We then match each affected firm to the corresponding unaffected firm that minimizes the squared difference in propensity scores between the two firms. We repeat this procedure for each rule change, resulting in separate treatment and control groups for SFAS 133 and SFAS 157. The test for covariate balance between the two groups appears in Table C1 in Appendix C. The advantage of using a matched sample of firms as a control group is two-fold. First, if observations with certain characteristics (e.g., size) are more likely to be treated and to have a differential trend in voluntary disclosure, controlling for these characteristics mitigates concerns that the treatment is non-random. Second, using treatment and control groups that are similar with respect to such characteristics can improve precision and better isolate the treatment effect (Roberts and Whited, 2013).24 23 To provide an anecdote, in 2004 the SEC directed Fannie Mae to restate its earnings by $9 billion of losses on derivatives due to improper application of SFAS 133. According to a case study by Risk Limited Corporation, Fannie Mae failed to fully understand the SFAS 133 rules, which “illustrates the complexity and effort required for ongoing FAS 133 compliance” (p. 16). See case study at: www.energyrisk.org/deutsch/fas-133-fannie-mae.ppt. Note that our test rely only on the notion that the adoptions of SFAS 133 and 157 increased information processing costs within three years of the respective adoptions. 24 Results are robust to using the entire sample of unaffected firms as the control group rather than the propensity score matched sample. 19 We employ a generalized difference-in-differences design. Specifically, for each rule change, we estimate the following regression: VoluntaryDisct+1 = φ0 + φ1 Postt*Affected + f + δ + θ Controlst + εt, (4) where Post is an indicator variable equal to one for fiscal years after the rule change became effective, and zero otherwise, Affected is an indicator variable equal to one for firms affected by the respective rule change, and zero otherwise, f and δ are vectors of firm and year fixed effects, respectively, and all other variables are as previously defined. We estimate equation (4) over a period of six years around each regulatory change (i.e., three years prior to and three years after the change). For SFAS 133, Affected firms are those reporting unrealized gains and losses on derivatives in accumulated other comprehensive income (e.g., Campbell, 2015), and the preperiod (post-period) refers to three fiscal periods beginning before (after) June 15, 2000. For SFAS 157, Affected firms are those reporting level 1, level 2 or level 3 assets or liabilities (e.g., Riedl and Serafiem, 2011), and the pre-period (post-period) refers to three fiscal periods beginning before (after) November 15, 2007. The distinguishing feature of the “generalized” difference-in-differences design is that it includes both firm and year fixed effects, which controls for any fixed differences between affected and unaffected firms (firm fixed effects absorb the Affected main effect) and any time trends (year fixed effects absorb the Post main effect). Thus, the coefficient on the interaction term, Post*Affected, represents the average treatment effect (or DiD ATE); see Bertrand et al. (2004), Hansen (2007), and Angrist and Pischke (2009) for details on this design. 4. Sample and descriptive statistics 4.1 Sample construction We construct our sample using data from Compustat, CRSP, I/B/E/S, Thomson-Reuters database of 13-F filings, and the WRDS SEC Analytics Suite. The sample begins in 1995, when 20 management earnings forecasts first become available in the I/B/E/S Guidance database, and ends in 2012. To be included in the sample, a firm must have a 10-K filing on EDGAR between 1995 and 2012, sufficient financial statement data on Compustat to calculate our control variables, and monthly stock returns over the 12 months prior to the 10-K filing on CRSP. The resulting sample consists of 72,366 firm-years.25 In two of our cross-sectional tests, we impose additional sample requirements. In the cross-sectional tests that involve market-based measures of changes in illiquidity (∆Illiquidity and ∆Spread), presented in Table 4, the sample is reduced to 69,066 observations due to data requirements to calculate daily bid/ask spreads. In tests that involve earnings management, presented in Table 6, the sample is reduced to 59,068 firm-years due to data requirements to estimate performance-matched abnormal accruals (AbAcc). 4.2 Descriptive statistics Table 1, Panel A presents descriptive statistics for our sample. Firms provide, on average, 2.62 forecasts per year, and for those firms providing a forecast, the first forecast occurs on average 108.52 days after the 10-K filing. The average 10-K in our sample has a ReadIndex of – 0.01 and Length of 10.25, (or 33,896 words).26 Descriptive statistics for our control variables show that our sample firms have a mean (median) industry-adjusted return-on-assets of 0.00 (0.02), a mean (median) leverage ratio of 0.22 (0.16), a mean (median) market-to-book ratio of 1.94 (1.03), and mean (median) special items of –0.02 (0.00). Approximately 32% of firms in our sample report a loss (mean Loss is 0.32), and the average (median) annual buy and hold return is about 14% (5%) over the twelve months prior to the 10-K. Similar to prior research 25 Without requiring control variables we have data for 86,236 10-Ks with CRSP identifiers over the 1995 to 2012 period. 26 The statistics for Length are similar to prior research (e.g., Li, 2008). 21 (e.g., Lehavy et al., 2011; Akins et al., 2012), average (median) analyst coverage is 4.61 (2.00) analysts and the average (median) number of institutional investors is 97.97 (51.00). Table 1, Panel B presents correlations among the variables used in our analysis, with Spearman (Pearson) correlations above (below) the diagonal. The Spearman (Pearson) correlation between our two measures of financial statement complexity is 0.47 (0.49), and the correlation between our measures of voluntary disclosure over the various windows ranges between 0.33 (Spearman correlation between Frequency and Frequency30) and 0.89 (Pearson correlation between Frequency and Frequency90). Notably, all measures of voluntary disclosure are positively correlated with all measures of financial statement complexity. Table 2 presents the average values of our measures of voluntary disclosure by quintile of financial statement complexity. Table 2 shows that the lowest quintile of ReadIndex (Length) has on average 1.27 (0.61) forecasts over the 12 months following the 10-K filing, while the highest quintile has on average 3.40 (4.17) forecasts, a difference of 2.13 (3.56) forecasts. Similarly, the first forecast for the lowest quintile of ReadIndex (Length) comes on average 123.86 (145.78) days after the filing of the 10-K, while the first forecast for the highest quintile comes on average 101.05 (96.27) days after the filing of the 10-K, a difference of 22.81 (49.51) days. All differences are positive and statistically significant (two-tailed p-values <0.001). Although effectively a univariate analysis and subject to the standard limitations, the results in Table 2 are consistent with a positive relation between financial statement complexity and voluntary disclosure. Figure 1 in Appendix C plots cumulative voluntary disclosure by month after the 10-K filing for firms in the top and bottom quintiles of financial statement complexity, where the initial value in month 0 is the number of management forecasts issued between the fiscal year-end date and the 10-K filing date. 5. Results 22 5.1 Financial statement complexity and voluntary disclosure Table 3 presents results from estimating equation (1). In Panel A, the dependent variable is voluntary disclosure measured over a 12-month window following the filing of the 10-K (Frequency), in Panel B a 90-day window following the filing of the 10-K (Frequency90), in Panel C a 60-day window (Frequency60), in Panel D a 30-day window (Frequency30), and in Panel E voluntary disclosure is measured as the number of days between the 10-K filing date and the first management forecast thereafter, multiplied by minus one (Immediacy). In each panel, financial statement complexity is measured by ReadIndex in columns (1) and (2) and Length in columns (3) and (4). Columns (1) and (3) of each panel present results from estimating pooled regressions. We find positive and significant coefficients on both ReadIndex and Length in 7 out of 8 pooled specifications across Panels A through D (two-tailed p-values < 0.01). The coefficients on ReadIndex and Length become monotonically larger as the length of the window increases, indicating that the bulk of the voluntary disclosures occur more than 30-days after the 10-K. Despite that fact that managers do not often issue forecasts before the next earnings announcement (average value of Frequency30 is 0.07; see Table 1), we do find results over shorter windows, albeit weaker than over the longer windows. This suggests that the informational problems created by complex financial statements are sufficiently large to accelerate disclosure of forecasts, although not strong enough to result in instantaneous disclosure. As noted above, one explanation for the results being weaker in the 30-day window is that managers may require time to sort out the extent to which the 10-K creates informational problems and the issues that create such problems. That is, managers may need to observe analysts’ and investors’ interpretation of financial statement information before understanding 23 the source of uncertainty and how to resolve it. Together with the fact that management rarely issues forecasts within 30 days of the release of the 10-K, the 60-day or 90-day windows may be the most convenient time to provide a forecast that aids investors in interpreting information provided in a recent 10-K release. We also find positive and significant coefficients on Immediacy in columns (1) and (3) of Panel E, and the signs on the coefficients of our control variables are generally consistent with prior literature (e.g., Ajinkya et al., 2005; Hirst et al., 2008). Combined, these results suggest that firms issue both more frequent and more immediate management forecasts when their financial statements are complex. The marginal effect of financial statement complexity on voluntary disclosure also appears to be economically significant. A firm in the top decile of ReadIndex issues about one additional management forecast over the 12 months following the 10-K (φ1 = 0.98, t-stat = 7.40 in Panel A, column (1)), with the first forecast issued approximately 14 days earlier (φ1 = 14.49, t-stat = 5.09 in Panel E, column (1)), relative to a firm in the bottom decile of ReadIndex, ceteris paribus.27 Similarly, a firm in the top decile of Length issues about three additional management forecasts over the 12 months following the 10-K filing (φ1 = 2.90, t-stat = 21.32 in Panel A, column (3)), with the first forecast issued approximately 48 days earlier (φ1 = 48.40, t-stat = 11.15 in Panel E, column (3)) relative to a firm in the bottom decile of Length, ceteris paribus. By comparison, the average firm issues 2.6 management forecasts. Columns (2) and (4) of each panel present results after including firm fixed effects in the respective regression specification. By including firm fixed effects, the regression coefficients capture within-firm variation rather than cross-sectional variation, and provides an interesting 27 Recall that all independent variables are scaled decile ranks. As a result, the coefficient measures the change in the dependent variable when moving from the bottom decile to the top decile of the respective independent variable, ceteris paribus. 