JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 87 THE IMPACT OF REGULATION FAIR DISCLOSURE ON EARNINGS MANAGEMENT AND ANALYST FORECAST BIAS By Seung-Woog (Austin) Kwag and Kenneth Small∗ Abstract Regulation Fair Disclosure (FD) has changed the information transfer process in the US securities market. We examine the impact that regulation FD has had on earnings management and analyst forecast bias. First, we examine the accuracy of financial analysts’ earnings forecasts in the post-FD period. We find that analysts have become less accurate in forecasting earnings in the post-FD period and tend to overestimate earnings more relative to the pre-FD period. Second, we examine the level of earnings management after the passage of regulation FD and we find that the level of earnings management did not change after the implementation of regulation FD. (JEL G10, G28) Introduction In October of 2000, the Securities Exchange Commission’s (SEC) Regulation Fair Disclosure (FD) took effect. The SEC adopted regulation FD to combat selective disclosure, which occurs when corporations release material non-public information to selected stakeholders, such as financial analysts or institutional investors, and leaves other investors in the dark. It was suggested that this practice undermined the integrity of and decreased investor confidence in the US securities markets. The SEC was also concerned with insider trading and misappropriation that arises in connection with selective disclosure. To comply with regulation FD, corporations must make intentional and inadvertent disclosures of material information public by filing the information with the SEC, or by another method intended to reach the public on a broad and non-exclusionary basis – e.g., a press release. Although a majority of market participants still expects the regulation’s positive effect – e.g., reduction in private information flow by leveling the information playing field, dissenting concerns – e.g., reduction in the quantity and quality of financial disclosures – do still exist.1 In sum, the expected impact of regulation FD on the securities industry is mixed. Proponents of regulation FD argue that it improves analyst forecast accuracy and reduces information asymmetry between managers and analysts, and between analysts and investors. Heflin et al. (2003) list three possible factors that may prevent information deterioration in the post-FD period: 1) Post-FD public information released directly from firms may fully substitute for private information that analysts were privy to in the pre-FD period; 2) Firms are likely to reduce the quality and quantity of information in the post-FD period; 3) Whether regulation FD has an impact on the financial markets is an empirical question in a situation where regulation FD does not effectively inhibit selective disclosure to financial analysts. Heflin et al. (2003) find supporting evidence that regulation FD improves informational efficiency of stock prices prior to earnings announcements and that firms voluntarily, and more frequently, disclose forward-looking earnings-related information. Therefore, it can be hypothesized that regulation FD partially alleviates forecast errors. ∗ Seung-Woog (Austin) Kwag, Assistant Professor of Finance, Department of Business Administration, Utah State University, 3510 Old Main Hill, Logan, UT, austin.kwag@usu.edu; Kenneth Small, Assistant Professor, Department of Finance, Loyola College in Maryland, Baltimore, MD, ksmall@loyola.edu. 1 Unger, L. S. Special Study: Regulation Fair Disclosure Revisited, U.S. Securities and Exchange Commission, 2001. JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 88 The SEC has signaled a strong interest in enforcing regulation FD by bringing enforcement actions against firms that are not following the standard. Raytheon, Motorola, Siebel Systems, and Secure Computing were among the first firms to receive enforcement actions. The cases of Raytheon and Motorola involved efforts to induce analysts to lower their published earnings estimates to be consistent with the company’s earnings expectations. Siebel Systems violated regulation FD by disclosing the company’s improved outlook to a selected group of brokerage investors. Secure Computing failed to disseminate material nonpublic information that it had disclosed selectively. Disciplinary actions have been taken in all of these cases. Many academicians and practitioners have begun to study the current and future implications of regulation FD on the securities industry. Proponents of regulation FD argue that it has leveled the informational playing field for all investors and fulfilled its promise of fair and equal disclosure of corporate information to the public. According to a survey, about 90% of top executives surveyed say that regulation FD should continue and has provided at least the pre-FD level of fairness to the stakeholders – analysts and investors.2 On the other hand, opponents of regulation