Accounting, Organizations and Society 47 (2015) 25e42 Contents lists available at ScienceDirect Accounting, Organizations and Society journal homepage: www.elsevier.com/locate/aos Regulation and the interdependent roles of managers, auditors, and directors in earnings management and accounting choice* Robert Libby a, *, Kristina M. Rennekamp a, Nicholas Seybert b a b Samuel Curtis Johnson Graduate School of Management, Cornell University, Ithaca, NY 14853, United States Robert H. Smith School of Business, University of Maryland, College Park, MD 20742, United States a r t i c l e i n f o a b s t r a c t Article history: Received 23 June 2015 Received in revised form 3 September 2015 Accepted 11 September 2015 In this paper, we examine the growing number of behavioral studies of how financial reporting, auditing, and other corporate governance regulations affect earnings management and accounting choice-related decisions of managers, auditors, and directors. We first describe how experimental and survey studies can add unique insights into our understanding of earnings management and accounting choice. We then organize our review of the literature by the type of regulation (financial reporting, auditing, or corporate governance) and secondarily by which of the three parties are affected. Finally, we point out useful directions for future research and discuss key methodological choices faced by those who will conduct that future research. © 2015 Elsevier Ltd. All rights reserved. Keywords: Earnings management Earnings quality Accounting choice Financial reporting Auditing Corporate governance Experimental design Surveys Regulation 1. Introduction This paper examines recent experimental and survey studies of managers', auditors', and directors' (or audit committee members') decisions that influence earnings management and accounting choice, and how these decisions are affected by financial reporting, auditing, and other corporate governance regulations. We evaluate what we have learned from these studies, point out useful directions for future research, and discuss key methodological choices faced by researchers in this area. Like our earlier review (Libby & Seybert, 2009), we employ a broad definition of earnings management and accounting choice to include: (1) choices of accounting methods; (2) implementation decisions related to estimates, classifications, levels of detail, and display format used in mandatory disclosures; (3) the frequency, timing, and content of * The authors wish to acknowledge the helpful comments of Scott Asay, Robert Bloomfield, Scott Emett, Mark Nelson, Ken Trotman and participants at the Accounting, Organizations, and Society's 40th Anniversary Event. * Corresponding author. E-mail addresses: rl54@cornell.edu (R. Libby), kmr52@cornell.edu (K.M. Rennekamp), nseybert@rhsmith.umd.edu (N. Seybert). http://dx.doi.org/10.1016/j.aos.2015.09.003 0361-3682/© 2015 Elsevier Ltd. All rights reserved. voluntary disclosures; and (4) investment, financing, and operating choices based on their accounting (rather than economic) consequences (Libby & Seybert, 2009, p. 291). The experimental and survey studies that we focus on examine the determinants of accounting choice and not their consequences for users and market prices.1 Since our earlier review, there has been an uptick in experimental and survey studies of the determinants of earnings management and accounting choice. While the majority of the literature on earnings management and accounting choice uses archival methods to draw inferences, experiments and surveys have different strengths and weaknesses that make them particularly useful for studying certain aspects of accounting choice. First, as Francis (2001, p. 310) notes, most of the earlier accounting choice literature does not include decision makers other than the manager. The need to study the effects of other parties to the process, 1 Different portions of the consequences literature have been reviewed recently by Dechow et al. (2010) and Libby and Emett (2014). Studies which examine managers', auditors', and directors' beliefs about the consequences of their actions are included where relevant. 26 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 such as auditors and audit committees (or directors), serves as the basis for many recent experimental and survey studies. Indeed, experiments and surveys have a comparative advantage in their ability to tease out the unique contributions of each party. Second, as Libby and Seybert (2009, p. 293) suggest, archival studies are limited to examining the effects of existing regulatory regimes, which makes it difficult to determine which specific elements of the regulatory regime impact the observed accounting choices. In experiments, specific elements of the regulatory regime can be independently manipulated to disentangle their effects on the parties' actions. Experimental and survey researchers can also investigate the effects of regulations that do not currently exist. And third, intermediate process measures are often captured in experiments and surveys, which allow assessment of the impact of specific motives, beliefs, and cognitive processes of the parties involved and how they interact with elements of regulation. On the other hand, experiments, and to a lesser extent surveys, have limited ability to representatively sample decisions, settings, and actors. This limits their ability to estimate the magnitude or importance of effects. Also, experiments that rely on manipulation of independent variables can only focus on a small number of effects. Furthermore, many variables are held constant, which can limit the generalizability of results or hide important interactions. Surveys are limited in their ability to illuminate non-conscious effects and are subject to a number of forms of response bias (see Nelson & Skinner, 2013, for a detailed discussion). In summary, different methods are useful for addressing different parts of research questions related to accounting choice, and a multimethod approach is often warranted. The earnings management and accounting choice literature generally views managers' choices as being motivated by managerial self-interest and maximization of current shareholders' interests (Fields, Lys, & Vincent, 2001; Francis, 2001). Tests of the effects of managerial self-interest rely mostly on differences in aspects of compensation contracts. Tests of maximization of current shareholders' interests rely mostly on differences in capital market pressures and differences in the importance of the liquidity benefits of transparency versus loss of competitive advantage (e.g., public vs. private ownership, the need for additional equity or debt financing, and industry competitiveness). The broader accounting quality literature (see Dechow, Ge, & Schrand, 2010, for a recent review) also recognizes the importance of auditors and directors as potential monitors that may constrain earnings management and accounting choice. In the auditing literature, auditors are often portrayed as balancing their wish to satisfy client management with their wish to avoid both out-of-pocket costs of litigation and regulatory enforcement, as well as the longer-term costs of reputation damage (e.g., Hackenbrack & Nelson, 1996; Watts & Zimmerman, 1978). Similarly, in the corporate governance literature, directors or audit committee members are portrayed as balancing their wish to satisfy management with their wish to avoid litigation and regulatory enforcement costs, including longer-term costs to reputation (e.g., Fama, 1980; Hermalin & Weisbach, 1998). Consistent with the above description of the various parties' motives, financial reporting, auditing, and corporate governance standards and regulations can be viewed as limits set on the effects of manager, auditor, and director motives. These limits operate by specifying required and prohibited types of behavior. Violation of the limits can be sanctioned through the courts or regulatory processes and the regulations also specify the type and magnitude of the potential sanctions. Many of the standards and regulations still leave room for a good deal of discretion (or judgment) on the part of all three parties involved in accounting choices. And, at the time of their issuance, there is uncertainty surrounding the exact manner in which enforcement agencies will interpret the standards and regulations and impose sanctions for infractions. Enforcement actions and speeches by regulators fill in many of these missing details over time. They also allow the regulators to efficiently react to the changing business environment. One feature distinguishing the experimental and survey literature is that it places a more significant emphasis on cognitive factors that may affect the manner in which human managers, auditors, and directors form their beliefs and preferences, which determine their choices (e.g., Baker & Wurgler, 2013; Koonce & Mercer, 2005; Koonce, Seybert, & Smith, 2011). These cognitive factors include self-serving attribution bias, different forms of overconfidence, anchoring on regulations formerly in force, manager/auditor/director personality traits, weighting of sunk costs, social identity factors, moral licensing, and others. There are a number of additional complications in studying the determinants of accounting choice that have been recognized in the behavioral literature. One concern is that each regulation can influence the judgments and decisions of any or all of the three parties involved in the financial reporting process. The limits imposed by regulations also affect behavior in concert with cross sectional differences in other attributes of the environment including the compensation scheme for the managers, auditors, and directors, as well as the transparency of their actions. Compounding the issue of cross-sectional differences in the environment, there are reliable individual differences in the manner in which each of these three parties respond to regulations and environmental attributes. Finally, the effects of regulations may also be dependent on other accounting choices that have been made in the current or prior periods. All of these complicating factors suggest the possibility of interesting interactions, and it is an emphasis on these interactions that differentiates much of the behavioral literature. The remainder of the paper is organized as follows. In Section 2, we review the existing literature and derive the key conclusions from each stream. We organize the literature first based on the type of regulation, and then by the parties affected. In Section 3, we discuss directions for future research. In this section we focus on further research into the aforementioned interactions. Our discussion of future research opportunities also provides some guidance for a greater focus on understanding causal mechanisms and evaluating reporting outcomes, and points out the benefits of taking a broader view of regulation. Section 4 examines key research choices that determine the effectiveness and efficiency of experimental and survey research on accounting choice. These choices include the realism of stimuli, choice of accounting setting, and selection of participants. We then make recommendations concerning different approaches to examining decision processes. Key issues in this regard include the preeminence of clever experimental design, best practices in mediation analysis, and methods to examine non-conscious processes. Section 5 concludes. Our review focuses mainly on papers published in the 2008 through 2014 volumes of Accounting, Organizations, and Society; Contemporary Accounting Research; Journal of Accounting Research; and The Accounting Review. We also include several working papers from SSRN, and discuss selected older papers that provide the motivation for the more recent papers. 2. Effects of regulation As in Libby and Seybert (2009), we discuss how (1) financial reporting regulations, (2) auditing regulations, and (3) other corporate governance regulations affect managers', auditors', and directors' judgments and decisions with respect to earnings management. A key to this organization is recognizing that each regulation can influence the judgments and decisions of any or all of the R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 three parties involved in the financial reporting process (see Fig. 1). For example, rules on audit committee independence imposed by the Sarbanes-Oxley Act (SOX) may affect directors by inducing greater scrutiny of reported financial numbers (e.g., Cohen, Hayes, Krishnamoorthy, Monroe, & Wright, 2013), but may also affect auditors by increasing the support that they can expect to receive from the audit committee in challenging management (e.g., Cohen, Krishnamoorthy, & Wright, 2010). 