24 time-series perspective on how financial statement complexity influences firms’ voluntary disclosure practices. The coefficients on both ReadIndex and Length are statistically significant in all specifications across the panels (two-tailed p-values < 0.10) indicating that within-firm changes in financial statement complexity are positively associated with within-firm changes in management forecast frequency and immediacy. As in our pooled specification, the results appear economically significant. For example, the results in column (4) of Panel E suggest that a firm in the top decile of Length issues its first forecast approximately 78 days earlier (φ1 = 78.44, t-stat = 13.22) than a firm in the bottom decile of Length.28 5.2 Cross-sectional variation in the relation between financial statement complexity and voluntary disclosure 5.2.1 Changes in illiquidity around the filing of the 10-K Table 4 presents results from estimating a model similar to Panel A of Table 3, except that we include measures of the change in illiquidity around the 10-K filing date (∆Illiquidity and ∆Spread) and interact these measures with our measures of financial statement complexity. Columns (1) through (4) of Table 4 present results using ReadIndex to measure financial statement complexity, and columns (5) through (8) present results using Length to measure financial statement complexity. We estimate regressions that interact each illiquidity measure separately, followed by specifications that include both illiquidity variables in the same regression specification, followed by specifications that include firm fixed effects. Finding consistent evidence across multiple specifications where interactions are included separately and simultaneously suggests our results are not influenced by multicollinearity. 28 Note that the signs on MTB and Leverage flip between our pooled and within-firm specifications which highlights the differences between these two settings. Our results indicate that in the cross-section, firms with higher growth options (lower leverage) tend to provide more voluntary disclosure. Over time within a given firm, however, the results suggest that firms provide more voluntary disclosure as growth options decline and leverage increases. A decline in growth options and an increase in leverage are likely to be issues of concern for both managers and investors (or at least issues that can require some clarity). 25 Consistent with our predictions, across all specifications, we find that the coefficients on the interaction between our measures of financial statement complexity and changes in illiquidity are positive and statistically significant at conventional levels. These findings indicate that managers appear to give specific consideration to the effect of the 10-K filing on liquidity when deciding to provide voluntary disclosure.29 5.2.2 External monitors Table 5 presents results from estimating a model similar to equation (1), except that we include the measures of external monitoring (NAnalysts and NInstitutions), and interact these measures with our measures of financial statement complexity. Columns (1) through (4) present results using ReadIndex to measure financial statement complexity, and columns (5) through (8) present results using Length to measure financial statement complexity. Consistent with the prediction that managers under a high degree of scrutiny from external monitors have stronger incentives to mitigate the negative informational effects of complex financial statements, across all specifications, we find that the relation between financial statement complexity and voluntary disclosure is significantly stronger when the firm has a greater number of analysts and institutional investors. Notably, our results also suggest that the sign of the relation between financial statement complexity and voluntary disclosure depends on the presence of external monitors (i.e., the main effect of FS_Complexity is negative and significant across all specifications). That is, while firms in the top decile of analyst coverage or number of institutional investors provide more voluntary 29 We note that the main effect on ∆Illiquidity is often negative and significant across specifications (similarly, the main effect on ∆Spread is negative and significant in one specification). We urge caution in interpreting this result. Liquidity and bid-ask spread reflect both fundamental uncertainty driven by volatility of firms’ cash flows and information uncertainty driven by the information environment (Taylor and Verrecchia, 2015). Consequently, if firms with the least complex financial statements experience a large change in illiquidity around their 10-K filing, that change is more likely attributable to fundamental uncertainty (as opposed to information uncertainty), and prior literature suggests that firms with more volatile fundamentals are less likely to disclose (e.g., Waymire, 1985; Chen et al., 2011). 26 disclosure after filing complex financial statements, firms in either the bottom decile of analyst coverage (firms with zero analyst coverage) or in the bottom decile of institutional investor coverage (firms with between 1 and 6 institutional investors) provide less voluntary disclosure after filing complex financial statements. This is consistent with the notion that scrutiny from external monitors disciplines managers’ disclosure decisions, and in the absence of that scrutiny, managers can more easily engage in self-interested activity at the expense of shareholders (e.g., obfuscation). 5.2.3 Firm performance and earnings management Table 6 presents results from estimating a model again similar to equation (1), except that we include measures of firm performance (ROA and Loss) and earnings management (AbAcc) in the model, and interact these measures with our measures of financial statement complexity. Columns (1) through (5) present results using ReadIndex to measure financial statement complexity, and columns (6) through (10) present results using Length to measure financial statement complexity. Consistent with our predictions, across all specifications, we find: (i) that the coefficient on the interaction between financial statement complexity and ROA is positive and statistically significant, (ii) that the coefficient on the interaction between financial statement complexity and Loss is negative and statistically significant, and (iii) that the coefficient on the interaction between financial statement complexity and AbAcc is negative and statistically significant. These findings are consistent with the notion that, conditional on either poor firm performance or earnings management, the benefits of a low quality information environment accrue to the manager whereas the costs are borne by shareholders. Collectively, the results from examining cross-sectional variation in the relation between financial statement complexity and voluntary disclosure suggest that managers are giving specific consideration to the informational problems created by complex financial statements, 27 and suggest that the positive relation between financial statement complexity and voluntary disclosure is strongest (weakest) in settings where managers have greater (lesser) incentives to mitigate the informational problems created by complex financial statements. Testing multiple predictions, and finding robust consistent evidence across these predictions, makes it less likely that our collective results are attributable to alternative explanations.30 5.3 Robustness analyses 5.3.1 Pre-emptive voluntary disclosure To examine whether managers anticipate some of the informational problems associated with filing complex financial statements and pre-emptively issue voluntary disclosure, we reestimate our primary tests using voluntary disclosure issued in anticipation of the 10-K filing as the dependent variable. We measure voluntary disclosure issued in anticipation of the 10-K filing as the number of management forecasts issued between the fiscal year-end date and the 10-K filing date, inclusive (PreFrequency).31 If managers anticipate financial statement complexity and pre-empt complex financial statements with voluntary disclosure, we predict a positive association between financial statement complexity and voluntary disclosure issued prior to the 10-K. We also examine whether the determinants of voluntary disclosure after filing a complex 10-K are distinct from the determinants of voluntary disclosure before the filing of a complex 10-K. If managers do not fully anticipate the informational problems associated with filing 30 For parsimony, we tabulate results from all our tests of cross-sectional variation using Frequency as the dependent variable. Using Frequency90, Frequency60, or Frequency30 as the dependent variable yields similar inferences. When Immediacy is defined for both forecasters and non-forecasters (i.e., set to –365 when the firm does not issue a forecast), our cross-sectional tests on Immediacy also yields similar inferences. However, when Immediacy is defined only for forecasters (set to missing when the firm does not issue a forecast) the sample shrinks to 26,509 firms (see Table 3, Panel E) and our cross-sectional results are mixed. 