FD claim that it has had a chilling effect on public dissemination of information. A survey conducted by the Association for Investment Management and Research (AIMR)3 shows that a majority of investment analysts and portfolio managers feel that many types of information (e.g., earnings guidance, forward-looking information, facts about internal operations, facts about costs and pricing, or facts about sales volume) are less available since the enactment of regulation FD.4 This paper provides empirical evidence of the impact of regulation FD on the investment community by investigating earnings management and analyst forecast bias (forecast accuracy and the direction of any bias) before and after the passage of regulation FD. We present evidence that the accuracy of financial analyst’s earnings estimates have decreased since the introduction of regulation FD. Not only has the inaccuracy of these estimates increased, but also earnings estimates tend to be overestimated in the post-FD period. However, our results suggest that regulation FD has had no significant impact on earnings management. In the following sections, we discuss related academic research, develop hypotheses, and analyze empirical results. Research Review Many studies present evidence that managers smooth their firm’s earnings to meet analysts’ forecasts [Brown (2001); Degeorge et al. (1999)]. Firms could manage earnings to create good news at the time of an earnings announcement or could manage earnings to meet expectations. Historically, to avoid earnings disappointment, firms manage earnings expectations through conference calls and preannouncements of earnings [Tasker (1998); and Soffer et al. (2000)]. Brown and Higgins (2001) present a comparative international study on earnings management. They find that U.S. firms tend to have twice as many small positive forecast errors (good news) than small negative (bad news) forecast errors. This ratio is significantly smaller for the non-U.S. firms. The percentage of extremely negative forecast errors is also smaller for the U.S. firms than for the non-U.S. firms. Degeorge et al. (1999) document that the distribution of forecast errors is skewed, with a smaller mass of forecast errors to the left of zero relative to the right. They also present striking evidence that zero forecast errors are the most frequent in the distribution. Many studies report that analyst forecast bias is, on average, optimistic. Abarbanell (1991) studies analyst optimism for the period of 1981 to 1984, and finds that the mean forecast error is significantly negative (i.e., optimistic) in each year. He also presents evidence that the optimistic forecasts are more frequent than the pessimism forecasts in each year during the four-year period. 2 Heffes, Ellen M. “Regulation fair disclosure (FD) and beyond,” Financial Executive 18 (2002), 52-54. AIMR changed its name to the CFA Institute in 2004. 4 CPA Journal. “Research Studies Show Differing Views on Regulation FD,” The CPA Journal 71 (2001), p.10. 3 JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 89 According to Francis and Philbrick (1993), management relation biases analysts’ earnings forecast toward optimism. La Porta (1996) forms ten portfolios on the basis of analysts’ earnings growth forecasts and reports that the forecast errors tend to be optimistic (i.e., actual earnings are algebraically smaller than analysts’ forecasts) for almost all portfolios. Other extant studies also document consistent findings. Among others are Fried and Givoly (1982) and O’Brien (1988). Heflin et al. (2003) find that the informational efficiency of stock prices improves after the implementation of FD and there is no significant change in analyst forecast accuracy and dispersion. They report that absolute cumulative abnormal returns prior to the quarterly earnings announcement are significantly smaller for the post-FD period than for the pre-FD, suggesting earnings information is conveyed to investors more efficiently after FD. Controlling for non-FD determinants of analyst forecast accuracy and dispersion, they also find that FD does not impair forecast accuracy and dispersion. In contrast to Heflin et al.’s findings, Irani and Karamanou (2003) provide evidence that FD has a negative impact on the informativeness of the firm’s information environment and information asymmetry. They document that in both the univariate and multivariate frameworks, the number of analysts following a firm significantly decreases and that analyst forecast dispersion significantly increases after FD. In this work we attempt to reconcile differences between the results presented in previous research. We examine the direction and magnitude of financial analysts’ earnings forecasts around the passage of regulation FD as well as the level of earnings management around the passage of regulation-FD. Hypothesis Development Regulation FD prohibits selective disclosure of material non-public information. The