2.1. Financial reporting regulation Financial reporting regulations provide the ground-level framework for conveying economically relevant and reliable information to investors, analysts, and other firm stakeholders. They specify both required disclosures and some limits to voluntary disclosures, and, as noted earlier, the requirements and limits still leave room for a good deal of discretion. The effects of auditing and corporate governance regulation depend on the nature of the financial reporting regulations, as auditors and directors often must decide whether the firm's financial reports are consistent with the reporting regulations. The primary responsibility for complying with financial reporting regulations rests with the CFO and CEO of the firm, as codified by SOX, where the signatures of these executives assert the accuracy and fair presentation of the reports. For this reason, much of the financial reporting regulation research focuses on the effects on managers. However, we also discuss recent research examining the effects on auditors and directors. Most of the recent research addresses three broad issues: (1) the effects of rules- versus principles-based standards on reporting choices, (2) the effects of information quantity or information location on reporting choices, and (3) the effects of reporting frequency and accruals timing on investment choices. 2.1.1. Rules versus principles The first and most rapidly growing area of research in financial reporting regulation is motivated by what is often described as a fundamental difference between IFRS and U.S. GAAP accounting e rules- versus principles-based standards. As suggested by Schipper (2003), however, principles versus rules can represent a continuum in any set of accounting standards. An accounting standard is almost always based on a broad underlying principle, and increased Managers REGULATION Financial ReporƟng (SEC and FASB) AudiƟng (PCAOB) Auditors Other Corporate Governance (SEC and Stock Exchanges) Directors Fig. 1. Effects of regulation on earnings management and accounting choice. 27 detail and precision are then layered on top in order to specify criteria for inclusion, exclusion, and application of the principle in specific circumstances. Nelson, Elliott, and Tarpley (2002) provide an important early foundation on which the subsequent research is based, as the authors shed light on how managers attempt to navigate imprecise accounting standards by altering assumptions and precise standards by structuring transactions. Unlike the broad survey evidence in Nelson et al. (2002), recent research often utilizes an experimental design that necessitates focus on a narrow accounting topic such as revenue or lease recognition. For this reason, choosing a proxy for principles versus rules that generalizes to an entire set of standards can be difficult. Two recent studies investigate the effects of principles versus rules on managers' operating lease classifications. Jamal and Tan (2010) test how lease accounting standards impact experienced financial managers' attempts to avoid balance sheet reporting of lease liabilities. They manipulate whether standards are principlesor rules-based and also whether the auditor is principles-, rules-, or client-oriented. The type of standard does not have a substantial effect on overall aggressive reporting. However, a principles-based standard coupled with a principles-oriented auditor leads to increased reporting of lease liabilities on the balance sheet. Agoglia, Doupnik, and Tsakumis (2011) conduct a similar experiment using CFO participants to test whether principles or rules lead to more aggressive operating lease reporting, and how audit committee strength affects this propensity. CFOs choose the operating lease treatment more frequently under the rules-based standard than principles-based standard. A strong audit-committee attenuates this effect. Results of a follow-up experiment reveal that both the probability of regulators second-guessing the lease treatment and a desire to report the economic substance of the transaction underlie the more conservative lease treatment choice under principlesbased standards. McEnroe and Sullivan (2013) provide recent survey evidence on a broad set of accounting issues likely to be impacted by principlesversus rules-based standards. The authors survey CFOs and auditors to ascertain their opinions on whether removing specific accounting rules and replacing them with more general principles would improve the qualitative characteristics of financial reporting. Ten specific rules are presented, including issues such as the choice to account for investments using the equity method, the choice between operating and capital lease treatment, the decision to expense R&D, and the decision to report retail land sales on an accrual basis using the percentage of completion method. For eight of ten issues, participants believe that removing the detailed reporting rules would actually harm reporting quality. Lease accounting represents the sole area in which participants moderately agree that a shift from rules to principles could improve reporting. This result is critical to interpreting the two previously discussed managerial experiments as well as the subsequent auditor experiments where a primary focus is lease accounting e any results from this literature should be generalized with caution as the lease issue may represent a special case in the principles versus rules debate. While the previous studies examined the behaviors and beliefs of managers, most recent research on principles versus rules focuses on auditors. Broadly speaking, this line of research addresses how the precision of the accounting standards upon which auditors must provide their opinions affects their willingness to accept aggressive client-preferred accounting methods. Accounting quality is reduced and earnings management is more likely if auditors are more willing to accept aggressive client-preferred treatments rather than pushing for methods that better reflect the economic substance of a transaction. Many have argued that rules-based standards lead to more aggressive accounting treatments than principles-based standards because they offer a “bright line” for 28 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 preparers to aim for in structuring transactions. Experimental evidence in recent years is generally consistent with Nelson et al.'s (2002) survey finding that audit managers and partners say that they would be less likely to challenge a client's aggressive reporting when the client structures a transaction to meet precise rulesbased standards. Segovia, Arnold, and Sutton (2009) provide some of the first experimental evidence concerning how auditors react to competing pressures from clients versus from the SEC to constrain aggressive reporting. They find support for the idea that auditors are less likely to constrain aggressive accounting under rules-based than under principles-based standards. Further, they find that auditors' experience drives variation in their responsiveness to client vs. SEC pressure. More experienced auditors respond primarily to greater client pressure by requiring greater adjustment to reported numbers (reducing aggressive reporting), while less experienced auditors respond primarily to greater SEC pressure by requiring greater adjustment to reported numbers. It is important to note that aggressive reporting under the rules-based standard involves impairing a long-term asset that has experienced no change in historical performance, while aggressive reporting under the principles-based standard involves expensing supplies that have not yet been used. Thus, the effect of principles versus rules may be attributable to the relatively greater uncertainty about future performance of an impaired asset compared to the relatively lower uncertainty about past use of supplies. Recent research also suggests a specific reason why the greater uncertainty surrounding principles-based standards might improve accounting quality. Cohen, Krishnamoorthy, Peytcheva, and Wright (2013) argue that principles-based standards will improve audit quality because the greater uncertainty created by principles will induce greater personal accountability for the decision process on the part of auditors. Greater process accountability will in turn cause auditors to seek out more audit evidence and discourage aggressive reporting. As with much prior research, the study utilizes a lease scenario where the rules-based standard indicates operating lease treatment is appropriate, but where the principles-based standard suggests the economic substance of the transaction merits capital lease treatment. Auditors are more likely to require capital lease treatment under the principles-based standard than under the rules-based standard, and this holds regardless of the strength of the regulatory regime. Peytcheva, Wright, and Majoor (2014) find that the increased process accountability induced by principles may also have detrimental effects, as auditors request both more diagnostic and nondiagnostic evidence items under principles-based standards. It is important to note an additional caveat concerning the manner in which the leasing standard is operationalized in the previously discussed manager and auditor studies. Typically, the lease just barely meets the criteria for an operating lease under the rules-based standard, and thus the aggressive reporting choice is sanctioned under the standard. The principles-based standard, on the other hand, does not make an explicit allowance for off-balance sheet reporting. Because the principles-based standard is thus more stringent, participants may view aggressive reporting as more difficult in this case. The exception is Agoglia et al. (2011), who conduct a robustness test constrained to participants who view the less precise principles-based standard as conveying similar numerical guidance to the more precise rules-based standard, which does not alter their primary findings. Quick (2013) provides an opposing view on the principles versus rules debate by demonstrating that principles-based standards can allow more flexibility to report aggressively when aggressive reporting is warranted. Using audit seniors and managers, her experiment manipulates the level of legal liability and the precision of the accounting standard regarding revenue recognition in a scenario where aggressive revenue recognition represents the economic substance of the transaction. Results indicate that auditors are more likely to allow aggressive revenue recognition under a principles-based standard and when they have limited legal liability. Two recent papers studying the effects of principles versus rules on auditors provide the most nuanced views on this topic. Backof, Bamber, and Carpenter (2014) find that rules-based standards can facilitate or constrain aggressive reporting compared to principlesbased standards, and that the directional effect depends on the stringency of the rules-based standard. They find that rules-based standards lead auditors to allow more aggressive reporting than principles-based standards for a lease transaction (where the rules indicate an operating lease is appropriate), but principles-based standards lead auditors to allow more aggressive reporting than rules-based standards for a transaction involving revenue recognition for a bundled good (where the rules indicate bundling is inappropriate). This paper thus directly manipulates a key confound in many previously discussed studies e the relative stringency of the rules-based standard as compared to the principles-based standard, and reveals that it is likely this stringency rather than the precision of the standard that determines reporting aggressiveness. Kadous and Mercer (2012) highlight a similar issue regarding the precision of accounting standards. Investigating jury judgments against auditors, they manipulate whether client reporting violates (complies with) a precise standard and find that juries return fewer (more) verdicts against auditors when the precise standard is replaced with an imprecise standard. Backof et al. (2014) also find that providing auditors with a judgment framework that encourages them to take high-level, big-picture perspective of the accounting issue rather than a detailed transaction view can help curb aggressive reporting. Messier Jr., Quick, and Vandervelde (2014) also find that the benefits of principles-based standards