31 Note that any management forecasts on the day of the 10-K filing or during the earnings announcement will be included in PreFrequency (and are excluded from our measures of voluntary disclosure after the filing). Results are robust to extending the pre-emptive disclosure windows backward to include the 30, 60, or 90 days prior to the fiscal year-end. 28 complex financial statements––and hence the determinants differ––we predict an incremental relation between financial statement complexity (FS_Complexity) and voluntary disclosure subsequent to the filing (Frequency) after controlling for voluntary disclosure prior to the filing (PreFrequency). Otherwise, if the determinants of voluntary disclosure do not differ before and after the filing of a complex 10-K, then controlling for voluntary disclosure before the 10-K, we expect to find no evidence of a relation between financial statement complexity and voluntary disclosure after the 10-K. Panel A of Table 7 presents results from estimating a model similar to equation (1), except that we use voluntary disclosure prior to the 10-K as our dependent variable (PreFrequency). Panel A shows positive and statistically significant coefficients on both measures of financial statement complexity (ReadIndex in columns (1) and (2), and Length in columns (3) and (4)). These results suggest that firms do tend to provide more voluntary disclosure in anticipation of filing complex financial statements. Panel B of Table 7 presents results from repeating our primary tests in equation (1), but including PreFrequency as an additional control variable. Panel B shows that voluntary disclosure prior to the filing of the 10K is very highly correlated with voluntary disclosure after the filing of the 10-K. Importantly, all coefficients on our measures of financial statement complexity remain positive and statistically significant. Collectively, the evidence in Table 7 suggests a positive relation between financial statement complexity and voluntary disclosure immediately prior to the filing, and an incremental association between financial statement complexity and voluntary disclosure subsequent to the filing (after controlling for voluntary disclosure prior to the filing). 5.3.2 Alternative measures of voluntary disclosure: 8-K filings We examine the robustness of our results to using the frequency and immediacy of firms’ 8-K filings as alternative measures of voluntary disclosure. Prior research suggests there is a 29 significant discretionary component to 8-K filing decisions and that managers actively use 8-Ks to alter their information environment (e.g., Leuz and Schrand, 2009; Balakrishnan et al., 2014b). However, there is undoubtedly a mandatory aspect to these disclosures. In this regard, we caution that management forecasts are perhaps a cleaner measure of voluntary disclosure than 8K filings, as 8-K filings can co-mingle both voluntary and mandatory disclosures.32 Nevertheless, we examine these additional measures of voluntary disclosure to ensure that our results are not specific to management forecasts, but rather apply to a broader array of firms’ voluntary disclosures. Mirroring our management forecast variables, we define Frequency8K, Frequency8K90, Frequency8K60 and Frequency8K30 as the number of 8-Ks filed during the 12-month, 90-day, 60-day, and 30-day period following the 10-K, and Immediacy8K as the number of days between a firm’s 10-K and its first 8-K filing thereafter. Panel A of Table 8 presents the average value for each measure by quintile of financial statement complexity, and the difference between the extreme quintiles. Panel A shows that the lowest quintile of ReadIndex (Length) has on average 4.93 (2.61) 8-Ks over the 12 months following the 10-K, while the highest quintile has on average 9.39 (13.64) 8-Ks, a difference of 4.46 (11.03). Similarly, the first 8-K for the lowest quintile of ReadIndex (Length) comes on average 84.25 (112.03) days after the filing of the 10K, while the first 8-K for the highest quintile comes on average 56.69 (33.96) days after the filing of the 10-K, a difference of 27.56 (78.07) days. All differences are positive and statistically significant (two-tailed p-values < 0.01). 32 As exploratory analysis in this regard, we examined characteristics of various types of 8-Ks. For example, focusing on 8-Ks with material contracts that must be disclosed (e.g., Li, 2013), we find firms with longer 10-Ks have significantly more 8-Ks related to material contracts/agreements. Firms in the bottom (top) quintile of length have on average 0.1 (2.1) 8-Ks related to material contracts/agreements 12 months after the 10-K. We also find that firms with less readable (longer) 10-Ks also have less readable (longer) 8-Ks. However, interpreting the readability and length of 8-Ks is challenging, as the content is not standardized across 8-Ks. For example it is difficult to compare the readability or length of a supply contract with, say, the readability or length of a director resignation. 30 Panel B presents results from repeating the tests in Panels A through E of Table 3, using the each of the five measures of 8-K disclosure as the dependent variable. For each of the five measures of 8-K disclosure, columns (1) through (5), we present results separately for our two measures of financial statement complexity (ReadIndex and Length) and two regression designs (pooled and within-firm), for a total of 20 specifications (5 x 2 x 2). Each column mirrors a Panel from Table 3. For parsimony we do not tabulate coefficients on control variables. Regardless of specification, we find the coefficients on our measures of financial statement complexity are positive and both statistically and economically significant. 5.3.3 Time-series variation To ensure that our results are not an artifact of common time-trends in financial statement complexity and voluntary disclosure, we estimate separate annual cross-sectional regressions of equation (1) from 1995 to 2012. This procedure allows both the intercept and coefficients to vary by year and produces a time-series of 18 coefficients (e.g., Fama and MacBeth, 1973). We estimate annual cross-sectional regressions for four separate regression specifications: one for each measure of financial statement complexity and one for each of management forecasts and 8Ks (2 x 2). Panel A of Table 9 presents the average of the coefficients (FM coef.) and t-tests for whether the average coefficient is different from zero (FM t-stat). For parsimony we do not tabulate coefficients on control variables. In three out of the four specifications, we find that the average coefficient on financial statement complexity is positive and statistically significant. Figure 2 in Appendix C plots the annual cross-sectional coefficients over our sample period for each of the four specifications. Next, we examine various sub-periods. First, we analyze the period from 1995 to 1999, before “Regulation Fair Disclosure” (“RegFD”) became effective. Prior to RegFD, managers could use an alternative channel––private communication (or “selective disclosure”)––to clarify 31 information in financial statements. However, beginning in October 2000, RegFD prohibited firms from disclosing material information to select groups of market participants and effectively eliminated this channel. Second, we analyze the period from 2000 to 2004, after RegFD but before the “Additional Form 8-K Disclosure Requirements and Acceleration of Filing Date” rule (“Rule8K”) became effective. Rule8K, which became effective in August 2004, expanded the mandatory disclosure requirements of Form 8-K filings (e.g., required firms to furnish earnings announcements on Form 8-K) and shortened the filing deadlines for certain reportable events to four business days after the occurrence of the event.33 Third, we analyze the sample period from 2005 to 2012, after both RegFD and Rule8K became effective. Panel B presents results from estimating equation (1) over each of the three sub-periods. As before, we estimate four specifications: one for each measure of financial statement complexity and voluntary disclosure (2 x 2). We find that the association between financial statement complexity and voluntary disclosure is relatively weak in the period before RegFD became effective: the association between financial statement complexity and 8-Ks remains positive and significant (columns (3) and (4)), but the association between financial statement complexity and management forecasts is not statistically significant (columns (1) and (2)). In both periods subsequent to RegFD however, we find that the association between financial statement complexity and voluntary disclosure remains positive and significant in all our specifications. In untabulated analyses, across all specifications, we find the difference in the coefficients on financial statement complexity before and after RegFD is statistically significant at conventional levels (two-tailed p-values < 0.10). These results are consistent with the notion that RegFD increases the incentives for managers to use voluntary disclosure (as opposed to 33 Among other changes, Rule8K also implemented Section 409 of SOX that required firms to file an 8-K within four business days of the consummation of a material contract (e.g., Li, 2013). 32 selective disclosure) to mitigate the informational problems created by complex financial statements. 5.4 Two quasi-natural experiments Panel A of Table 10 presents mean and median values for our measures of financial statement complexity pre- and post-SFAS133, for affected firms and a matched sample of unaffected firms. Panel B presents mean and median values for our measures of financial statement complexity pre- and post-SFAS157, for affected and a matched sample of unaffected firms. Consistent with our text-based measures of complexity reflecting the complexity of the underlying accounting rules, we find significantly larger increases in both ReadIndex and Length for firms affected by SFAS 133 and firms affected by SFAS 157. Figure 3 in Appendix C plots the average values of each measure of voluntary disclosure for the sample of affected and unaffected firms around the adoption of SFAS 133 and the adoption of SFAS 157. These plots provide some visual evidence that both groups of firms had similar levels and trends in voluntary disclosure prior to the rule changes, but widely divergent levels of voluntary disclosure after the rule change. Panel C of Table 10 presents results from estimating equation (4). Across all specifications, we find the average treatment effect is highly statistically significant (DiD ATE tstats range from 2.56 to 4.77). Collectively, the results from our two quasi-natural experiments suggest managers give specific consideration to the complexity of accounting standards, and help alleviate concerns that a correlated omitted variable explains both complexity of the financial statements and the demand for voluntary disclosure. 