passage of regulation FD could have decreased firm specific information signals available to analysts (i.e., pre-announcement guidance), and the bias in forecast errors could have increased after the passage of the act. However, because of possible strengthening of private information channels, forecast errors may have remained unchanged in the post-FD period. This leads to the first hypothesis: H1A: Analyst forecast errors have increased in the post-FD period relative to the pre-FD period. Given a possible reduction in the accuracy of the analysts forecast predictions, a firm’s propensity to manage earnings to meet the analyst’s “target” in the post-FD period may have also decreased. If analyst accuracy decreases in the post-FD period, the “costs” associated with missing the consensus estimates should also decrease. In addition, if forecasts are less accurate, the ability of firm’s to meet the more inaccurate forecasts may be reduced. This leads to the second hypothesis: H2A: Earnings management has increased in the post-FD period relative to the pre-FD period. Note that we state both hypotheses in the form of the alternatives, and in the next section we discuss the data and research design that we employ to test the two central hypotheses. Data and Research Design We collect analyst consensus forecast data compiled by the I/B/E/S, accounting information from COMPUSTAT, and monthly and daily price data from the Center for Research on Security JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 90 Prices (CRSP) database. We are interested in the pre-FD period, which includes 1999 and 2000, and the post-FD period, which includes 2001 and 20025. The initial /B/E/S sample contains 1268 firm-year observations. The sample size is reduced to 1099 firm-year observations after merging the databases together. To gauge the level of earnings management, we employ an extension of the cross-sectional Jones model used in Teoh, Welch, and Wong (TWW, 1998). Following TWW, we use discretionary current accruals (DCA) as a proxy for earnings management because managers have greater flexibility and control over current accruals versus long-term accruals. The following specifies the TWW model: CAit = ∆[ AR (2) + INV (3) + OCA(68)] − ∆[ AP (70) + TP (71) + OCL(72)] (1) CAit ∆Sales it 1 = α0 ( ) + α1 ( ) + ε it TAi ,t −1 TAi ,t −1 TAi ,t −1 (2) NDCAit = αˆ 0 ( DCAit = ∆Sales it − ∆TRit 1 ) + αˆ 1 ( ) TAi ,t −1 TAi ,t −1 (3) CAit − NDCAit , TAi ,t −1 (4) CAit is the current accruals for firm i in year t; AR is accounts receivables; INV is inventory; OCA is other current assets; AP is accounts payable; TP is tax payable; OCL is other current liabilities; ∆Sales it is the change in sales for firm i from year t-1 to year t; TAt ,t −1 where is the total assets for firm i in year t-1; αˆ 0 , αˆ 1 are the OLS estimates of nondiscretionary current accruals for firm i in year t; and accruals for firm i in year t. The negative management, while the positive α 0 , α 1 ; NDCAit is the DCAit is the discretionary current DCAit indicates the income-decreasing earnings DCAit suggests the income-increasing earnings management. To quantify the earnings management regardless of its impact on earnings, we use the absolute value of DCAit ( | DCA | it ) as the operational measure of earnings management. A higher |DCA| indicates a higher degree of earnings management. We form five earnings management portfolios from the least managed (or unmanaged; DCA_P1) to the most managed (DCA_P5). Annual forecast errors are computed for pre-FD years (1999, 2000) and post-FD years (2001, 2002) as: FE it = 5 Ait − Fit Pi ,t −1 The use of the differing pre-FD periods does significantly impact the results of the research. (5) JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 Where 91 FE it = the analyst forecast error at the earnings announcement of year t for firm i deflated by the stock price one month prior to the earnings announcement; year t for firm i; Ait = the reported earnings of Fit = the analyst consensus forecast of year t for firm i; and Pi ,t −1 = the stock price one month prior to year t for firm i. Absolute forecast error (absFE) indicates the absolute value of FE and is used to measure analyst forecast accuracy. We form five behavioral portfolios from the most overestimated (FE_P1) to the least overestimated (FE_P5), on the basis of FE. We also create five accuracy portfolios from the most accurate (absFE_P1) to the least accurate (absFE_P5) on the basis of absFE. Empirical Results Univariate Analysis To evaluate the impact that FD has had on earnings management and analyst forecast errors, we first examine the level of discretionary accruals (|DCA|), the level of forecast errors, and the absolute value of forecast errors before and after FD. This analysis is presented in Figure 1. Figure 1: Means of |DCA|, FE, and absFE 0.08 |DCA| / FE/ absFE 0.06 0.04 0.02 Pre-FD Post-FD 0 -0.02 -0.04 -0.06 |DCA| FE absFE Pre-FD 0.0672 -0.0187 0.0295 Post-FD 0.0655 -0.0354 0.0437 92 JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 Figure 2A: |DCA| Portfolio Means of Forecast Error (FE) 0.0000 -0.0100 -0.0200 FE FE Pre-FD FE Post-FD -0.0300 -0.0400 -0.0500 -0.0600 FE Pre-FD FE Post-FD DCA_P1 DCA_P5 -0.0175 -0.0314 -0.0216 -0.0567 |DCA| Portfolio Figure 2B: |DCA| Portfolio Means of Absolute Forecast Error (absFE) 0.0700 0.0600 0.0500 absFE 0.0400 absFE Pre-FD absFE Post-FD 0.0300 0.0200 0.0100 0.0000 absFE Pre-FD absFE Post-FD DCA_P1 DCA_P5 0.0257 0.0354 0.0332 0.0648 |DCA| Portfolio As can be seen, the |DCA|s slightly decrease from the pre-FD to the post-FD period. The average |DCA| in the pre-FD period is 0.0672 and the average in the post-period is 0.0655. Both JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 93 parametric (Fisher's least-significant-difference; LSD) and non-parametric (Scheffé's) tests show that the post-FD |DCA| is statistically the same as the pre-FD |DCA|. The results of the univariate analysis indicate that the level of earning management did not change after the FD took effect, which rejects our original conjecture. Although the information playing field has been leveled, firm’s propensity to engage in earnings management has not changed. The level (FE) and absolute value (absFE) of forecast errors before and after the introduction of FD indicate that the magnitude of forecast errors has decreased from -0.0187 to -0.0354 since the introduction of FD. The average absolute value of forecast errors has increased from 0.0295 to 0.0437 around the introduction of FD. LSD and Scheffé's tests exhibit significant mean differences between pre- and post-FD FE and absFE. These results together indicate that financial analysts have become less accurate in the post FD period. Further, they provide evidence that the information flow from firm to analysts in the pre-earnings announcement period has been effectively reduced in the post-FD period. The benefit of a level information playing field has been balanced by the costs associated with decreased analyst accuracy. Next, we examine the level and absolute value of forecast errors before and after the introduction of FD with respect to the level of earnings management (|DCA|). Figure 2.A contains the univariate specification of pre and post values of FE classified into two extreme portfolios based on the level of |DCA|, and Figure 2.B contains the specification of pre and post absFE classified into the same two extreme portfolios. |DCA| is ranked from its lowest level, DCA_P1, which includes firms with the lowest level of earnings management, to its largest level, DCA_P5, which includes firms with the largest level of managed earnings. The results in Figure 2.A indicate that for both the least-managed (DCA_P1) and mostmanaged (DCA_P5) portfolios, the magnitude of forecast errors has decreased since the introduction of FD from -0.0175 to -0.0314 and from -0.0216 to -0.0567, respectively. But, notice that the decrease in forecast error is greater for DCA_P5 than for DCA_P1. LSD and Scheffé's tests present significant mean differences between pre-FD and post-FD forecast error for both portfolios. The average absolute value of forecast errors has increased around the introduction of FD for both |DCA| portfolios – from 0.0257 to 0.0354 and from 0.0332 to 0.0648, respectively. These results confirm the evidence provided in Figure 1 that analyst accuracy has decreased and information flow has decreased from management to analysts in the post-FD period. There is also evidence that higher earnings management results in lower accuracy. In particular, the mean (absolute) forecast error is smaller (greater) for DCA_P5 than for DCA_P1 regardless of the introduction of FD. Categorical Data Analysis: 2 × 5 Contingency Table Using a categorical data analysis, we examine the impact of FD on earnings management, forecast accuracy, and the direction of forecast errors. The treatment variable (FD) has two levels before and after the implementation of FD, while the response variables have five levels which range from P1 to P5. P1 through P5 represents five portfolios of the response variable (i.e., earnings management, forecast accuracy, and the direction of forecast errors) ranked from highest level (P5) to its lowest level (P1). As a result, the relationships between the treatment variable and the response variables are summarized in three 2 × 5 contingency tables (Table 1). Our interest lies in determining whether there is an association between the row variable and the column variable. Panel A of Table 1 contains the contingency analysis of |DCA|. The Mantel-Haenszel ChiSquare test is used to examine changes in DCA around the introduction of FD. The value of the statistic is 0.7654 (p-value = 0.3817), which indicates no significant change in DCA at the conventional significance levels post-FD relative to pre-FD. This is consistent with the results in Figure 1. Panel B of Table 1 contains the contingency analysis of forecast errors (FE). The Mantel-Haenszel Chi-Square test statistic value of 9.7478 (p-value = .0018) indicates that financial analysts’ forecast errors have significantly decreased over the pre-FD to post-FD period. 