for constraining aggressive reporting are not straightforward. In a setting related to the treatment of R&D expenses, they manipulate whether the prior-year standard is IFRS-based and requires capitalization, IFRS-based and requires expensing, or GAAP-based and requires expensing, and find that both US and Norwegian auditor participants anchor on the prior-year standard in making a decision about a current year accounting treatment. Because of this, some of the purported benefits of principles-based standards may be reduced by auditors anchoring on old rules-based standards, which are often still allowed even when principles-based standards are introduced. However, they also find that anchoring on old standards may be reduced if auditors' accountability for the decision process is increased. Taken together, the evidence indicates that the ability of a principles-based standard to constrain aggressive reporting is probably very limited. However, it seems clear that the joint goals of reducing the complexity of standards while also constraining aggressive reporting will only be met where a less-stringent set of rules is replaced with a more-stringent general principle (as in the case of leases). Framing the comparison of principles versus rules in the context of IFRS versus GAAP also seems not to be productive. As Schipper (2003) and Nelson (2003) note, all standards have the potential to include relatively more detail and precision, shifting from a broader principle to a more specific set of rules. The degree of precision is a debate that continues in standard setting around the world, and has the potential to affect all stakeholders in the economy. Unfortunately, few studies have identified the key attributes of principles versus rules that facilitate or constrain aggressive reporting, focusing instead on specific accounting issues such as leases or revenue recognition. Future research might attempt to R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 develop a broader conceptual framework that aids in operationalizing these key attributes as opposed to selecting a specific accounting standard in an attempt to more directly address a current reporting controversy. If future research does choose to focus on comparisons of U.S. versus international accounting standards, the uncertain status of convergence towards a global set of accounting standards suggests that more research may be needed on the effects of a world with incomplete convergence, as was considered by Asay, Brown, Nelson, and Wilks (2013). While the bulk of research on financial reporting regulation and reporting decisions clearly falls within the principles versus rules debate, several other financial reporting regulations have received attention in the literature. The two primary areas involve the quantity of information and location of information that must be presented. These issues are important as they represent other fundamental aspects of financial reporting regulations that differ both within and across regimes. 2.1.2. Effects of the required amount and location of information on reporting choices A number of recent experimental papers investigate how the required amount or location of information impact reporting choices. We first discuss several papers that focus on the amount of information that the firm must disclose, followed by papers that focus on the location of the information that the firm must disclose. Majors (2014) examines whether a mandatory range disclosure of estimate reasonableness alters aggressive reporting behavior, particularly for individuals high in Dark Triad personality traits (Machiavellianism, narcissism, and psychopathy). The study utilizes the experimental economics paradigm with student participants, testing whether incentive-consistent aggressive accounting estimates will be attenuated by a mandated disclosure of a range of reasonable estimates. When range is not disclosed, managers high (compared to low) in Dark Triad personality traits provide more aggressive point estimates for reporting to investors. When range is disclosed, this tendency is attenuated such that all managers report less aggressive estimates. The findings demonstrate that personality interacts with reporting requirements such that the negative impact of manager psychology can be targeted with reporting regulation. Griffin (2014) considers how auditors may also be affected by regulation requiring increased disclosure surrounding fair value measurements. Drawing on moral licensing theory, he shows that supplemental disclosure might actually increase misstatements in fair value reporting. Griffin (2014) considers both input subjectivity (i.e., the reliability of the inputs to fair value estimates) and outcome imprecision (i.e., the degree of variability in future potential outcomes) in his study. He finds an interaction where more subjective Level 3 estimates are more likely to require adjustment from auditors only when they lead to a more imprecise range of possible outcomes. When the range of possible outcomes is precise, auditors' ratings of the likelihood that they would require an adjustment do not differ depending on whether inputs are more or less subjective. However, this interaction goes away when supplemental disclosure is provided to explain the subjectivity in the fair value estimates, as well as the range of potential alternative outcomes. Combined, the results support the idea that including a supplemental footnote disclosure makes auditors feel less responsible and therefore less likely to require adjustment. Further, Griffin (2014) shows that, following auditing standards, auditors' required adjustments tend to anchor on the lower bound of the range of possible outcomes rather than the midpoint, such that the required dollar amount of adjustments is actually lower when estimates of future outcomes are imprecise and thus have a greater range of possible outcomes. 29 The final paper on the amount of information reported considers a specific context in which the firm either may or may not report potentially useful information to stakeholders e the reversal of a large asset impairment. Under IFRS, impairments should be reversed when value increases, but under GAAP this treatment is not permitted. Trottier (2013) focuses on the effect of reversibility on the initial willingness to record the impairment loss. Trottier finds that managers are less likely to record impairments that are not reversible, particularly when they have current bonus incentives. The results demonstrate that managers are worried about foregoing current bonuses that cannot be regained in the future should the asset's underlying value increase. The remaining papers investigate the location in which information must be reported and how this affects reporting outcomes. The determinants and consequences of information location and other presentation effects has been the subject of both archival and experimental research over the last two decades (see Libby & Emett, 2014, for a recent review). Clor-Proell and Maines (2014) investigate an important element of reporting regulation, recognition versus disclosure, to test whether cognitive and process effort by managers contributes to differences in the reliability and bias in disclosed and recognized numbers. Using controller and CFO participants, the authors provide three optional methods for estimating a contingent liability. The methods increase in required effort but decrease in resulting bias such that participants must trade-off reporting accuracy with the effort they are willing to exert. The authors predict that capital market pressure on public company executives will magnify effort and reduce bias in recognized (as compared to disclosed) numbers. The results show that public company executives utilize lower effort for disclosed liabilities and thus report more biased numbers, whereas private company executives exert equal effort regardless of whether the liability is recognized or disclosed. These findings suggest that regulation governing mandatory recognition and disclosure will interact with capital market pressures to determine the ultimate effort and bias underlying information provided to investors. Only one recent paper has examined the effects of earnings presentation regulations on auditor behavior. IFRS currently requires a higher level of disaggregation of expenses than does US GAAP. Libby and Brown (2013) find that U.S. audit managers require correction of smaller misstatements as disaggregation increases on the face of the financial statements. This is consistent with the idea that auditors believe that disaggregated numbers would be subject to greater SEC scrutiny, and that disaggregated line items represent materiality benchmarks. However, Libby and Brown (2013) find that the effect goes away when the disaggregation is instead reported in the footnotes (as is allowed under IFRS), presumably because the footnotes are expected to receive less scrutiny. Interestingly, they also find a substantial amount of disagreement among auditors on the issue of how disaggregation affects materiality. While disaggregation on the face of the financial statements reduces the average amount of misstatement that auditors report they will tolerate, it also increases the variance in their responses. Follow-up questions further highlight this disagreement e 58% say disaggregation changes the materiality of the reported expense amount, but 42% say that it does not. Overall, their study suggests that disaggregation can increase the reliability of reported financial statement numbers because smaller misstatements will likely be corrected at the insistence of auditors, but that there is substantial disagreement among auditors on the issue. Their results suggest that better guidance is needed if auditors are expected to make consistent decisions about materiality. Taken together, research on the amount and location of reported information generally suggests that when more detailed information about estimates or economic events must be reported, 30 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 managers will engage in a lower level of misreporting and auditors will scrutinize the numbers to a greater extent. However, the effect is dampened when information appears in a footnote disclosure rather than on the face of the financial statements e managers and auditors are less concerned about the accurate presentation of disclosed information. However, it is important to note that there may be exceptions to this general intuition, as Griffin (2014) shows that auditors may abdicate their responsibility to require corrections of imprecise estimates if supplemental disclosure makes them feel as though users have received sufficient warning about subjectivity in the reported numbers. While the broader takeaways from the literature may largely confirm readers' prior beliefs, some of the more interesting inferences stem from the subtler interaction effects. For example, increasing the quantity of information reported may be particularly helpful in curbing aggressive behaviors for managers with certain personality traits (Majors, 2014), requiring more prominent disclosure of numbers will lead to higher quality information when capital market pressure is particularly high (Clor-Proell & Maines, 2014), and quantity of information interacts with location of information to determine whether reporting quality improves or does not (Libby & Brown, 2013). These nuances leave a number of important considerations for regulators and stakeholders as they interpret the previous effects of financial reporting regulation and contemplate potential intended and unintended consequences of proposed future regulation. 