5.5 Alternative Interpretation: Voluntary disclosure as additional obfuscation One alternative interpretation of the positive association between financial statement complexity and voluntary disclosure is that complex financial statements reflect an intentional 33 choice by managers to obfuscate and hide information from investors, and such managers issue more voluntary disclosure in an attempt to mislead investors and reinforce a “false narrative.” While plausible, this alternative interpretation is generally inconsistent with the findings from our cross-sectional tests on firm performance and earnings management (Table 6). Presumably, if firms were issuing voluntary disclosures to mislead investors, the positive relation between financial statement complexity and voluntary disclosure would be higher when managers have greater incentives to obfuscate. However, we find the opposite––the positive relation between financial statement complexity and voluntary disclosure is lower when managers have greater incentives to obfuscate. Nevertheless, in untabulated analyses we conduct two additional sets of tests in an effort to further address this concern. First, we examine whether the accuracy of management forecasts varies with financial statement complexity. Lehavy et al. (2011) argue that analysts are less accurate when financial statements are complex because analysts have less information. However, managers should not be similarly affected. Consistent with this––and counter to the notion their forecasts are intended to mislead investors––we find no evidence that managers’ forecasts are less accurate when financial statements are complex, and some evidence that their forecasts are actually more accurate when financial statements are complex.34 Second, consistent with an extensive prior literature that finds management forecasts (and voluntary disclosures more generally) improve liquidity and enhance transparency, we find that management forecasts and liquidity are positively related in our sample. We argue that the findings from our cross-sectional tests and these additional tests are inconsistent with the notion that managers are issuing more voluntary disclosure in order to mislead investors. 34 We note that this result is already somewhat in the literature. While not their primary focus, Hutton et al. (2012) examine when managers are more accurate than analysts, and find managers are more accurate than analysts when the Fog index is high. They do not discuss the result further (p. 1233, Table 4). 34 6. Supplemental analyses 6.1 Alternative measures of financial statement complexity 6.1.1 Alternative text-based measures of complexity Throughout all of our analyses, we treat ReadIndex and Length as two different empirical measures of the same underlying construct—financial statement complexity. Accordingly, we include them separately in our regressions. However, in untabulated analyses we include ReadIndex and Length simultaneously in equation (1) and find that Length subsumes ReadIndex. The fact that one of our two measures of financial statement complexity subsumes the other is perhaps not surprising given that these measures are fairly highly, positively correlated (0.49). The empirical challenge when two variables measure the same underlying construct is that it is difficult to predict whether and when one measure will load incrementally to the other. We use two common approaches to address the robustness of our analysis with respect to the simultaneous inclusion of multiple measures of the same construct. The first approach follows Barth et al. (1997). We include both measures simultaneously in equation (1) and use an F-test to determine whether the coefficients on ReadIndex and Length are jointly different from zero. We find that the coefficients are jointly different from zero (two-tailed p-value < 0.01). The second approach follows Lang et al. (2012). We conduct a principal component analysis of our six readability measures and length. We find that only a single factor has an eigenvalue greater than one, that this factor explains 84% of the variation in all seven variables, and that this factor loads positively on Length and each of the measures of readability (see factor output in Table C2 of Appendix C). This provides a degree of confidence that both length and readability are measuring the same economic construct.35 In untabulated analysis, we find 35 We note that this contrasts with Lang and Stice-Lawrence (2015) who find that––pooling across annual reports from 42 different countries––Fog and Length are negatively correlated and load on two distinct principal components. 35 inferences are similar if we consolidate Length and the six measures of readability into a single text-based measure of financial statement complexity. 6.1.2 Alternative measures of financial statement complexity: Business complexity In this section, we assess the robustness of our results to an alternative measure of financial statement complexity based on the complexity of the firm’s business strategy. Specifically, we regress ReadIndex and Length on two sets of predictors of the firm’s business complexity. Our first set of predictors includes firm size, leverage, growth opportunities, absolute returns, acquisitions, capital intensity, capital expenditures, research and development, the amount raised from stock and debt issuances, cash flow volatility, and indicator variables for whether the firm is audited by a Big 5 auditor, had a goodwill impairment, and had a restructuring charge (e.g., Li, 2008; Bushee et al, 2015). Our second set of predictors adds ROA, Loss and firm fixed effects to these variables (e.g., Lang and Stice-Lawrence, 2015). The predicted values from these regressions are a linear combination of variables that measure the complexity of the firm’s business strategy. As such, the predicted value can be considered as an additional measure of financial statement complexity that combines readability/length with more traditional measures of business complexity identified in the literature (e.g., R&D, acquisitions). Variable definitions and results appear in Panel A of Table C3 in Appendix C.36 Panel B of Table C3 in Appendix C presents results from re-estimating equation (1) using the predicted and residual values from the respective first-stage model in Panel A. We find that both the predicted and residual values are positively related to voluntary disclosure, and that the relation is much stronger for the predicted values. We caveat, that to interpret the predicted (residual) value as the non-discretionary (discretionary) component of financial statement 36 The computation of cash flow volatility requires five years of data for each firm-year and reduces our sample to 67,008 observations. 36 complexity, one needs to assume that discretion is uncorrelated with the determinants in the model. Prior literature suggests that may not be the case. For example, Li (2008) interprets the correlations between Loss and measures of readability and length as evidence of discretion. Thus, this analysis should not be interpreted as separating non-discretionary and discretionary components of readability and length. We advise readers that the results from this analysis should be interpreted with caution. 6.2 Changes in analyst forecasts around the 10-K We examine whether the relation between financial statement complexity and voluntary disclosure varies with analysts’ reaction to the 10-K. Analyst forecast behavior is commonly used to measure the quality of the firm’s information environment (e.g., Lang et al., 2012), so one can think of these tests as analogous to cross-sectional tests regarding the changes in liquidity around the 10-K. We construct two new variables that measure the effect of the 10-K on analysts’ forecasts: (i) the magnitude of the revision in the consensus analyst forecast around the 10-K, and (ii) the ex post accuracy of the revised consensus forecast. Per the regression specification used in our cross-sectional tests (see for example Table 4), we interact these analyst variables with our measures of financial statement complexity and include them in equation (1). Results appear in Table C4 of Appendix C. We find managers are less likely to provide voluntary disclosure subsequent to filing complex financial statements when analysts revise their forecasts in response to the 10-K and when those revisions are more ex post accurate. These findings are consistent with the notion that managers use their forecasts to “guide” analysts’ expectations (e.g,, Ajinkya and Gift, 1984), and are related to prior work that documents managers have a comparative advantage in forecasting earnings of firms with complex financial statements––when financial statement complexity is high, analysts are less accurate (e.g., Lehavy et al., 2011) but managers are more accurate (e.g., Hutton et al., 2012). 37 7. Conclusion A growing literature documents that complex financial statements negatively affect the information environment. In this paper, we examine whether managers use voluntary disclosure to mitigate these negative effects. We test our predictions by analyzing the relation between financial statement complexity and subsequent voluntary disclosure using three distinct sets of tests. First, using traditional cross-sectional and within-firm designs, we find that more complex financial statements are followed by more frequent and immediate voluntary disclosure. Second, examining cross-sectional variation in the relation between financial statement complexity and voluntary disclosure, we find that the relation is stronger when liquidity decreases around the filing of the financial statements and when firms have more outside monitors, and that the relation is weaker when firms have poor performance and greater earnings management. Third, employing two quasi-natural experiments, we find that firms affected by the adoption of complex accounting standards (e.g., SFAS 133 and SFAS 157) increase voluntary disclosure to a greater extent than unaffected firms. We conduct a battery of robustness tests and supplemental analyses and find our results are robust to changes in research design and variable measurement. By using three sets of tests—employing cross-sectional and within-firm designs, examining cross-sectional variation, and using two quasi-natural experiments—we strive to alleviate concerns that our collective results are attributable to alternative explanations. However, we recognize that we cannot definitively rule out the possibility that our results are driven by an omitted variable, and that more research is needed to further understand the effect of financial statement complexity on the information environment. 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Information quality and discretionary disclosure. Journal of Accounting and Economics 12, 365–80. Waymire, G., 1985. Earnings volatility and voluntary management forecast disclosure. Journal of Accounting Research, 268–295. You, H. Zhang, X., 2009. Financial statement complexity and investor underreaction to 10-K information. Review of Accounting Studies. 14, 559–586. 