94 JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 Table 1: 2 × 5 Contingency Table Analysis: Treatment = Regulation Fair Disclosure (FD) Row Levels (Treatment) Pre-FD Post-FD Total Column (Response) Levels P2 P3 P4 n13 n14 n12 %n12 %n13 %n14 n22 n23 n24 %n22 %n23 %n24 N+2 N+3 N+4 P1 n11 %n11 n21 %n21 N+1 Total P5 n15 %n15 n25 %n25 N+5 N1+ N2+ N Panel A. 2 × 5 Contingency Table of |DCA| Frequency Row Percentage Pre-FD Post-FD Total DCA_P1 DCA_P2 DCA_P3 DCA_P4 DCA_P5 Total 112 18.76 90 17.93 202 102 17.09 106 21.12 208 135 22.61 112 22.31 247 120 20.10 97 19.32 217 128 21.44 97 19.32 225 1099 Total 597 502 Mantel-Haenszel Chi-Square ( χ MH ) = 0.7654 (p-value=0.3817) 2 Panel B. 2 × 5 Contingency Table of FE Frequency Row Percentage Pre-FD Post-FD Total FE_P1 FE_P2 FE_P3 FE_P4 FE_P5 102 17.09 117 23.31 219 120 20.10 100 19.92 220 115 19.26 105 20.92 220 122 20.44 98 19.52 220 138 23.12 82 16.33 220 1099 Total Mantel-Haenszel Chi-Square χ 2 MH 597 502 =9.7478 (p-value=0.0018) Panel C. 2 × 5 Contingency Table of absFE Frequency Row Percentage Pre-FD Post-FD Total |FE|_P1 |FE|_P2 |FE|_P3 |FE|_P4 |FE|_P5 129 21.61 90 17.93 219 129 21.61 91 18.13 220 132 22.11 88 17.53 220 112 18.76 108 21.51 220 95 15.91 125 24.90 220 Mantel-Haenszel Chi-Square χ 2 MH 597 502 1099 =10.4487 (p-value=0.0012) Notes: This table summarizes the association between the treatment (row) variable and the response variable (column) variable. The treatment variable is the regulation fair disclosure (FD), while the response variable is one of three variables of interest – earnings management, analyst optimism, and forecast accuracy. For earnings management, P1 (P5) indicates the least (most) managed portfolio – denoted DCA_P1 (DCA_P5) in Panel A. For analyst overestimation, P1 (denoted FE_P1) indicates the most overestimated (or least pessimistic) portfolio, while P5 (denoted FE_P5) represents the least overestimated (or most pessimistic) portfolio. For forecast accuracy, P1 (P5) denotes the most (least) accurate portfolio – denoted |FE|_P1 (|FE|_P5). nij is the number of observations in the cell i, j where i is the ith row and j is the jth column; Ni+ is the number of observations in the ith row; N+j is the number of observations in the jth column; % n1j (% n2j) is n1j (n2j) divided by N1+ (N2+); and N is the total number of observations in the sample. The null hypothesis is that the treatment has no impact on the response variable – i.e., there is no difference between the response variable before and after FD. JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 95 Panel C of Table 1 contains the contingency analysis of absolute value of financial analysts’ forecast errors (absFE). Like with the previous analysis of FE the Mantel-Haenszel Chi-Square test statistic value of 10.4487 (p-value = .0012) indicates that absFE has significantly increased over the pre-FD to post-FD period. This analysis supports the results from the graphical analysis and our earlier univariate results. In the next section, we extend the analysis to a multivariate framework to control of the influence that book-to-market, firm size, analyst coverage, forecast dispersion might have on the pre-post-FD levels of analyst optimism and forecast accuracy. However, we note that the univariate analysis does not control for other factors that may also have influenced the incidence of earnings management around the FD introduction date. This issue is addressed in a multivariate specification that is discussed in the next section. Multivariate Empirical Models To further examine the relationships between forecast accuracy and earnings management around the introduction of FD, we examine two regression models. In each regression specification we control for firm size (logarithm of market value of equity; logSize), book-tomarket ratio (BtoM), analyst coverage (NUMEST), and forecast dispersion (STD):6 FE it = β 0 + β 1 FDit + β 2 | DCA | it + β 3 FDit * | DCA | it + β 4 log Sizeit + β 5 BtoM it + β 6 NUMESTit + β 7 STDit + u it (6) absFE it = β 0′ + β 1′FDit + β 2′ | DCA |it + β 3′ FDit * | DCA | it + β 4′ log Sizeit + β 5′ BtoM it + β 6′ NUMESTit + β 7′ STDit + vit (7) | DCA | it = the earnings management score [i.e., the absolute value of the discretionary current accrual] for firm i in year t; FDit is a dummy variable for firm i that takes the value of 0 in the pre-FD period and 1 in the post-FD period and FE it is the analyst forecast error at the where earnings announcement of year t for firm i deflated by the stock price one month prior to year t; absFE it is the absolute value of FE it ; logSizeit is the logarithm of the market value of equity for firm i at the earnings announcement of year t; the market value of equity for firm i in year t; for firm i in year