2.1.3. Effects of reporting frequency and accruals timing on operational decisions The previously discussed financial reporting regulation studies investigated the reporting and disclosure decisions brought about by those regulations. However, reporting regulation may also affect the real decisions that firms make and thus may have unintended economic consequences. Over the last few decades, a number of archival studies investigated the possibility that companies would increase or decrease investment in accordance with the effects of these investments on the financial statements (e.g. Baber, Fairfield, & Haggard, 1991; Roychowdhury, 2006). The Graham, Harvey, and Rajgopal (2005) survey paper, in which experienced executives explicitly indicated their willingness to manage earnings through real (operational) methods, spawned a resurgence of experimental studies in this area. These experiments are particularly helpful because they eliminate the endogeneity concerns that severely limited the breadth of archival studies that could previously be implemented. The archival research relied on very carefully chosen settings and cleverly designed comparisons, where it was still not completely clear that the operational decision could be separated from or attributed to the accrual effects. Wang and Tan (2013) provide evidence on the issue of reporting frequency by examining how the frequency of a voluntary disclosure can alter managers' incentives to sacrifice firm growth for predictable earnings streams. Utilizing MBA student participants, the authors manipulate firm policy on the frequency of quarterly earnings guidance and firm goals regarding that earnings guidance. The manager's task is to choose between two strategic firm projects, one of which will provide higher economic benefits but lower earnings predictability from quarter to quarter, and the other of which will provide lower economic benefits but higher earnings predictability. When the firm's policy is to guide infrequently, participants with accuracy guidance goals prefer the project with lower economic benefits and higher predictability. Participants with meet/beat guidance goals prefer the project with higher benefits and lower predictability. However, when the firm's policy is to guide frequently, participants prefer the lower benefit, higher predictability project regardless of guidance goal. These results suggest that guidance frequency and guidance accuracy goals can each contribute to a short-term focus on earnings predictability that sacrifices long-term operational profitability. Several of the papers in this area involve the timing of expenses. Jackson (2008) examines a depreciation context and finds that managers are more likely to sell an asset that has experienced more depreciation under the accelerated depreciation method (as compared to the straight-line method), holding economic characteristics constant. Additional measures of participant beliefs reveal that the effect of straight line versus accelerated depreciation on the asset disposal decision operates primarily through perceptions of the value that the asset previously provided. Thus, the more “used up” an asset appears to be based on accrual accounting, the more sense it makes to a manager to dispose of it, regardless of the true underlying economic circumstance. Jackson, Keune, and Salzsieder (2013) demonstrate that source of financing can have similar effects on asset disposal decisions. Managers are more hesitant to dispose of debt-financed assets than equity-financed assets, and this is especially true when the unpaid principal on the debt is higher. Similar to Jackson (2008), belief measures indicate that an unpaid principal causes participants to perceive that the asset has provided less value to date. Seybert (2010) explores another expense timing difference, the capitalization versus expensing of research and development, to show that managers are more hesitant to abandon a failing project when the expenditures have been capitalized and they were responsible for initiating the project. This tendency is stronger for high self-monitors (those more concerned about their reputation), and thus the results suggest that reputation concerns will drive investment decisions that can increase reported earnings. Brink, Gouldman, and Rose (2014) extend Seybert (2010) in an experiment with MBA participants who assume the role of middle managers who have knowledge of their superiors' executive compensation incentives. The authors hypothesize that mere knowledge of the executive incentives will induce subordinates to alter investment decisions to optimize the financial reporting outcomes. Results indicate that R&D capitalization (i.e., impairment in the event of project abandonment) increases subordinates' overinvestment in continuing projects when superiors have shortterm unrestricted stock compensation but decreases overinvestment when superiors have long-term restricted stock compensation. These findings suggest that R&D reporting format can negatively impact even middle managers when knowledge of executive compensation exists. The authors also highlight how this phenomenon could be magnified by Dodd-Frank requirements that executive compensation packages receive increased transparency and disclosure. Graham, Hanlon, and Shevlin (2011) conduct a survey of tax executives and multinational corporations to ascertain the effect of non-cash tax expense on real investment decisions. Under GAAP, firms that declare their foreign earnings to be permanently reinvested need not accrue tax expense on the future repatriation of those earnings. This declaration affects the current GAAP tax expense displayed on the income statement and accrued as a liability but not the future cash taxes paid, as the future cash taxes depend upon the actual future repatriation decision. Tax executives are asked to indicate the importance of items such as actual cash taxes, foreign tax rates, and the GAAP tax expense on their decisions concerning which countries to invest in. Responses indicate that the U.S. GAAP tax expense is roughly as important (or even more important for high-R&D firms) as the actual cash taxes and foreign tax rate in making real investment decisions. The same is true for earnings repatriation decisions e the GAAP expense is a very important factor in this real decision. These results suggest that, contrary to economic theory, accrual basis tax expense alters R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 crucial global investment decisions. The final paper investigates how impairment reversibility causes managers to make different investment decisions in impaired divisions. Using student and experienced participants in two experiments, Rennekamp, Rupar, and Seybert (2015) find responsibility for asset impairment in a failing division induces cognitive dissonance in managers. How managers resolve this dissonance depends upon whether reporting regulations allow impairment reversal in the future. When the impairment is reversible in the event of asset value recovery, managers responsible for the initial impairment (compared to managers not responsible for the impairment) allocate greater research and development investment to the impaired division. When the impairment is irreversible, responsible managers allocate lower research and development investment to the impaired division. These differences are attenuated when managers are given an alternate mode of dissonance reduction through denial of responsibility for the division's poor prior performance. The findings suggest that reversible impairments instill a sense of hope in managers who have overseen a failure, while irreversible impairments instill a sense of hopelessness and blame on the failing division. Taken together, the results of these studies demonstrate how reporting differences such as reporting frequency, expense deferral, and impairment reversibility can alter project choices, investment location, and investment magnitude. These decisions may be particularly damaging because they have direct immediate and/or future real economic consequences and represent a tradeoff between short-term reporting issues and long-term firm value. To make matters worse, investors and information intermediaries may have a harder time undoing the effects of these real earnings management choices to discern the true underlying economic state of the firm. This is one reason for managers to implement real earnings management in the first place (e.g., Roychowdhury, 2006). Evans, Houston, Peters, and Pratt (2015) examine its effects on auditors' ability to detect real earnings management, which we discuss in the following section on auditing regulation. 2.2. Auditing regulation Although managers have a responsibility to refrain from earnings management, auditors play a key role in constraining earnings management. Because of this, research that examines how auditing regulation is likely to affect earnings management primarily considers regulations that are intended to increase the likelihood that auditors constrain aggressive managerial reporting, typically by shifting auditors' incentives. Auditors are more likely to constrain aggressive reporting if regulations succeed in either making them more independent from client management (and thus client pressure) and/or more accountable to non-client constituents (e.g., investors, regulators, etc.). This is consistent with the prior literature that suggests auditors must balance their desire to satisfy client management with their desire to avoid litigation, regulatory enforcement, and reputational damage (Hackenbrack & Nelson, 1996). Both increased independence from clients as well as increased accountability to non-clients shift auditors' incentives away from pleasing management and allowing them to report aggressively. We therefore categorize our discussion based on research that focuses primarily on either auditor independence (from client management) or accountability (to non-clients). 2.2.1. Auditor independence Increasing auditors' independence from client management may increase auditors' willingness to constrain managers' aggressive accounting decisions, often by reducing the quasi-rents that 31 result from incumbency. The most common mechanisms for increasing auditor independence that have been examined in the recent literature are firm or partner rotation. Winn (2014) finds that mandatory partner rotation reduces planned effort in the final year of the audit before rotation, and that rotation increases the time spent on documentation relative to other activities that may be more likely to improve audit quality. However, Winn (2014) does not find that rotation affects independence (positively or negatively), where independence is captured by the magnitude of adjustment proposed by auditors. In her study, a larger proposed adjustment goes against client wishes, and reflects a more independent mindset. Bauer (2014) also finds that rotation does not enhance independence, but considers a specific theoretical reason. Drawing on social identity theory, he predicts that auditors can form very strong bonds with new clients quickly, particularly when they share more overlap with the client's norms and values. The results suggest that auditors form a relatively strong relationship with the client after very short tenure, which would tend to reduce the effectiveness of rotation for enhancing independence. More broadly, Daugherty, Dickins, Hatfield, and Higgs (2012) survey audit partners' opinions on how partner rotation affects audit quality. The partners in their survey believe that rotation improves independence, contrary to the evidence in the experimental papers discussed above. However, respondents also suggest that rotation reduces audit quality because it reduces client-specific knowledge and makes audit partners more likely to switch to a new industry rather than relocating their families when it is time to rotate. As a result, they argue that partner rotation leads to broader, but shallower, industry expertise. Efforts that affect auditor independence may also affect the behavior of the managers who are subject to auditors' monitoring decisions. Evans et al. (2015) conduct an international experiment using managers domiciled in the U.S. versus Europe and Asia. Managers choose how much to manage accruals versus real operations to help meet a target. The authors predict and find that stronger audit enforcement in the U.S. induces managers to prefer the less detectable real earnings management to accruals earnings management, both when they are managing earnings upward and downward. Under less stringent international audit enforcement, managers prefer to use accruals for downward but real decisions for upward earnings management. These results suggest that the differences in audit regulation and enforcement across regimes can induce managers to engage in different forms of earnings manipulation. 2.2.2. Auditor accountability The second stream of research investigating the effects of audit regulations focuses on increasing auditor accountability to nonclients (e.g., investors, regulators, etc.), although many results in this stream suggest that these regulations may not work as intended.2 An early example is Kadous, Kennedy, and Peecher (2003) who show that an SEC mandate to assess the quality of a client's preferred accounting method, as well as alternative methods, might actually increase auditors' commitment to a client-preferred method. This presumably occurs because motivated reasoning leads them to process information in a way that supports the client's preferences, rather than processing information objectively. 