42 Appendix A. Variable definitions Measures of financial statement complexity ReadIndex First principal component of the following six measures of readability: Flesch-Kincaid readability, Gunning Fog readability index, RIX readability, ARI readability, SMOG readability, and LIX readability. See Appendix B for details. Length Natural logarithm of the number of words in the firm’s 10-K Measures of voluntary disclosure Frequency Number of management forecasts issued over the 12 months following the 10-K filing date. Frequency90 Number of management forecasts issued over the 90 days following the 10-K filing date. Frequency60 Number of management forecasts issued over the 60 days following the 10-K filing date. Frequency30 Number of management forecasts issued over the 30 days following the 10-K filing date. Immediacy Number of days between the 10-K filing date and the firm's first management forecast issued thereafter, multiplied by –1. Number of management forecasts issued between the fiscal year-end date and the 10-K filing date. PreFrequency Additional variables Size Natural logarithm of market value of equity, measured at the fiscal year-end. ROA Industry-year adjusted return on assets, measured as income before extraordinary items scaled by total assets. Loss Indicator variable equal to one if net income is negative, and zero otherwise. Leverage Long term debt plus short term debt, scaled by total assets. MTB Market value of equity plus book value of liabilities divided by book value of assets, measured at the fiscal year-end. SpecialItems Special items scaled by total assets. Returns Buy and hold return over the 12 months prior to the 10-K filing date. σReturns Standard deviation of monthly returns over the 12 months prior to the 10-K filing date. ∆Illiquidity Average value of the Amihud (2002) measure of illiquidity on day t = 0 and day t = 1 relative to the 10-K filing date, less the average value from t = –5...–50, multiplied by 106. ∆Spread Average value of the bid-ask spread on day t = 0 and day t = 1 relative to the 10-K filing date, less the average value from t = –5...–50, multiplied by 100, where bid-ask spread is calculated as (ask–bid)/price using data on closing prices and quotes from CRSP NAnalysts Number of analysts with one-year ahead earnings forecasts as of the 10-K filing date. NInstitutions Number of institutional investors as of the 10-K filing date. AbAcc Performance-matched abnormal accruals (e.g., Kothari et al., 2005). 43 Appendix B. Details on readability index We construct our readability index (ReadIndex) as the first principal component of the six measures of readability defined below. Higher values of ReadIndex correspond to less readable text. Each measure of readability is normalized prior to conducting the factor analysis. Factor analysis is conducted on the full sample of 10-Ks between 1995 and 2012 prior to requiring data on control variables (sample of 86,236 firm-year observations). Measures of readability Flesch Kincaid The Flesch-Kincaid Readability Index: 0.39 * (number of words / number of sentences) + 11.8 * (number of syllables / number of words) – 15.59 LIX The LIX Readability Index is equal to: (number of words / number of sentences) + (number of words over 6 letters * 100/ number of words) RIX The RIX Readability Index: (number of words with 7 characters or more) / (number of sentences) Fog The Gunning Fog Index: 0.4 * (number of words / number of sentences) + 40 * (number of words with more than two syllables / number of words) ARI The Automated Readability Index (ARI): 4.71 * (number of characters / number of words) + 0.5 * (number of words / number of sentences) − 21.43 SMOG The SMOG Index: 1.043 * sqrt(30 * number of words with more than two syllables / number of sentences) + 3.1291 Principal component output Factor 1st 2nd 3rd 4th 5th 6th Eigenvalue 5.62 0.21 0.11 0.05 0.01 0.01 Proportion of the variation explained 93.62% 3.43% 1.85% 0.82% 0.19% 0.09% Cumulative Proportion of the variation explained 93.62% 97.05% 98.91% 99.72% 99.91% 100.00% Readability Measures FleschKincaid LIX RIX Fog ARI SMOG Correlation matrix (1) (1) (2) (3) (4) (5) (6) (7) 0.95 0.96 0.96 0.87 0.97 0.94 (2) 0.97 0.96 0.96 0.86 0.95 0.93 (3) 0.99 0.95 0.95 0.90 0.94 0.98 (4) 0.97 0.94 0.93 (5) 0.91 0.84 0.89 0.84 0.86 0.99 0.93 0.84 0.87 (6) 0.98 0.95 0.94 1.00 0.85 (7) 0.96 0.91 0.98 0.90 0.85 0.90 0.92 Legend: (1) ReadIndex, (2) Flesch Kincaid, (3) LIX, (4) RIX, (5) Fog, (6) ARI, (7) SMOG 44 First Principal Component Weights 0.17400 0.17584 0.17545 0.16306 0.17321 0.17253 Table 1. Descriptive statistics Panel A presents descriptive statistics for the variables used in our analysis. Panel B presents correlations between the variables used in our analysis. Spearman (Pearson) correlations appear above (below) the diagonal. All variables are as defined in Appendix A. Sample of 72,366 firm-year observations from 1995 to 2012. Panel A. Distribution of variables Variable Observations Mean Std 25th Median 75th Measures of voluntary disclosure Frequency Frequency90 Frequency60 Frequency30 Immediacy 72,366 72,366 72,366 72,366 26,509 2.62 0.59 0.37 0.07 –108.52 5.35 1.37 0.98 0.34 96.94 0.00 0.00 0.00 0.00 –153.00 0.00 0.00 0.00 0.00 –63.00 2.00 0.00 0.00 0.00 –44.00 –0.01 10.25 0.92 0.59 –0.59 9.89 –0.05 10.28 0.52 10.64 5.64 0.00 0.22 1.94 –0.02 0.32 0.14 0.15 –0.11 0.02 4.61 97.97 0.49 1.98 0.23 0.22 1.79 0.07 0.47 0.67 0.10 2.93 1.27 5.80 132.53 0.50 4.21 –0.02 0.02 1.03 –0.01 0.00 –0.25 0.08 –0.04 –0.26 1.00 16.00 0.00 5.55 0.02 0.16 1.29 0.00 0.00 0.05 0.12 0.00 –0.02 2.00 51.00 0.00 6.97 0.09 0.35 2.05 0.00 1.00 0.36 0.18 0.00 0.16 6.00 124.00 1.00 Measures of financial statement complexity ReadIndex Length 72,366 72,366 Additional variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns ∆Illiquidity ∆Spread NAnalysts NInstitutions AbAcc 72,366 72,366 72,366 72,366 72,366 72,366 72,366 72,366 69,066 69,066 72,366 72,366 59,068 45 Table 1. Descriptive statistics (cont’d) Panel B. Correlation matrix (1) (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) 0.89 0.70 0.34 0.45 0.12 0.25 0.34 0.15 –0.01 0.04 0.01 –0.10 0.04 –0.10 0.02 –0.01 0.34 0.36 –0.05 (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) 0.81 0.66 0.81 0.33 0.43 0.52 0.51 0.75 0.82 0.60 0.14 0.14 0.09 0.04 0.06 0.27 0.27 0.19 0.07 0.14 0.47 0.40 0.35 0.24 0.14 0.11 0.22 0.36 0.30 0.26 0.22 0.10 0.13 0.07 0.09 0.12 0.01 0.01 –0.01 0.01 –0.02 0.02 0.15 0.11 –0.14 0.18 0.14 0.12 0.06 0.02 0.04 –0.05 0.33 0.26 –0.21 –0.13 –0.11 –0.09 –0.06 –0.05 –0.09 –0.11 –0.03 –0.06 –0.04 –0.02 –0.11 –0.10 –0.06 –0.04 –0.04 0.06 0.08 –0.33 –0.01 –0.02 0.01 –0.29 0.05 0.04 0.03 0.00 –0.01 –0.02 –0.03 0.25 0.02 –0.02 0.22 0.15 –0.29 –0.04 –0.07 –0.04 0.00 –0.07 –0.01 –0.06 –0.34 0.14 –0.09 0.13 –0.16 0.48 –0.18 0.13 0.11 0.09 0.05 0.05 0.08 0.13 0.29 0.05 0.03 0.13 –0.04 –0.03 0.02 –0.02 0.04 0.04 0.03 0.02 0.03 0.02 0.05 0.07 0.01 0.01 0.04 –0.01 0.01 –0.03 –0.01 0.20 0.47 0.39 0.29 0.18 0.11 0.19 0.26 0.69 0.13 0.02 0.26 –0.08 –0.18 0.07 –0.12 0.23 0.05 0.48 0.41 0.30 0.17 0.16 0.24 0.41 0.92 0.18 0.11 0.24 –0.08 –0.25 0.17 –0.26 0.29 0.06 0.71 –0.05 –0.05 –0.04 –0.02 –0.02 –0.03 –0.03 –0.08 0.00 0.01 –0.04 0.10 –0.01 –0.02 0.01 –0.02 0.00 –0.08 –0.07 0.80 0.45 0.58 0.12 0.23 0.30 0.13 –0.01 0.02 0.01 –0.09 0.02 –0.09 0.02 0.00 0.31 0.32 –0.05 0.49 0.52 0.08 0.16 0.21 0.11 –0.03 0.02 0.00 –0.06 0.02 –0.06 0.01 0.00 0.23 0.22 –0.04 0.36 0.04 0.07 0.15 0.06 –0.01 0.01 –0.01 –0.04 0.00 –0.01 0.01 0.00 0.17 0.18 –0.02 0.07 0.18 0.15 0.08 0.00 –0.05 0.01 –0.06 –0.03 –0.09 0.01 0.00 0.11 0.15 –0.02 0.49 0.22 0.06 0.04 0.01 –0.04 0.05 –0.02 –0.03 0.01 0.00 0.16 0.18 –0.03 0.35 0.12 0.15 –0.07 –0.04 0.08 –0.03 –0.03 0.02 0.01 0.23 0.32 –0.03 0.05 0.05 0.16 0.12 –0.33 0.16 –0.33 0.06 –0.01 0.70 0.80 –0.07 –0.04 0.04 0.00 0.04 –0.01 0.02 0.00 0.00 0.04 0.07 0.00 –0.17 –0.03 0.05 –0.04 –0.02 0.00 0.01 0.01 0.06 0.01 –0.03 0.12 0.23 0.21 0.02 0.01 0.09 0.05 –0.02 –0.34 0.14 –0.23 0.00 –0.02 0.04 0.06 0.11 –0.16 0.46 –0.01 0.04 –0.18 –0.23 –0.01 0.08 0.00 –0.04 0.03 0.06 –0.01 0.00 0.03 –0.17 –0.24 0.01 0.20 0.03 0.03 –0.01 –0.01 –0.01 0.01 0.73 –0.07 –0.05 Legend: (1) Frequency, (2) Frequency90 (3) Frequency60, (4) Frequency30, (5) Immediacy, (6) ReadIndex, (7) Length, (8) Size, (9) ROA, (10) Leverage, (11) MTB, (12) SpecialItems, (13) Loss, (14) Returns, (15) σReturns, (16) ∆Illiquidity, (17) ∆Spread, (18) NAnalysts, (19) NInstitutions, (20) AbAcc 46 Table 2. Distribution of voluntary disclosure by quintiles of financial statement complexity This table presents the average value for each measure of voluntary disclosure by quintile of financial statement complexity. p-values (two-tailed) appear in brackets, test for a difference in voluntary disclosure between extreme quintiles, and are based on standard errors clustered by firm and date. All variables are as defined in Appendix A. Variable Frequency Frequency90 Frequency60 Frequency30 Immediacy Variable Frequency Frequency90 Frequency60 Frequency30 Immediacy Q1 1.27 0.27 0.18 0.05 –123.86 Q1 0.61 0.12 0.09 0.04 –145.78 Q2 2.26 0.49 0.33 0.07 –111.99 ReadIndex quintile Q3 Q4 2.86 3.30 0.64 0.76 0.42 0.47 0.08 0.09 –104.72 –100.98 Q2 1.30 0.28 0.21 0.06 –112.38 Length quintile Q3 Q4 2.71 4.3 0.60 0.99 0.43 0.61 0.08 0.09 –95.75 –92.43 47 Q5 3.40 0.78 0.44 0.09 –101.05 Diff Q5–Q1 2.13 0.51 0.26 0.04 22.81 Diff p-value [<0.001] [<0.001] [<0.001] [<0.001] [<0.001] Q5 4.17 0.96 0.5 0.11 –96.27 Diff Q5–Q1 3.56 0.84 0.41 0.07 49.51 Diff p-value [<0.001] [<0.001] [<0.001] [<0.001] [<0.001] Table 3. Financial statement complexity and voluntary disclosure This table presents results from estimating the association between our two measures of financial statement complexity and voluntary disclosure. In Panel A, voluntary disclosure is measured as the number of forecasts over the 12 months following the filing of the 10-K (Frequency), in Panels B, C, and D voluntary disclosure is measured as the number of forecasts over the 90, 60, and 30 days following the filing of the 10-K (Frequency90, Frequency60, and Frequency30 respectively), and in Panel E, voluntary disclosure is measured using the number of days between the filing date of the 10-K and the first management forecast thereafter, multiplied by minus one (Immediacy). Columns (1) and (2) (Columns (3) and (4)) of each panel present results measuring financial statement complexity, using ReadIndex (Length). All variables are as defined in Appendix A. Independent variables are transformed into decile ranks and scaled to range from 0 to 1. t-statistics appear in parentheses and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Panel A. Voluntary disclosure 12 months subsequent to the 10-K filing Dependent variable: Frequency FS_Complexity = ReadIndex Variable FS_Complexity Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) FS_Complexity = Length (1) 0.98*** (7.40) (2) 1.51*** (9.63) (3) 2.90*** (21.32) (4) 4.32*** (22.63) 4.62*** (20.30) 3.82*** (24.19) –0.05 (–0.42) 0.35** (2.21) –1.73*** (–15.38) –0.48*** (–5.18) –0.29** (–2.08) –0.31* (–1.90) No 72,366 18.4 6.77*** (17.10) 2.30*** (15.20) 0.69*** (4.13) –2.33*** (–10.78) –0.59*** (–7.49) –0.20*** (–2.72) 