t and BtoM it is the book value of equity divided by NUMESTit is the number of analysts’ forecasts STDit is the standard deviation among individual analyst’s forecasts of earnings. The results of the multiple regressions are presented in Table 2. Panel A contains the results from the first regression specification [i.e., Equation (6)]. The binary variable ( β1 ) in this specification is interpreted as the mean change in forecast errors from the pre-FD period to the post-FD period, while controlling for |DCA|, logSize, BtoM, NUMEST, and STD. The value of β1 is negative and significant, indicating that the level of analyst overestimation of earnings increased from the pre-period to the post-period. The effects of firm size, analyst coverage, and forecast dispersion on analyst optimism are all significant at the 1% level. Evidence suggests that analyst overestimation decreases for larger and less-covered firms with lower dispersion in 6 The control variables are used or suggested for use in Gleason and Lee (2003) and Fama and French (1995). 96 JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 earnings forecasts. Notice that both β2 and β3 are not statistically significant, implying that earnings management is not a significant factor affecting the level of analyst overestimation. Table 2: Regression Results Panel A. Regression of FE on FD, |DCA|, logSize, BtoM, NUMEST, and STD Coefficient β0 β1 β2 β3 β4 β5 β6 β7 Estimate Pr > |t| -0.1382 <.0001a -0.0109 0.0051a -0.0014 0.9713 -0.0001 0.9975 0.0135 <.0001a -0.0002 0.1348 -0.0024 0.0047a -0.0599 <.0001a Adjusted R-square 0.1462 Number of observations 1,099 Panel B. Regression of absFE on FD, |DCA|, logSize, BtoM, NUMEST, and STD Coefficient β 0′ β1′ β 2′ β 3′ β 4′ β 5′ β 6′ β 7′ Estimate Pr > |t| 0.1763 <.0001a 0.0094 0.0132b 0.0025 0.9487 0.0713 0.1480 -0.0151 <.0001a 0.0004 0.3750 -0.0026 0.0014a 0.0613 <.0001a Adjusted R-square 0.1783 Number of observations 1,099 Notes: This table presents the coefficient estimates of the regression equations (6) and (7) and their p-values. Significance levels denoted as follows: a (1%), b (5%), and c (10%). The second specification [i.e., Equation (7)] captures the change in the absolute value of forecast errors, while controlling for |DCA|, logSize, BtoM, NUMEST, and STD. The coefficient estimate on β 1′ is 0.0094 and significant at the 5% level. This positive and significant coefficient estimate indicates that analyst forecast accuracy deteriorated after the introduction of FD. This JOURNAL OF ECONOMICS AND FINANCE • Volume 31 • Number 1 • Spring 2007 97 supports our conjecture that the reduction in information flow from firm to financial analyst has impaired their ability to forecast earnings. Again size, analyst coverage, and forecast dispersion effects are significant at the 1% level. Firms with large size, high analyst coverage, and low forecast dispersion tend to receive more accurate forecasts than firms with small size, low analyst coverage, and high forecast dispersion. As in Panel A, notice that both β 2′ and β 3′ are not significant. This evidence similarly suggests that earnings management is not a significant factor affecting the level of analyst forecast accuracy. All told, the multiple regression analysis confirms the results of the univariate analysis. Specifically, we reject the hypothesis that managers have a reduced incentive to manage earnings after the enactment of FD and the hypothesis that analyst accuracy has not changed in the post-FD period relative to the pre-FD period. Instead, we find that earnings management has not changed and that analysts have become less accurate since the introduction of FD. Conclusions Has regulation FD impaired the ability of financial analysts to make accurate earnings forecasts and reduced the need for earning management? In our univariate specification, we present evidence that analyst forecast accuracy has deteriorated in the post-FD period, while the magnitude of earnings management has not been significantly reduced. Specifically, we find that analysts tend, on average, to overestimate earnings more in the post-FD period. After controlling for potential confounding factors, our multiple regression specifications also confirm the results of the univariate analysis. In particular, our results highlight the impact that regulation FD has had on the ability of financial analysts to make accurate forecasts. Our findings open the door for future research in this area. For example, has the market’s reaction to missed earnings changed in the post-FD period? If financial analysts’ ability to correctly forecast earnings have deteriorated in the post-FD period, has this created a phantom hit-or-miss opportunity for firms? In addition, what is the best information dissemination method for firms to use in the post-FD period? In particular, how has the market reacted to firms that have chosen not to provide earnings guidance? 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