2 Although not specifically focused on the effects of regulation, Trotman et al. (2015) review literature that examines another source of auditor accountability e the hierarchical review process. Their discussion provides an overview of research on how different operationalizations of the review process can affect preparers' accountability and, ultimately, audit outcomes and audit quality. 32 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 More recent research builds on the idea that increased auditor accountability may not be effective, or may have unintended consequences that result from cognitive biases. For example, Piercey (2011) looks at how documentation requirements affect the leniency of auditors' judgments. He finds that documentation can actually make auditors more lenient with clients on a misstatement task if they document their risk assessments qualitatively rather than quantitatively. Piercey (2011) suggests that qualitative risk assessments allow for more wordsmithing and ex-post flexibility in defining what a term means, so that lenient risk assessments are more justifiable should something go wrong. Winn (2014) manipulates the likelihood of a PCAOB inspection, which should also affect accountability to regulators. While she finds that the expectation of a PCAOB inspection increases planned audit effort, she does not find that it increases the extent to which auditors require correction of a potential misstatement. Thus, one important takeaway from Winn's (2014) paper may be that increased audit effort does not necessarily always translate to an improved audit outcome (in her case, misstatement correction), which could have implications for whether we view increased audit effort as either a positive signal regarding the audit process or instead an indicator of reduced audit efficiency. At a broader level, Westermann, Cohen, and Trompeter (2014) survey experienced auditors to understand how different sources of accountability affect professional skepticism. While accountability that arises from PCAOB inspections and documentation requirements generally increase professional skepticism, competing sources of accountability (e.g., for engagement profitability) may reduce professional skepticism. Further, responses also suggest that the enhanced professional skepticism that arises from regulation may induce a “check-the-box” mentality, which could actually harm audit quality. In fact, this type of “check-the-box” mentality may help account for Winn's (2014) finding that accountability increases audit effort but does not improve misstatement correction, in that auditors may be primarily concerned with the appearance of providing a thorough audit, rather than with actually improving audit processes. Combined, research on the effects of increasing auditor accountability via regulation suggests that it may be insufficient for constraining earnings management, particularly if it cannot overcome auditors' cognitive biases and competing sources of accountability. Still other papers examine how regulations that affect auditor accountability influence the decisions that audit committee members make in carrying out their oversight responsibilities. If auditing regulations that increase accountability induce too much compliance-focused behavior, one potential countermeasure would be to introduce an Audit Judgment Rule (AJR) that prohibits second-guessing of auditor's estimates when they are made in “good faith and in a rigorous, thoughtful, and deliberate manner” (Peecher, Solomon, & Trotman, 2013). Kang, Trotman, and Trotman (2014) find that, in the presence of such an AJR, audit committee members feel greater accountability to ensure the reasonableness of the financial statements, although, on average, it does not make them more skeptical or increase the number of probing questions that they ask of the auditor. While an AJR might decrease auditors' accountability, a separate proposal that could instead increase auditors' accountability is the requirement of additional audit report disclosure of critical audit matters (i.e., areas that include significant management judgments and estimates, or areas with significant measurement uncertainty) (IAASB, 2013; PCAOB, 2013). This type of mandated disclosure arguably increases auditors' accountability by drawing attention to areas requiring greater attention in the audit. Kang (2014) manipulates (1) whether such a disclosure is required, as well as (2) whether the investor audience is sophisticated, and finds that audit committee members are more likely to challenge management's estimates in the absence of the mandated disclosure, but only when the investor base is relatively sophisticated. When the additional audit disclosure is mandated, audit committee members are less likely to question management's estimates, suggesting that, while the additional proposed disclosure in the audit report may increase auditors' accountability, it may simultaneously reduce the amount of oversight by audit committee members. Additional analyses suggest that the decline in audit committee oversight may be driven by greater perceived accountability to management than to investors, suggesting that the outcome may be different if responsibility towards investors is particularly salient to the audit committee. Overall, the research that examines how auditing regulations affect earnings management suggests that the effects of regulations are more complicated than they may at first appear to be. Results in a variety of settings demonstrate that both increased auditor independence and increased auditor accountability can fail to produce desired outcomes and, in some cases, can even lead to unanticipated consequences. Some research suggests that increased independence from client management may not improve outcomes, particularly if auditors are quick to form bonds with new clients such that independence is compromised. Other research on accountability to non-clients suggests that it increases effort and/or documentation, but may not actually improve outcomes. Still other research suggests that increasing the accountability of one group reduces perceived accountability of another group and may lower overall reporting quality. Thus, it is still largely an open question as to which types of regulation might successfully shift auditors' incentives away from pleasing client management and towards pleasing other non-client constituents. We now turn our discussion to research on the effects of corporate governance regulations. 2.3. Corporate governance regulation Audit committee members may be the last line of defense constraining earnings management. Because of this, much of the research on the effects of corporate governance regulation has examined how regulations might help the audit committee to be more effective in carrying out its oversight duties. Like auditors, audit committee members must balance their desire to please management with their desire to constrain management and please others. Also like auditors, audit committee members are more likely to constrain aggressive reporting by management as they become more independent from management and/or more accountable to constituents other than management. We therefore structure our discussion of corporate governance regulation based on research that focuses primarily on either audit committee independence (from management) or accountability (to nonmanagement constituents). We conclude the section with a discussion of research that investigates how auditors react to changes in audit committee members' independence and accountability. 2.3.1. Audit committee independence To facilitate oversight of financial reporting, one specific requirement of SOX is that the audit committee consist of independent directors, presumably to improve the flow of information with auditors and to reduce the potential for influence by managers. In interviews with 22 experienced directors, Cohen, Krishnamoorthy, et al. (2013) provide evidence on how this may affect financial reporting quality. Consistent with the idea that SOX gives audit committees greater authority over the audit process, the vast majority of respondents (86%) indicate that the audit committee has the most say over hiring and firing decisions with R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 respect to the external auditor, although they also agree, on average, that management still has some influence in the process. Directors also generally agree that the frequency of meetings with external auditors has increased post-SOX, and that these meetings involve more back-and-forth exchange of substantive questions and ideas. SOX also requires that the audit committee include at least one “financial expert”.3 Cohen, Krishnamoorthy, et al. (2013) also provide some evidence on the effects of this requirement. While the majority of directors agree that there is sufficient financial expertise on audit committees (post-SOX), some expressed concern that those who qualify as “financial experts” tend to be more rulesoriented and less knowledgeable about the broader business of the firm. As a result, some believed that financial experts were less likely to understand and identify the business risks of the firm, albeit were more likely to understand and identify risks related to financial reporting quality. While the structure of the board can directly affect its independence, Magilke, Mayhew, and Pike (2009) provide evidence on a specific institutional feature e stock-based compensation e that may further affect audit committee members' independence and ability or willingness to constrain aggressive financial reporting. Using an abstract experimental market with student participants, they find that audit committee members are most objective in the absence of stock-based compensation.4 In the presence of stockbased compensation, they find that audit committee members are biased towards upward earnings management when they receive stock-based compensation tied to the earnings of current shareholders, but more conservative, downward, earnings management when they receive stock-based compensation tied to the earnings of future shareholders. The results of the experiment suggest that independence requirements imposed by SOX may be compromised by the form of compensation that is provided to audit committee members, in that stock-based compensation may reduce willingness to constrain aggressive earnings management. Persellin (2013) uses an experiment with MBA student participants serving as proxies for audit committee members to examine the effects of both compensation and likelihood of PCAOB inspection. Consistent with prior research on the effects of stock option compensation (e.g., Magilke et al., 2009), she finds that participants are more likely to side with management (in this case agreeing that an income-decreasing adjustment is not necessary) when compensation is based on stock options rather than cash. However, this only occurs when the likelihood of a PCAOB inspection is low. The effect is moderated when the likelihood of PCAOB inspection is high, where participants are instead more likely to agree with auditors that an income-decreasing adjustment is necessary, regardless of the form of compensation. Thus, while PCAOB inspection may be primarily intended to increase the accountability of auditors, Persellin (2013) finds that the threat of inspection may also increase the willingness of audit committee members to act independently of management's wishes. 2.3.2. Audit committee accountability In cases where audit committee independence may be compromised, one potential solution is to increase disclosure about audit committee members' compensation and/or relationships with management. This has the potential to increase audit committee members' accountability to non-management constituents, 3 Alternatively, if no financial expert serves on the audit committee the firm must disclose why that is the case. 4 Section 4 includes additional discussion on when non-experts are most likely to be a reasonable proxy for experienced professionals in an experiment. 