0.07 (0.59) –1.30*** (–6.98) Yes 72,366 61.2 3.47*** (16.33) 3.56*** (24.11) –0.27** (–2.20) 0.91*** (6.06) –1.70*** (–15.31) –0.84*** (–9.81) –0.23** (–1.98) –0.32** (–2.19) No 72,366 20.4 4.92*** (15.20) 1.77*** (14.04) 0.33** (2.12) –1.47*** (–8.16) –0.37*** (–5.16) –0.46*** (–6.66) 0.12 (1.21) –1.30*** (–8.40) Yes 72,366 63.1 48 Table 3. Financial statement complexity and voluntary disclosure (cont’d) Panel B. Voluntary disclosure 90 days subsequent to the 10-K filing Dependent variable: Frequency90 FS_Complexity = ReadIndex Variable FS_Complexity Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) (1) 0.27*** (8.22) (2) 0.41*** (10.26) (3) 0.71*** (20.84) (4) 1.06*** (21.27) 1.04*** (18.71) 0.90*** (22.27) –0.03 (–1.07) 0.05 (1.36) –0.41*** (–14.47) –0.12*** (–5.39) –0.11*** (–3.00) –0.08* (–1.94) No 72,366 15.0 1.62*** (16.40) 0.53*** (13.30) 0.19*** (4.49) –0.65*** (–11.83) –0.15*** (–7.07) –0.08*** (–4.23) –0.01 (–0.33) –0.32*** (–6.72) Yes 72,366 52.5 0.77*** (14.84) 0.83*** (22.14) –0.09*** (–2.93) 0.19*** (5.19) –0.40*** (–14.42) –0.21*** (–9.73) –0.09*** (–3.09) –0.08** (–2.20) No 72,366 16.7 1.18*** (14.28) 0.40*** (11.78) 0.11*** (2.62) –0.44*** (–9.44) –0.10*** (–4.93) –0.15*** (–7.76) 0.00 (0.02) –0.32*** (–7.71) Yes 72,366 54.2 49 FS_Complexity = Length Table 3. Financial statement complexity and voluntary disclosure (cont’d) Panel C. Voluntary disclosure 60 days subsequent to the 10-K filing Dependent variable: Frequency60 FS_Complexity = ReadIndex Variable FS_Complexity Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) (1) 0.12*** (5.76) (2) 0.17*** (6.25) (3) 0.37*** (15.78) (4) 0.57*** (19.13) 0.51*** (18.21) 0.56*** (20.70) –0.07*** (–3.63) 0.07*** (2.66) –0.24*** (–13.10) –0.06*** (–3.96) –0.06** (–2.43) –0.05* (–1.93) No 72,366 8.9 0.81*** (13.57) 0.35*** (12.46) 0.11*** (3.59) –0.30*** (–8.82) –0.08*** (–5.19) –0.03** (–2.27) –0.00 (–0.12) –0.26*** (–8.45) Yes 72,366 42.5 0.36*** (12.47) 0.53*** (20.38) –0.10*** (–4.95) 0.14*** (5.78) –0.23*** (–12.94) –0.11*** (–7.32) –0.05** (–2.41) –0.05** (–2.16) No 72,366 9.8 0.56*** (10.44) 0.28*** (11.22) 0.06** (2.15) –0.18*** (–6.05) –0.05*** (–3.48) –0.07*** (–4.95) 0.00 (0.20) –0.26*** (–9.43) Yes 72,366 43.5 50 FS_Complexity = Length Table 3. Financial statement complexity and voluntary disclosure (cont’d) Panel D. Voluntary disclosure 30 days subsequent to the 10-K filing Dependent variable: Frequency30 FS_Complexity = ReadIndex Variable FS_Complexity Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) (1) 0.00 (0.27) (2) 0.01* (1.65) 0.14*** (15.77) 0.08*** (11.74) –0.00 (–0.21) 0.00 (0.34) –0.06*** (–10.25) –0.03*** (–7.06) –0.03*** (–6.15) 0.04*** (4.94) No 72,366 3.1 0.13*** (7.76) 0.07*** (7.13) 0.04*** (3.76) –0.03*** (–2.87) –0.03*** (–4.60) –0.01*** (–3.29) –0.02*** (–4.20) 0.01 (0.72) Yes 72,366 23.5 51 FS_Complexity = Length (3) 0.02*** (3.65) (4) 0.07*** (7.33) 0.13*** (14.15) 0.08*** (11.52) –0.00 (–0.49) 0.01 (1.09) –0.06*** (–10.17) –0.03*** (–7.96) –0.03*** (–6.02) 0.04*** (4.94) No 72,366 3.2 0.10*** (5.88) 0.06*** (6.33) 0.03*** (3.14) –0.01 (–1.32) –0.02*** (–3.97) –0.02*** (–4.36) –0.02*** (–4.09) 0.01 (0.75) Yes 72,366 23.7 Table 3. Financial statement complexity and voluntary disclosure (cont’d) Panel E. Voluntary disclosure immediacy subsequent to the 10-K filing Dependent variable: Immediacy FS_Complexity = ReadIndex Variable FS_Complexity Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) (1) 14.49*** (5.09) (2) 25.82*** (5.95) (3) 48.40*** (11.15) (4) 78.44*** (13.22) 49.58*** (11.72) 46.21*** (11.13) –6.00** (–2.28) –15.81*** (–4.45) –15.49*** (–7.33) –5.31*** (–2.84) –6.19* (–1.87) –12.20*** (–2.73) No 26,509 5.1 116.82*** (11.70) 40.82*** (6.73) 3.74 (0.76) –55.40*** (–9.43) –9.32*** (–3.42) –5.76** (–2.48) –3.56 (–1.00) –20.93*** (–3.71) Yes 26,509 36.1 30.64*** (6.68) 40.94*** (11.58) –9.63*** (–3.68) –5.96* (–1.86) –14.92*** (–7.05) –10.89*** (–5.81) –6.11** (–2.00) –10.63*** (–2.65) No 26,509 6.6 86.52*** (8.70) 32.96*** (6.30) –1.08 (–0.23) –36.93*** (–6.81) –6.10** (–2.31) –9.19*** (–4.10) –3.50 (–1.06) –15.37*** (–3.11) Yes 26,509 37.6 52 FS_Complexity = Length Table 4. Changes in illiquidity around the filing of the financial statements This table presents results from examining whether the relation between financial statement complexity (FS_Complexity) and subsequent voluntary disclosure (Frequency) varies with the change in illiquidity around the 10-K filing. Our model follows the specifications in Panel A of Table 3, except that we interact our measures of financial statement complexity with our measures of the change in illiquidity around the 10-K filing (∆Illiquidity and ∆Spread). All variables are as defined in Appendix A. For parsimony we do not tabulate coefficients on control variables. t-statistics appear in parentheses and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Dependent variable: Frequency FS_Complexity = ReadIndex Variable FS_Complexity FS_Complexity x ∆Illiquidity (1) 0.59*** (5.05) 0.85*** (4.79) FS_Complexity x ∆Spread ∆Illiquidity –0.27*** (–3.44) ∆Spread Controls Firm effects Observations R2 (%) Yes No 69,066 18.4 (2) 0.76*** (5.76) 0.50*** (3.70) 0.01 (0.20) Yes No 69,066 18.4 (3) 0.45*** (3.76) 0.78*** (4.42) 0.34*** (2.62) –0.28*** (–3.63) 0.07 (1.08) Yes No 69,066 18.4 FS_Complexity = Length (4) 1.06*** (6.59) 0.73*** (4.97) 0.24* (1.90) –0.32*** (–4.48) 0.11 (1.56) Yes Yes 69,066 61.8 53 (5) 2.15*** (16.43) 1.58*** (7.01) –0.59*** (–7.53) Yes No 69,066 20.4 (6) 2.55*** (18.16) 0.79*** (4.97) –0.13** (–2.42) Yes No 69,066 20.4 (7) 1.95*** (13.94) 1.49*** (6.62) 0.50*** (3.20) –0.59*** (–7.50) –0.02 (–0.32) Yes No 69,066 20.4 (8) 3.54*** (19.08) 1.34*** (7.28) 0.30** (2.07) –0.57*** (–7.83) 0.04 (0.60) Yes Yes 69,066 63.7 Table 5. External monitors This table presents results from examining whether the relation between financial statement complexity (FS_Complexity) and subsequent voluntary disclosure (Frequency) varies with the intensity of external monitoring. Our model follows the specifications in Panel A of Table 3, except that we interact our measures of financial statement complexity with our measures of external monitoring intensity (NAnalysts and NInstitutions). All variables are as defined in Appendix A. For parsimony we do not tabulate coefficients on control variables. t-statistics appear in parentheses and are based on standard errors clustered by firm and date. ***, ** , and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Dependent variable: Frequency FS_Complexity = ReadIndex Variable FS_Complexity FS_Complexity x NAnalysts (1) –0.87*** (–6.10) 3.40*** (8.44) FS_Complexity x NInstitutions NAnalysts 2.70*** (10.00) NInstitutions Controls Firm effects Observations R2 (%) Yes No 72,366 22.1 (2) –0.80*** (–6.20) 3.29*** (8.44) 5.84*** (17.50) Yes No 72,366 21.9 (3) –1.37*** (–8.85) 2.61*** (5.78) 1.61*** (3.90) 2.28*** (9.04) 5.25*** (16.88) Yes No 72,366 24.1 54 FS_Complexity = Length (4) –1.03*** (–5.55) 2.47*** (5.75) 1.85*** (4.36) –0.71** (–2.57) 5.36*** (14.80) Yes Yes 72,366 62.5 (5) –0.66*** (–3.75) 6.68*** (15.29) 0.87*** (3.25) Yes No 72,366 25.1 (6) –0.45*** (–2.60) 5.67*** (13.20) 3.95*** (11.46) Yes No 72,366 23.9 (7) –1.47*** (–7.38) 5.98*** (13.99) 1.62*** (3.94) 0.48** (2.28) 4.67*** (14.93) Yes No 72,366 26.8 (8) –1.66*** (–7.07) 6.04*** (12.72) 3.61*** (7.43) –2.19*** (–7.46) 2.62*** (7.16) Yes Yes 72,366 64.7 Table 6. Firm performance and earning management This table presents results from examining whether the relation between financial statement complexity (FS_Complexity) and subsequent voluntary disclosure (Frequency) varies with firm performance and earnings management. Our model follows the specifications in Panel A of Table 3, except that we interact our measures of financial statement complexity with our measures of firm performance and earnings management (ROA, Loss, and AbAcc). All variables are as defined in Appendix A. For parsimony we do not tabulate coefficients on control variables. t-statistics appear in parentheses and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Dependent variable: Frequency FS_Complexity = ReadIndex Variable FS_Complexity FS_Complexity x ROA (1) –0.93*** (–4.82) 4.17*** (10.66) FS_Complexity x Loss (2) 1.83*** (9.34) –1.64*** (–8.04) FS_Complexity x AbAcc ROA Loss 1.35*** (5.97) –0.63*** (–6.15) 3.53*** (20.21) 0.22* (1.85) Yes No 59,068 18.4 Yes No 59,068 18.1 AbAcc Controls Firm effects Observations R2 (%) (3) 1.88*** (8.17) –1.20*** (–4.57) 3.52*** (20.09) –0.61*** (–5.96) 0.21* (1.73) Yes No 59,068 18.0 FS_Complexity = Length (4) 0.29 (1.09) 3.94*** (10.24) –1.40*** (–6.85) –1.25*** (–4.79) 1.48*** (6.56) 0.07 (0.64) 0.25** (2.07) Yes No 59,068 18.6 55 (5) 1.02*** (3.78) 2.40*** (6.95) –0.63*** (–3.56) –0.53*** (–2.60) 1.09*** (5.08) 0.04 (0.40) 0.42*** (3.64) Yes Yes 59,068 61.1 (6) 1.28*** (5.45) 4.31*** (9.16) 0.72*** (3.15) –1.14*** (–12.51) Yes No 59,068 20.8 (7) 4.49*** (23.13) –3.09*** (–14.31) 3.15*** (19.45) 0.50*** (4.83) Yes No 59,068 20.9 (8) 4.57*** (19.29) –2.08*** (–7.74) 3.03*** (19.04) –1.07*** (–11.29) 0.60*** (6.03) Yes No 59,068 20.5 (9) 3.51*** (11.62) 3.85*** (8.49) –2.89*** (–13.67) –2.17*** (–8.11) 1.08*** (4.80) 0.32*** (3.29) 0.61*** (6.32) Yes No 59,068 21.5 (10) 4.53*** (13.86) 3.07*** (7.52) –1.80*** (–9.04) –0.92*** (–4.29) –0.04 (–0.20) 0.36*** (3.32) 0.53*** (5.04) Yes Yes 59,068 63.5 Table 7. Robustness—Financial statement complexity and pre-emptive voluntary disclosure This table presents results from estimating the association between financial statement complexity and voluntary disclosure issued prior to the 10–K filing date. Panel A presents results from repeating the tests in Panel A of Table 3, replacing the dependent variable with voluntary disclosure issued between the fiscal year-end and the 10-K filing date, inclusive (PreFrequency). Panel B presents results from repeating the tests in Panel A of Table 3 after including PreFrequency as an additional control variable. All variables are as defined in Appendix A. t-statistics appear in parentheses and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two–tail), respectively. Panel A. Financial statement complexity and voluntary disclosure prior to the 10-K Dependent variable: PreFrequency FS_Complexity = ReadIndex Variable FS_Complexity Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) FS_Complexity = Length (1) 0.26*** (8.23) (2) 0.42*** (10.26) (3) 0.69*** (20.99) (4) 1.08*** (23.18) 0.95*** (18.34) 0.86*** (21.99) –0.05 (–1.62) 0.08** (2.05) –0.40*** (–14.45) –0.12*** (–5.04) –0.15*** (–4.00) –0.08** (–2.11) No 72,366 13.2 1.59*** (16.64) 0.48*** (11.50) 0.20*** (4.63) –0.65*** (–12.09) –0.14*** (–6.40) –0.08*** (–3.75) –0.05 (–1.58) –0.36*** (–7.83) Yes 72,366 50.7 0.69*** (14.28) 0.80*** (21.90) –0.10*** (–3.42) 0.21*** (5.79) –0.39*** (–14.34) –0.20*** (–9.27) –0.13*** (–4.27) –0.08** (–2.38) No 72,366 14.9 1.14*** (14.26) 0.35*** (9.91) 0.12*** (2.79) –0.43*** (–9.64) –0.09*** (–4.26) –0.14*** (–7.18) –0.04 (–1.47) –0.36*** (–8.97) Yes 72,366 52.4 56 Table 7. Robustness—Financial statement complexity and pre-emptive voluntary disclosure (cont’d) Panel B. Controlling for voluntary disclosure prior to the 10-K Dependent variable: Frequency FS_Complexity = ReadIndex Variable FS_Complexity PreFrequency Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Firm effects Observations R2 (%) (1) 0.51*** (6.03) 8.57*** (46.05) (2) 0.91*** (7.86) 5.72*** (36.83) (3) 1.35*** (14.45) 8.43*** (44.79) (4) 2.65*** (18.87) 5.38*** (37.22) 1.74*** (17.55) 1.71*** (19.66) –0.05 (–0.67) 0.34*** (3.55) –0.74*** (–10.03) –0.28*** (–4.50) 0.13 (1.59) –0.29*** (–2.70) No 72,366 49.0 3.97*** (15.25) 1.42*** (14.25) 0.38*** (2.86) –1.32*** (–8.70) –0.32*** (–4.97) –0.14** (–2.38) 0.21** (2.48) –0.86*** (–6.19) Yes 72,366 69.4 1.27*** (12.29) 1.63*** (19.02) –0.15** (–2.06) 0.60*** (6.29) –0.74*** (–10.16) –0.44*** (–7.63) 0.15* (1.94) –0.29*** (–2.89) No 72,366 49.4 3.01*** (12.63) 1.14*** (12.15) 0.18 (1.38) –0.85*** (–6.06) –0.20*** (–3.29) –0.30*** (–5.26) 0.24*** (3.04) –0.88*** (–7.15) Yes 72,366 70.1 57 FS_Complexity = Length Table 8: Robustness—Alternative measure of voluntary disclosure: 8-Ks This table presents results from estimating the association between our two measures of financial statement complexity and the frequency and immediacy of 8-K disclosures. Panel A presents the average value for each measure of 8-K disclosure by quintile of financial statement complexity. Frequency8K is the number of 8-Ks issued over the 12 months following the 10-K filing date. Frequency8K90, Frequency8K60, and Frequency8K30 are the number of 8-Ks issued over the 90, 60, and 30 days following the 10-K filing date respectively. Immediacy8K is the number of days between the 10-K filing date and the firm's first 8-K filing thereafter, multiplied by –1. Panel B presents results from repeating the tests in Panels A through E of Table 3, using the each of the five measures of 8-K disclosure. For each of the five measures, we present results separately for our two measures of financial statement complexity and two regression designs––pooled and within-firm (5 x 2 x 2). For parsimony we do not tabulate coefficients on control variables. All variables are as defined in Appendix A. t-statistics (two-tailed p-values) appear in parentheses (brackets) and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Panel A. Portfolio sorts Variable Frequency8K Frequency8K90 Frequency8K60 Frequency8K30 Immediacy8K Variable Frequency8K Frequency8K90 Frequency8K60 Frequency8K30 Immediacy8K Q1 4.93 1.26 0.87 0.35 –84.25 Q1 2.61 0.63 0.44 0.18 –112.03 Q2 7.40 1.94 1.33 0.51 –64.34 Q2 4.90 1.24 0.88 0.33 –76.72 ReadIndex quintile Q3 Q4 8.67 9.41 2.31 2.55 1.54 1.66 0.60 0.67 –56.58 –52.81 Length quintile Q3 7.89 2.06 1.42 0.53 –52.21 58 Q4 10.75 2.90 1.91 0.74 –39.75 Q5 9.39 2.52 1.60 0.67 –56.69 Diff Q5–Q1 4.46 1.26 0.73 0.32 27.56 Diff p-value [<0.001] [<0.001] [<0.001] [<0.001] [<0.001] Q5 13.64 3.75 2.35 1.01 –33.96 Diff Q5–Q1 11.03 3.12 1.91 0.83 78.07 Diff p-value [<0.001] [<0.001] [<0.001] [<0.001] [<0.001] Table 8: Robustness—Financial statement complexity and 8-K disclosures (cont’d) Panel B. Regressions of 8-K disclosures on financial statement complexity Dependent variable: FS_Complexity ReadIndex Controls Within-Firm R2 ReadIndex Controls Within-Firm R2 Length Controls Within-Firm R2 Length Controls Within-Firm R2 Table 3 Panel A Table 3 Panel B Table 3 Panel C Table 3 Panel D Table 3 Panel E Frequency8K Frequency8K90 Frequency8K60 Frequency8K30 Immediacy8K (1) (2) (3) (4) (5) *** 2.99 (12.28) Yes No 16.8 *** 0.90 (12.44) Yes No 12.7 3.60*** (13.13) Yes Yes 54.5 *** 0.54 (11.10) Yes No 7.7 *** 0.23 (11.53) Yes No 5.2 21.58*** (10.51) Yes No 5.7 1.24*** (14.60) Yes Yes 45.1 0.72*** (12.23) Yes Yes 38.5 0.29*** (11.25) Yes Yes 30.3 30.98*** (9.19) Yes Yes 34.4 11.02*** (57.93) Yes No 33.8 3.21*** (53.27) Yes No 27.4 2.05*** (46.31) Yes No 19.6 0.83*** (42.53) Yes No 11.4 88.93*** (33.42) Yes No 15.0 11.33*** (48.21) Yes Yes 62.0 3.54*** (46.24) Yes Yes 52.3 2.25*** (39.81) Yes Yes 44.4 0.88*** (32.48) Yes Yes 33.2 107.13*** (28.22) Yes Yes 39.9 59 Table 9: Robustness—Time-period analysis This table presents results from estimating the association between financial statement complexity and voluntary disclosure subsequent to the 10-K filing over various time periods. Panel A presents results from estimating the regression specification in Panel A of Table 3 using separate annual cross-sectional regressions. Columns (1) and (2) present results using Frequency as the dependent variable. Columns (3) and (4) presents results using Frequency8K as the dependent variable. We report the time-series average of the estimated annual slope coefficients (FM coef.), their t-statistics (FM t-stat), and the average of the annual regression R2. Panel B presents results from estimating the regression specification in Panel A of Table 3 over three sub-samples: 1995 to 1999, before Regulation Fair Disclosure became effective (Pre-RegFD and Pre-Rule8K); 2000 to 2004, after RegFD but before the “Additional Form 8-K Disclosure Requirements and Acceleration of Filing Date” rule became effective (Post-RegFD and PreRule8K); and 2005 to 2012, after both rules became effective (Post-RegFD and Post-Rule8K). Columns (1) and (2) present results using Frequency as the dependent variable. Columns (3) and (4) presents results using Frequency8K as the dependent variable. For parsimony we do not tabulate coefficients on control variables. All variables are as defined in Appendix A. t-statistics appear in parentheses. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Panel A. Annual cross-sectional regressions Variable Statistic FS_Complexity FM coef. FM t-stat. Controls #Years Avg R2 Dependent variable: Frequency Dependent variable: Frequency8K FS_Complexity = FS_Complexity = ReadIndex (1) Length (2) ReadIndex (3) Length (4) 0.27*** (3.64) –0.01 (–0.19) 1.04*** (10.20) 4.04*** (8.71) Yes 18 17.0 Yes 18 16.8 Yes 18 10.6 Yes 18 26.0 Panel B. Time-period subsamples Dependent variable: Frequency FS_Complexity = Time Period Variable 1995 to 1999 Pre-RegFD Pre-Rule8k FS_Complexity 2000 to 2004 Post-RegFD Pre-Rule8K 2005 to 2012 Post-RegFD Post-Rule8K Controls N R2 (%) FS_Complexity Controls N R2 (%) FS_Complexity Controls N R2 (%) ReadIndex (1) Length (2) ReadIndex (3) Length (4) –0.02 (–0.63) Yes 22,102 8.7 –0.03 (–1.17) Yes 22,102 8.7 0.66*** (7.24) Yes 22,102 10.7 1.71*** (14.43) Yes 22,102 12.0 0.41*** (3.21) Yes 20,742 15.0 0.89*** (5.29) Yes 20,742 15.2 2.08*** (9.49) Yes 20,742 16.3 8.03*** (20.50) Yes 20,742 25.2 0.79*** (3.07) Yes 29,522 20.8 0.51* (1.75) Yes 29,522 20.7 1.32*** (5.85) Yes 29,522 12.2 5.75*** (20.94) Yes 29,522 15.5 60 Dependent variable: Frequency8K FS_Complexity = Table 10: Quasi-natural experiments—Changes in accounting standards This table presents results from estimating the effects of two changes in accounting standards, SFAS 133 and SFAS 157, on voluntary disclosure. For each change in accounting standards, we use a sample of firms affected by the change (treatment group) and a propensity score matched sample of firms unaffected by the change (control group). Our analysis spans a window of three years prior to and three years after the change. Panel A presents the difference in mean and median values of our measures of financial statement complexity before and after SFAS 133. Panel B presents the difference in mean and median values of our measures of financial statement complexity before and after SFAS 157. Panel C presents results from using a generalized difference-in-differences design to estimate the effect of the change in accounting standards on voluntary disclosure. Columns (1) and (2) of Panel C show results for SFAS 133. Columns (3) and (4) of Panel C show results for SFAS 157. In columns (1) and (2), Post is an indicator variable equal to one for fiscal periods beginning after June 15, 2000 and zero otherwise, and Affected is an indicator variable equal to one for firms with data on unrealized gains and losses on derivatives in accumulated other comprehensive income and zero otherwise. In columns (3) and (4), Post is an indicator variable equal to one for fiscal periods beginning after November 15, 2007 and zero otherwise, and Affected is an indicator variable equal to one for firms with data on level 1, level 2 or level 3 assets or liabilities and zero otherwise. All other variables are as defined in Appendix A. t-statistics (two-tailed p-values) appear in parentheses (brackets) and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (twotail), respectively. Panel A. Changes in financial statement complexity around SFAS133 Affected Measure of FS_Complexity ReadIndex Length Unaffected Statistic Mean Median PreFAS133 –0.04 –0.17 PostFAS133 0.00 –0.16 PreFAS133 –0.04 –0.12 PostFAS133 –0.20 –0.21 DiD ATE 0.20 0.10 p–value DiD = 0 [<0.001] [0.003] Mean Median 9.96 9.96 10.19 10.19 9.98 9.99 10.11 10.11 0.10 0.11 [<0.001] [<0.001] Panel B. Changes in financial statement complexity around SFAS157 Affected Measure of FS_Complexity ReadIndex Length Unaffected Statistic Mean Median PreFAS157 0.08 0.03 PostFAS157 0.20 0.15 PreFAS157 0.01 –0.02 PostFAS157 0.02 0.03 DiD ATE 0.11 0.07 p–value DiD = 0 [<0.001] [<0.001] Mean Median 10.50 10.24 10.65 10.40 10.38 10.15 10.4 10.16 0.13 0.15 [<0.001] [<0.001] 61 Table 10: Quasi-natural experiments—Changes in accounting standards (cont’d) Panel C. Generalized difference-in-differences design Variable Post * Affected DiD ATE FAS133 FAS157 Dependent variable: Dependent variable: Frequency (1) 0.68*** (4.13) Frequency8K (2) 0.48** (2.56) 2.96*** (5.50) 0.76*** (3.54) 0.00 (0.00) 0.04 (0.15) –0.18 (–1.48) –0.22* (–1.91) –0.53*** (–4.45) –0.20 (–1.17) Firm & Year 10,851 52.3 –2.30*** (–3.72) –0.13 (–0.44) –0.15 (–0.38) 2.38*** (5.93) 0.30** (1.98) –0.02 (–0.12) –0.21 (–1.30) 0.24 (0.93) Firm & Year 10,851 67.6 DiD ATE Frequency (3) 1.17*** (4.77) Frequency8K (4) 0.77*** (2.77) 3.77*** (8.07) 0.31* (1.66) 0.38 (1.16) 0.80** (2.47) 0.11 (0.86) –0.41*** (–3.50) 0.14 (0.86) –0.48** (–2.23) Firm & Year 17,060 80.4 –1.46** (–2.33) 0.20 (0.93) 0.08 (0.24) 1.34*** (3.69) –0.07 (–0.44) 0.06 (0.46) –0.51*** (–2.77) –0.26 (–1.12) Firm & Year 17,060 67.6 Control variables Size ROA Leverage MTB SpecialItems Loss Returns σReturns Fixed Effects Observations R2 (%) 62 Appendix C. Supplemental analyses This appendix reports results for additional tests briefly described in the paper. Contents: Figure 1. Time-series of voluntary disclosure by quintile of financial statement complexity Figure 2. Time-series of annual cross-sectional regression coefficients Figure 3. Time-series of voluntary disclosures for treatment and control firms