33 by drawing attention to potential areas of concern. Two recent experiments using active directors as participants look at how transparent disclosures can increase accountability and alleviate or exacerbate problems associated with a lack of audit committee independence. Rose, Mazza, Norman, and Rose (2013) examine the interactive effects of director stock ownership and transparency of director decisions. They show that stock-owning director participants in their experiment are more likely to oppose earnings management attempts by management if their board discussions are transparently disclosed. This indicates that the often suggested policy of required stock ownership for directors should be tied to greater transparency of director reporting if the audit committee is to be an effective check against earnings management. Rose, Rose, Norman, and Mazza (2014) examine whether disclosure of any relationship between a CEO and board members can increase director accountability to non-management and help to mitigate problems associated with a lack of independence from management. They first demonstrate that friendship ties increase directors' willingness to accept proposed R&D cuts to meet the CEO's bonus target. These cuts improve reported short-term performance to benefit management, but at the expense of long-term performance of the firm. Further, the authors find that disclosure of friendship ties may backfire, and actually increase directors' propensity to approve the cuts proposed by the CEO. This counterintuitive result is presumably driven by the fact that disclosure of friendship ties provides directors with a subconscious psychological “moral license” to engage in more selfish behavior. In other words, the fact that the relationship is disclosed makes directors feel as though they have fulfilled their professional responsibilities, giving directors more psychological freedom to act in the best interest of their friend (the CEO). Finally, Rose et al. (2014) find that investors are more likely to agree with the directors' decisions when friendship ties are disclosed, consistent with the idea that investors view the disclosures as a signal of directors' transparency and objectivity. Combined, the results of this study suggest the importance of independence between directors and CEO's, and that simply disclosing any relationship between the two is not sufficient for increasing directors' perceived accountability and constraining earnings management. 2.3.3. Effects of corporate governance regulations on auditors Although corporate governance regulations are aimed primarily at changing the behavior of management and audit committee members, research has examined how auditors might also be affected through the amount of support they expect to receive from audit committee members in constraining aggressive reporting. The recent research builds on earlier studies discussed in more detail by Libby and Seybert (2009). For example, Libby and Kinney's (2000) experiment suggests that, pre-SAB99 and pre-SOX, boards were not a particularly effective control on earnings management to meet earnings benchmarks. They find that, even in the presence of a requirement to report uncorrected misstatements to the audit committee, auditors still allow managers to engage in earnings management, and avoid full correction of quantitatively immaterial misstatements, if correction would lead to a missed analyst consensus forecast. Further supporting the importance of a strong audit committee, Ng and Tan (2003) similarly find that audit managers, on average, expect a smaller adjustment of a material misstatement in the absence of a strong audit committee and authoritative guidance on the audit issue. DeZoort and Salterio's (2001) earlier survey of experienced directors finds that auditors can expect more support from audit committee members that have either more audit knowledge or more experience on independent corporate boards. More recent papers further support the idea that auditors can 34 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 expect more support and involvement from the audit committee in the post-SOX environment. Beasley, Carcello, Hermanson, and Neal (2009) find that audit committee members appointed post-SOX are more likely to question auditors about methods and potential alternatives. Cohen et al. (2010) interview experienced auditors, who indicate that their planning phase has become much more dependent on perceived strength of corporate governance in the firm. Whereas meetings with the audit committee pre-SOX were fairly passive, auditors' perception is that meetings are now much more active and involve more give-and-take. Providing complementary evidence, Cohen, Krishnamoorthy, et al. (2013) conduct detailed interviews of experienced directors to get their opinions on the effects of SOX. Consistent with Cohen et al.'s (2010) interview results, Cohen, Krishnamoorthy, et al. (2013) find that directors believe the meetings between auditors and the audit committee have become more frequent and more involved, and that the issues discussed are more substantive. However, they also find that directors perceive that, post-SOX, auditors have become more frustrated, more overworked and much more rules-oriented or rigid, presumably out of greater concern about facing litigation and PCAOB inspection. Directors express the belief that auditors now act more like “policemen” rather than collaborators with management and the audit committee. While directors' responses in Cohen, Krishnamoorthy, et al. (2013) suggest that SOX may have had some negative effects on auditors' attitudes, they also suggest that auditors may be taking their monitoring role even more seriously to crack down on aggressive accounting. This is also consistent with responses provided by CFOs in the survey by Dichev, Graham, Harvey, and Rajgopal (2013). Cohen, Gaynor, Krishnamoorthy, and Wright (2011) examine audit partners' and managers' decisions in light of the strength of audit committee independence. They predict and find an ordinal interaction. Auditors waive the largest amount of the proposed adjustment, regardless of audit committee independence, when managers have low incentives to manage earnings, presumably because the risk of misstatement is low. When managers have strong incentives to manage earnings (i.e., to meet/beat a forecast), auditors waive more of a proposed adjustment when the audit committee is less independent. Their results provide additional support for the idea that audit committee independence may increase the extent to which auditors believe that they will have backing from the audit committee in pushing for an adjustment. A big takeaway from Cohen et al. (2011) is that auditors appear to be relatively lenient when their enforcement is needed the most e that is, when incentives to manipulate are high and the audit committee is not very independent and therefore unlikely to challenge the CEO. Not all studies support the idea that increased audit committee independence has been beneficial for auditors. McEnroe (2007) surveys CFOs and audit partners and finds that, while they agree that SOX reduces egregious earnings management that violates GAAP, they believe it has limited impact on within-GAAP manipulations. Gibbins, McCracken, and Salterio (2007) survey CFOs and find that they think audit committee independence as well as who serves as the chair of the committee are unimportant in resolving auditor-manager disputes. Respondents in their survey indicate that the audit committee does not help to resolve conflicts, and instead wants information brought to their attention only after a resolution has been reached. Only half of the respondents say that the audit committee plays an important role in resolving conflicts with management. Combined, the evidence in the research on corporate governance regulations suggests that audit committee involvement has improved in recent years, and more knowledgeable and independent directors have been more likely to support correction of discovered errors and constrain earnings management. But, in some cases it appears that directors are not as effective at helping auditors to actually reign in within-GAAP earnings management. 3. Future research From our review of the literature, some broad themes emerge about where future research has the potential to make the greatest contributions. We structure our review of research along the dimensions of financial reporting regulations, auditing regulations and corporate governance regulations. This is, in part, driven by the fact that most research examines the effects of only a single given regulation, and mostly on a single decision maker. In the real world, however, multiple regulations have the potential to influence behavior, often in competing ways. 3.1. Important interactions 3.1.1. Multiple actors There is room for more research on how a given group is affected by regulations that may be primarily intended to affect another group. For example, much of the research on financial reporting regulations looks at effects on managers or on auditors, but pays less attention to the effects on audit committee members who are not the primary target of those regulations. Additional research on the effects of other aspects of financial reporting regulation on audit committees would be useful. Both Libby and Kinney (2000) and Nelson et al. (2002) rely on auditor participants' perceptions to draw inferences about the effects of regulation on audit committee members and managers, respectively. This indirect approach may also be useful in other areas, especially given the difficulty in recruiting experienced directors for experiments and surveys. Studies of audit regulations look primarily at the effects on auditors. Some notable exceptions are Persellin (2013), Kang (2014), and Kang et al. (2014), which all examine how existing or proposed auditing regulations affect the behavior of audit committee members. These studies provide some evidence on how regulations affecting auditors' accountability and/or independence affect the stance that audit committee members take in their interactions with auditors. Trotman, Bauer, and Humphreys (2015) call for additional research that both manipulates audit committee member behavior and observes resulting auditor behavior or, alternatively, manipulates auditor behavior and observes the resulting behavior of audit committee members (e.g., with respect to their questioning of auditors). Future work could also examine how auditing regulations affect managers' actions and interactions with auditors. Evans et al. (2015), which examines the effects of stronger audit enforcement on managers' choices between accruals and real earnings management, is a recent example examining this category of issues. Finally, although corporate governance regulations are often aimed at both directors and managers, less work is being done in the experimental literature on how corporate governance regulations affect managers' behavior. One exception is Ugrin and Odom (2010), which investigates the likely impact of increased sanctions imposed by SOX on executive attitudes toward fraudulent reporting. They find that increasing jail time from one to ten years significantly dampens attitudes towards misreporting, whereas further increases from ten to twenty years have no significant impact. Further analyses indicate that the primary costs of jail time to executives come in the form of career opportunities and social costs, such that even relatively small criminal sanctions represent a strong disincentive to engage in fraudulent reporting. We suggest that future work should do more to examine the effects of corporate governance regulations on managers, particularly since they R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 are often targeted by such regulations. To date, most of the evidence in this area has been provided via archival, rather than experimental, research (see, e.g., Beyer, Cohen, Lys, & Walther, 2010; Cohen, Dey, & Lys, 2008). In a similar vein, there is also still a lack of research examining the effects of a single regulation on multiple actors (managers, auditors, and directors). Much of the research focuses on how a given regulation, along with other factors, influences the judgments and decisions of a given group with respect to earnings management decisions. While this provides useful information, it would also be useful to better understand how regulations influence the behavior of a given group in light of how another group is influenced. For example, Cohen, Krishnamoorthy, et al. (2013) provides evidence on auditors' perceptions of how board members' activities are affected by corporate governance regulations, and how board members' interactions with auditors have changed in response to auditors' reactions to corporate governance regulations. Although survey research has provided some evidence on how different groups react to regulations in light of the reactions of other groups, we propose that future experimental research could provide additional insights to the literature. This is particularly important given than an individual regulation may push one group in a direction that is offset by another group. For example, imposing an AJR that limits second-guessing of auditors' judgments may reduce auditors' accountability to non-clients, but may be offset by increased feelings of responsibility for oversight by directors (Kang et al., 2014). Similarly, auditors' responses to changes in the auditors' report (e.g., disclosure of “key” or “critical” audit matters; IAASB 2015) may be seen as relieving either managers or audit committees of some of their responsibilities. 