around SFAS 157 and SFAS 133 Table C1. Quasi-natural experiments: Covariate balance Panel A. Covariate balance between observations affected and unaffected by SFAS 133 Panel B. Covariate balance between observations affected and unaffected by SFAS 157 Table C2. Principal component analysis including measures of readability and length Table C3. Decomposing financial statement complexity Panel A. Models of financial statement complexity Panel B. Models of voluntary disclosure Table C4. Changes in analyst forecasts around the filing of the financial statements 63 Figure 1. Cumulative voluntary disclosure by quintile of financial statement complexity This figure plots cumulative number of management forecasts (Frequency) from the beginning of the fiscal year to twelve months after the 10-K filing by intervals of one month. The initial value in month zero is the number of management forecasts issued between the fiscal year-end date and the 10-K filing date. We plot the cumulative number of forecasts separately for the lowest quintile of financial statement complexity (Quintile 1) and the highest quintile of financial statement complexity (Quintile 5). Panel A presents results for ReadIndex, Panel B for Length. Panel A. Cumulative voluntary disclosure by extreme quintiles of ReadIndex 4.5 Quintile 5 Quintile 1 4 3.5 Frequency 3 2.5 2 1.5 1 0.5 0 0 1 2 3 4 5 6 7 8 9 10 11 12 Months after 10-K filing Panel B. Cumulative voluntary disclosure by extreme quintiles of Length 6 Quintile 5 Quintile 1 5 Frequency 4 3 2 1 0 0 1 2 3 4 5 6 7 8 Months after 10-K filing 64 9 10 11 12 Figure 2. Time-series of annual cross-sectional regression coefficients This figure plots annual cross-sectional regression coefficients estimated in Panel A of Table 9. Cov(Freq, ReadIndex) is the coefficient from a regression of Frequency on ReadIndex and control variables. Cov(Freq, Length) is the coefficient from a regression of Frequency on Length and control variables. Cov(Freq8K, ReadIndex) is the coefficient from a regression of Frequency8K on ReadIndex and control variables. Cov(Freq8K, Length) is the coefficient from a regression of Frequency8K on Length and control variables. 7.00 Cov(Freq , ReadIndex) Cov(Freq8K , ReadIndex) 6.00 Cov(Freq , Length) Cov(Freq8K , Length) Coefficient 5.00 4.00 3.00 2.00 1.00 0.00 Year 65 2012 2011 2010 2009 2008 2007 2006 2005 2004 2003 2002 2001 2000 1999 1998 1997 1996 1995 -1.00 Figure 3. Time-series of voluntary disclosures for treatment and control firms around SFAS 157 and SFAS 133 This table presents average voluntary disclosure for affected firms and a matched sample of unaffected firms for the pre- and post- periods. Panel A presents results for SFAS 133. Panel B presents results for SFAS 157. Panel A. Voluntary disclosure around SFAS 133 Panel B. Voluntary disclosure around SFAS 157 66 Table C1. Quasi-natural experiments: Covariate balance This table presents cross-sample differences in mean and median values of the control variables used to calculate the propensity score in our quasi-natural experiment design. Panel A (Panel B) presents the difference in mean and median values for the firms affected by SFAS 133 (SFAS 157) and their matched sample. p-values (two-tailed) test for differences between means and medians and appear in brackets. Panel A. Covariate balance between observations affected and unaffected by SFAS133 Affected Variable Size ROA Leverage MTB SpecialItems Loss Returns σReturns Mean 6.44 0.28 0.31 1.89 –0.01 0.14 0.19 0.14 Median 6.36 0.16 0.29 1.19 0.00 0.00 –0.03 0.12 Unaffected Mean 6.45 0.28 0.31 1.83 –0.01 0.17 0.23 0.14 Median 6.42 0.16 0.28 1.22 0.00 0.00 –0.03 0.12 Affected–Unaffected Diff. in means –0.01 0.00 0.00 0.06 0.00 –0.03 –0.04 0.00 p–value [0.893] [0.945] [0.553] [0.354] [0.404] [0.051] [0.220] [0.303] Diff. in medians –0.06 0.00 0.01 –0.03 0.00 0.00 0.00 0.00 p–value [0.708] [0.692] [0.438] [0.248] [0.599] NA [0.716] [0.474] Panel B. Covariate balance between observations affected and unaffected by SFAS157 Affected Variable Size ROA Leverage MTB SpecialItems Loss Returns σReturns Mean 6.62 1.79 0.21 2.00 –0.01 0.20 0.14 0.09 Median 6.50 0.29 0.15 1.50 0.00 0.00 0.09 0.07 Unaffected Mean 6.59 1.74 0.21 2.03 –0.01 0.20 0.15 0.09 Median 6.52 0.30 0.15 1.58 0.00 0.00 0.10 0.08 67 Affected–Unaffected Diff. in means 0.03 0.05 0.00 –0.03 0.00 0.00 –0.01 0.00 p–value [0.531] [0.750] [0.608] [0.458] [0.878] [0.808] [0.753] [0.212] Diff. in medians –0.02 –0.01 0.00 –0.08 0.00 0.00 –0.01 –0.01 p–value [0.829] [0.132] [0.235] [0.021] [0.415] NA [0.678] [0.266] Table C2. Principal component analysis including measures of readability and length This table presents principal component output from consolidating the six readability measures defined in Appendix B and Length into one index of financial statement complexity. Factor 1st 2nd 3rd 4th 5th 6th 7th Eigenvalue 5.88 0.76 0.20 0.11 0.04 0.01 0.01 Proportion of the variation explained 83.94% 10.86% 2.80% 1.58% 0.59% 0.15% 0.07% Cumulative Proportion of the variation explained 83.94% 94.81% 97.61% 99.19% 99.77% 99.93% 100.00% 68 Measures FleschKincaid LIX RIX Fog ARI SMOG Length First Principal Component Weights 0.16698 0.16785 0.16608 0.15409 0.16515 0.16415 0.09263 Table C3. Decomposing financial statement complexity Panel A presents results from estimating financial statement complexity as a function of characteristics of the firm’s business environment. Abs_Returns is the absolute value of the buy and hold return over the 12 months prior to the annual report filing date. Acquisitions is acquisitions scaled by total assets. Capital is net plant, property, and equipment scaled by total assets. Capex is the amount of capital expenditures scaled by total assets. R&D is the ratio of research and development expense to sales. Financing is the amount raised from stock and debt issuances during the year scaled by total assets. σCFO is the standard deviation of cash flows from operations over the prior five years scaled by total assets. BigN is an indicator variable equal to one if the firm is audited by a Big 5 auditor and zero otherwise. Goodwill is an indicator variable for whether the firm had a goodwill impairment charge that year. Restructuring is an indicator variable for whether the firm had a restructuring charge that year. Panel B presents results from estimating regressions of Frequency on the scaled decile ranks of the predicted and residual values of the models estimated in Panel A and the control variables used in Table 3. For parsimony we do not tabulate coefficients on control variables. All other variables are as defined in Appendix A. Sample of 67,008 observations. tstatistics appear in parentheses and are based on standard errors clustered by firm and date. p-values test for differences between coefficients and appear in brackets. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two–tail), respectively. Panel A. Models of financial statement complexity Size Leverage MTB Abs_Returns Acquisitions Capital Capex R&D Financing σCFO BigN Goodwill Restructuring ROA Loss Firm effects Observations R2 (%) ReadIndex Coeff. t-stat. 0.11*** (20.58) 0.23*** (6.49) –0.04*** (–7.50) 0.07 (0.08) 0.23*** (2.91) –0.57*** (–12.75) –0.03 (–0.24) 0.04*** (7.34) 0.10*** (3.57) 0.34*** (5.86) 0.06*** (2.88) 0.05*** (3.27) 0.14*** (8.72) No 67,008 8.8 ReadIndex Coeff. t-stat. 0.06*** (6.11) 0.15*** (3.55) –0.03*** (–7.06) –2.65*** (–3.69) 0.13** (2.08) –0.30*** (–3.91) –0.07 (–0.62) –0.01** (–2.16) –0.02 (–0.80) –0.12* (–1.74) –0.13*** (–5.40) 0.08*** (4.82) 0.10*** (7.15) 0.00*** (2.72) 0.10*** (8.33) Yes 67,008 60.2 Length Coeff. t-stat. 0.13*** (29.89) 0.31*** (14.97) –0.06*** (–19.11) 4.79*** (6.89) –0.50*** (–10.44) –0.05* (–1.72) –0.53*** (–6.47) 0.03*** (13.88) 0.12*** (8.16) 0.49*** (14.67) –0.23*** (–16.34) 0.07*** (7.42) 0.22*** (14.85) No 67,008 23.2 Length Coeff. t-stat. 0.12*** (18.54) 0.25*** (9.21) –0.05*** (–19.08) 1.17*** (2.82) –0.18*** (–4.80) –0.23*** (–4.88) –0.53*** (–8.56) –0.00 (–1.28) –0.04*** (–3.38) 0.07* (1.95) –0.19*** (–15.41) 0.17*** (18.41) 0.23*** (18.59) 0.01*** (11.02) 0.14*** (21.03) Yes 67,008 71.5 Panel B. Models of voluntary disclosure PredictedValue ResidualValue 1st Stage Model (1) Coeff. t-stat. 4.88*** (16.02) 1.25*** (7.80) two-tailed p-value: predicted – residual = 0 [<0.001] Controls Yes Firm effects Yes Observations 67,008 R2 (%) 61.6 Dependent variable: Frequency 1st Stage Model (2) 1st Stage Model (3) Coeff. t-stat. Coeff. t-stat. 5.54*** (21.12) 4.75*** (20.33) 0.70*** (7.30) 3.28*** (20.37) [<0.001] Yes Yes 67,008 62.7 69 [<0.001] Yes Yes 67,008 63.0 1st Stage Model (4) Coeff. t-stat. 5.91*** (22.37) 1.81*** (18.77) [<0.001] Yes Yes 67,008 63.5 Table C4. Changes in analyst forecasts around the filing of the financial statements This table presents results from examining whether the relation between financial statement complexity (FS_Complexity) and subsequent voluntary disclosure (Frequency) varies with the change in analyst forecasts around the 10-K filing. Our model follows the specifications in Panel A of Table 3, except that we interact our measures of financial statement complexity with our measures of the change in analyst forecasts around the 10-K filing (∆Accuracy and Revision). ∆Accuracy is the difference in Accuracy between the first analyst consensus forecast after the 10-K filing and the last analyst consensus forecast prior to the 10-K filing, where Accuracy is defined as the absolute value of the difference between the mean analyst consensus forecast and realized EPS, scaled by price at the beginning of the fiscal year and multiplied by negative one. Revision is the absolute value of the difference between the first median analyst consensus forecast after the 10-K filing and the last median analyst consensus forecast prior to the 10-K filing, scaled by price at the beginning of the fiscal year. All other variables are as defined in Appendix A. For parsimony we do not tabulate coefficients on control variables. t-statistics appear in parentheses and are based on standard errors clustered by firm and date. ***, **, and * denote statistical significance at the 0.01, 0.05, and 0.10 levels (two-tail), respectively. Dependent variable = Frequency FS_Complexity = ReadIndex Variable FS_Complexity FS_Complexity x ∆Accuracy (1) 1.52*** (6.61) –0.19 (–0.70) FS_Complexity x Revision ∆Accuracy –0.06 (–0.42) Revision Controls Firm effects Observations R2 (%) Yes No 45,714 18.4 (2) 1.75*** (7.36) –0.78** (–2.45) 1.00*** (5.83) Yes No 45,714 18.5 70 (3) 1.64*** (6.54) 0.45 (1.46) –1.01*** (–2.83) –0.81*** (–4.44) 1.37*** (6.81) Yes No 45,714 18.6 FS_Complexity = Length (4) 4.51*** (19.10) –1.04*** (–4.08) 0.31** (2.46) Yes No 45,714 21.3 (5) 4.81*** (19.75) –1.83*** (–5.67) 1.03*** (7.01) Yes No 45,714 21.3 (6) 4.80*** (18.46) 0.08 (0.27) –1.92*** (–5.43) –0.48*** (–3.24) 1.28*** (7.49) Yes No 45,714 21.4