3.1.2. Multiple regulations We also suggest that future research should do more to consider that regulations do not operate in a vacuum, and that individuals may be affected by multiple regulatory efforts at once. One paper that bridges this gap is Persellin (2013), which examines audit committee members' behavior in light of both their own compensation (which is impacted by corporate governance regulations) but also PCAOB inspection (an auditing regulation). Another is Griffin (2014) whose effects result from a combination of financial reporting regulations and auditing standards related to fair value measurement. We believe that these joint effects are a particularly important area for future research. 3.1.3. Interactions among accounting choices Related to the need to examine how the interaction of regulations or groups affect reporting outcomes, there is also a lack of literature examining interactions among accounting choices and how they are affected by context and the regulatory environment. The tradeoff between real and accruals earnings management represents one such broad category. Very few papers (including archival papers) over the last decade have examined this issue. One exception is the Evans et al. (2015) study suggesting that managers in the U.S. GAAP regulatory environment exhibit a greater preference for real over accruals earnings management than managers in an international IFRS environment. However, the specific drivers of this difference are open for future research. Numerous financial reporting, auditing, and corporate governance regulations would likely impact managers' assessments of the tradeoff between these two earnings management methods and/or auditors' and audit committee members' ability to detect them. Another broad category of accounting choice interactions would be numbers reported in the financial statements versus voluntary disclosures of quantitative or qualitative performance information. While studies have 35 examined the effects of disclosure regulation itself (e.g., Clor-Proell & Maines, 2014; Majors, 2014), it remains unknown how regulations targeting qualitative disclosure would simultaneously affect the reporting of other quantitative information (or vice versa) as either complements or substitutes. In the real world, a large set of reporting and disclosure choices are interdependent and managers must choose the optimal combination, whatever their objective function may be. 3.2. Understanding causal mechanisms and outcomes As noted in Section 1, key elements of the experimentalists' comparative advantage in the study of earnings management and accounting choice are the ability to study effects on each party to the process and to separate the effects of specific elements of a regulatory regime. Where a finer understanding of the process is important, there is a need for future experimental or survey research to tackle issues that have so far been addressed primarily by archival research. For example, the PCAOB is considering whether to require the engagement partner on an audit to sign the audit report. Carcello and Li (2013) use archival data to examine whether such a requirement will affect audit quality. Their study compares U.K. firms (that currently have a similar signature requirement) to a matched sample of U.S. firms (where no such requirement exists), and finds evidence consistent with the idea that a signature requirement improves audit quality. While a matched sample helps mitigate concerns about differences in U.K. and U.S. firms, other cultural, regulatory, and enforcement differences between the two countries are likely to remain and may affect their analyses. Again, an experiment can hold constant differences across firms and environments to provide convergent evidence on the potential effects of these types of proposed regulations, as well as provide insights into the precise causal factors though which these effects occur. 3.2.1. Understanding causal mechanisms Understanding causal mechanisms requires a careful conceptual structuring of the earnings management process and an understanding of which parts are targeted for change by an existing or proposed regulation. We believe that research can benefit from structuring at three levels: (1) elements of the earnings management process, (2) economic drivers, and (3) psychological drivers. 3.2.1.1. Elements of the earnings management process. Researchers should carefully consider whether they expect a regulation to improve prevention, detection, and/or correction of earnings management. For example, increases in the magnitude of potential sanctions against management and the client firm for GAAP violations, or within-GAAP biases in reporting, presumably are aimed at preventing or discouraging earnings management attempts. Holding constant auditors' and audit committee members' willingness to correct misstatements, regulations that are meant to increase effort likely constrain earnings management through better detection. Holding constant auditors' and audit committee members' detection of misstatements, regulations that are meant to increase independence from management likely constrain earnings management through increased correction of detected misstatements. Some regulations may also affect more than one element of the earnings management process. As Nelson et al. (2002) demonstrate, the level of precision in a financial reporting standard can affect both the likelihood of an earnings management attempt and auditors' correction decisions given detection. Furthermore, some regulations may be designed to improve both detection and correction. 36 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 In designing an investigation of the effects of a regulation, it is useful for researchers to first think carefully about what the regulation is meant to achieve. If a regulation is meant to operate through improved detection, the setting must be such that variation in detection can be observed, and the dependent variable must likewise relate to detection of a misstatement rather than correction (and vice versa if the regulation is meant to improve correction). Furthermore, carefully delineating detection effects from correction effects and choosing the appropriate dependent variables may change our perceptions of whether a given regulation appears to be effective. For example, if a given regulation is designed to improve detection, one should not conclude that the regulation is ineffective if it does not lead to differences in dependent variables that capture correction of misstatements. 3.2.1.2. Economic drivers. In Section 1, we discussed the fact that managers' choices are often modeled as balancing managerial selfinterest and current shareholders' interests. Some reporting regulations such as those increasing transparency seem aimed at bringing those interests into closer alignment. Reporting regulations that affect timing of recognition of revenues and expenses and timing of reports appear to operate simply by changing what real actions are in the manager's self-interest or the current shareholders' interests. Auditing regulations and corporate governance regulations seem to be aimed either at increasing independence by decreasing the value of satisfying client management, or increasing accountability by increasing the costs of litigation, regulatory enforcement, and long-term reputation loss. For example, mandatory audit firm rotation or consulting prohibitions should increase independence by decreasing the value of satisfying management. Inspection requirements increase the likelihood of sanctions on auditors, and other aspects of the Sarbanes-Oxley Act increase the magnitudes of sanctions, both of which increase the expected costs of litigation, regulatory enforcement, and long-term reputation loss to auditors. Similarly, regulation of the compensation of directors can increase independence by affecting the value of satisfying client management, and regulation of disclosures about board actions can increase accountability by increasing the expected costs of litigation, regulatory enforcement, and reputation loss. Future research would benefit from more precise specification of the economic drivers underlying hypothesized changes in behavior. 3.2.1.3. Psychological drivers. More fundamentally, a number of recent studies have focused on the effects of underlying cognitive processes on reporting choices. For example, recent papers have examined the effects of the related concepts of mindset and construal level on auditors' evaluations of accounting choices (Griffith, Hammersley, Kadous, & Young, 2015; Rasso, 2015). Both studies have implications for audit guidance and the organization of workpapers provided within audit firms. An understanding of these effects may also have implications for understanding the effects of auditing regulations that operate through the same processes. Similarly, Asay (2014) and Brown (2014) show how horizoninduced optimism and cognitive dissonance can bias both managers' probability estimates and utilities for outcomes that are key determinants of earnings management attempts. These effects may also provide a basis for designing and predicting the effects of specific regulations aimed at reducing these effects in management choices. Recent experimental and archival studies (Guggenmos, 2015; Pacelli, 2015) also demonstrate how broad elements of corporate culture can affect the aggressiveness of financial reporting choices and the accuracy of analysts' estimates. These types of carryover effects suggest that corporate culture may moderate the effects of a regulatory change on actions by the parties involved in earnings management and accounting choice (see Tarullo, 2014, for a discussion in the context of banking regulation). These issues are ripe for experimental and survey explorations. 3.2.2. Evaluating reporting outcomes Takeaways from the research on the effects of regulation would be much clearer if researchers considered three issues related to financial reporting outcomes. First, it is clear that there are important contingenciesdunder some conditions the effect of a regulation can be positive and under some conditions it will be negative. Second, some regulatory changes have multiple effects (e.g., they provide a benefit but increase a cost). And third, some effects on process do not lead to reporting improvements. Considering these three possibilities will help researchers explain the possible implications of their research for practice, as well as consider related directions for future research. For example, some research on the effects of audit regulation appears to treat increased audit effort as being synonymous with increased audit quality. Similarly, some research on the effects of corporate governance regulations appears to treat increased meetings and interaction between auditors and the audit committee as a signal of improved audit committee oversight. However, in both cases it could instead be argued that the regulations are increasing the appearance of audit quality and audit committee oversight, but that actual outcomes are not improving. 3.3. A broader view of regulation Finally, we encourage researchers to expand their definition of what constitutes research on “regulations”, since variation in enforcement can occur in the absence of formal regulatory changes. The breadth and importance of these less formal regulatory channels can be seen from the issues discussed at the 2014 AICPA National Conference on Current SEC and PCAOB Developments (see PwC, 2014 for a review). At that meeting, representatives of the SEC discussed current regulations that were under review, indicated specific concerns about how factors used to determine operating segments following current standards were being weighted, indicated that the SEC would increase its focus on adequacy of income tax expense disclosures for 2015, reported on changes in enforcement practices requiring that more companies admit wrongdoing rather than “neither admit nor deny” responsibility, and discussed the future of IFRS for domestic companies as well as many other topics. Similarly, on the auditing side, PCAOB representatives discussed a variety of current standardsetting initiatives, results and findings from current inspections, and recent enforcement actions. FASB and IASB staff also discussed current projects (e.g., leases) and implementation efforts related to new standards (e.g., revenue recognition). Note that these topics include more detailed interpretations of existing standards and regulations, warnings in advance about areas of increasing scrutiny which could lead to more detailed interpretations or enforcement actions in the future, and even changes in the magnitude of sanctions imposed for certain infractions. None of these regulatory or enforcement changes require a change in existing laws, standards, or regulations. 4. Methodological considerations Some methodological best practices for experimental research in accounting are universal. For a discussion of these we refer readers to discussions in Libby, Bloomfield, and Nelson (2002), Kachelmeier and King (2002), Nelson and Tan (2005), and Bonner (2008). In this section of the paper, we instead focus on methodological suggestions that are particularly relevant for research on R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 the effects of regulations on earnings management and accounting choice. 4.1. Realism of stimuli A key advantage of using experimental research to address questions about the effects of regulations is that experiments are able to create settings that do not yet exist. This allows for ex ante research on accounting standards, which may help regulators understand the consequences (both intended and unintended) of what is being proposed before costly regulations are put in place. However, this also creates some challenges from an experimental design perspective when it comes to determining the appropriate level of realism for experimental stimuli. The regulatory process can take many years, and proposals often go through many iterations (e.g., see the Libby & Kinney, 2000, study of the effects of the proposed SAS 89). Researchers who map their stimuli too closely to a current proposal may be unable to provide much insight should a proposed regulation be changed down the road. From a design perspective, researchers should choose a level of realism in their materials that appropriately captures the constructs of interest rather than the specifics of a proposal at a given time. We encourage researchers to think about the conceptual aspects of a given proposal that are most interesting. This allows us to learn something even if (or, more likely, when) a proposal changes or is never adopted. For example, regardless of whether the United States ever actually adopts IFRS, the SEC has expressed interest in moving away from rules-based standards and towards more “objectives-based” standards (SEC, 2012). This suggests that, regardless of whether IFRS are ever adopted in the U.S., research is still important if it can inform us on the effects of differences in the specificity, use of examples, and other attributes of “rules-based” vs. “principles-based” standards. As another example, recent research has started to investigate the effects of discussing Key or Critical Audit Matters (CAMs) in the audit report, both in terms of how it will affect auditors (Kang, 2014; Kang et al., 2014) and investors/jurors (Backof et al., 2014; Brasel, Doxey, Grenier, & Reffett, 2014; Brown, Majors, & Peecher, 2015; Gimbar, Hansen, & Ozlanski, 2014; Kachelmeier, Schmidt, & Valentine, 2014). While there is still some uncertainty about what a CAM disclosure might look like or include, we can nevertheless learn from these papers so long as their materials successfully capture important elements of the construct of increased disclosure about areas that posed the most difficulty for auditors or required the most subjective and complex auditor judgments. Future research can also examine which elements of CAM disclosures cause any discovered effects. 4.2. Choice of accounting setting Related to the idea that an appropriate level of realism should be chosen, researchers must also be careful to select an appropriate experimental setting. From our review of the literature, it is clear that there is a lot of interest in understanding the effects of principles- vs. rules-based standards. Many of these studies use lease accounting settings to contrast the two types of standards, perhaps because it is a convenient one since there is general agreement that current lease accounting standards are rules-based. However, McEnroe and Sullivan (2013) survey Fortune 1000 CFOs and experienced auditors about principles-based vs. rulesbased standards, and find that lease settings may differ from most others. They give respondents ten settings where GAAP incorporates rules, and ask whether elimination of the rule would lead to accounting that better achieves the conceptual framework's definition of useful financial information. In almost all settings, the majority of respondents agree that financial reporting is improved 37 by keeping the rule rather than switching to more principles-based standards. Importantly, the one setting where they believe the rule should be eliminated is with operating leases. This suggests that a lease setting may be quite different from many other settings, which could affect the generalizability of the results in prior research. At the very least, we encourage researchers and standard setters to be clearer about the meaning of rules-based and principles-based, and researchers to expand the number of settings that they examine in the future when contrasting the effects of elements of principles- vs. rules-based standards. 4.3. Selection of participants Libby et al. (2002) suggest that the choice of participants should match the goal(s) of an experiment, and that researchers should not use more sophisticated participants than is necessary to achieve those goals. Sophisticated participants are appropriate when the goal of an experiment is to investigate the effects of a regulation in a setting that requires a strong understanding of institutional features (i.e., studies that “peer into the minds of experts”). For example, experienced auditors are likely necessary for research that investigates how auditors' behavior changes in response to regulations that affect the style and content of the audit report. Alternatively, less sophisticated participants are appropriate when the goal of an experiment is to investigate fundamental psychological biases or economic behaviors (Libby et al., 2002). Student subject pools may be a useful source of less sophisticated participants (see, e.g., Elliott, Hodge, Kennedy, & Pronk, 2007, for a discussion of when MBA students are likely to be appropriate). Researchers are also increasingly using Amazon's Mechanical Turk (AMT) platform to recruit participants (see, e.g., Farrell, Grenier, & Leiby, 2014; Krische, 2014; Rennekamp, 2012). Regardless of their source, the use of less sophisticated participants allows researchers to address many more unanswered questions, because the availability of less sophisticated participants is much greater. A number of studies have used less sophisticated MBA student participants as proxies for managers to investigate regulatory effects (Brink et al., 2014; Jackson, 2008; Seybert, 2010; Wang & Tan, 2013). However, very few studies have used less sophisticated participants to examine the effects of regulation on earnings management and accounting choice on auditors or directors (see Persellin, 2013, for an exception). While we believe the studies we review in this paper have generally made appropriate use of sophisticated auditor and director participants, we do not know how many interesting research questions have been abandoned because researchers assumed that they could not be answered using less sophisticated participants. Some of this may be due to entirely appropriate concerns that those involved in the review process will be dismissive of “auditor” and “audit committee” studies that do not use actual auditors and directors as participants. Thus we not only encourage researchers to use less sophisticated participants (again, where appropriate), we also encourage journal editors and reviewers to be open-minded to their use, and to actively consider that less sophisticated participants might be appropriate for answering certain questions related to fundamental biases and behaviors. At the same time, if the goal is to “peer into the minds of experts,” more costly experienced participants are necessary. Here we encourage researchers to be entrepreneurial in their attempts to obtain appropriate participants. We also encourage editors to recognize that the costs of additional experimentation are much higher in such studies. 4.4. Examining decision processes As we note throughout the paper, an important part of the 38 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 comparative advantage of experiments and surveys is the ability to disentangle the effects of correlated variables and gather intermediate process measures that allow assessment of the impact of specific motives, beliefs, and cognitive processes of the parties involved. There are many ways that experiments and surveys can be designed to provide a more detailed description of decision processes. We believe that the current literature would benefit from a broader view of decision process analysis. We discuss this issue under three headings: 1) the preeminence of clever experimental design, 2) process measures and mediation, and 3) nonconscious processes. 4.4.1. The preeminence of clever experimental design Certainly, the most influential decision researchers of the last 50 years are Daniel Kahneman and Amos Tversky.5 Every decision researcher should read and reread their work. It is important to note that their early work was the subject of intense criticism from many who had more orthodox views of decision processes. They very successfully fended off and converted many of their critics by their ability to design clever experiments that were remarkably simple in concept: they constructed two settings which their theory suggests would result in different effects, and then randomly assigned subjects to those settings. When alternative explanations were raised, they would either point out how those theories could not explain the results, or design another simple experiment whose results could not be explained by those alternative theories. We note that they rarely, if ever, gathered intermediate process measures (we discuss their use below). It is important to note that simple two-celled experiments cannot always be designed to eliminate alternative theories and hypotheses. This has led to the use of more complex designs where well-specified interactions provide much of the discrimination among the alternatives. The power of interactions to eliminate alternative explanations was recognized first in the experimental accounting literature in studies of expertise (see Libby & Luft, 1993, for a review) and much more recently in the archival literature in the focus on “diff in diff” designs based on natural experiments (e.g., Hanlon, Maydew, & Shevlin, 2008). Studies that demonstrate a two-way interaction help to rule out alternative explanations in that, while many alternatives can explain an observed main effect of independent variables, it is much less likely that alternatives can explain the observed interaction. If they can, researchers should more carefully consider whether different manipulation choices would help to rule out any alternatives. Three-way interactions with personality traits where two-way interactions are stronger for individuals who should be more prone to an effect are particularly powerful methods for supporting process explanations (e.g., Seybert, 2010). The big take-away here is that any time you rely on correlations of measures, you are giving up a major part of the experimentalist's comparative advantage. Design (manipulation) just about always trumps measurement. Unfortunately, we are always limited in the number of independent variables that can be manipulated. 4.4.2. Process measures and mediation Papers using experimental methodology increasingly rely on “process measures” to help tell their story. These measures are typically captured on 7-point (or 9- or 11-point) scales, and are then used to test for mediation using the approach popularized by Baron and Kenny (1986) or a related approach. If a process measure “mediates” the relationship between an independent and dependent variable, then researchers often conclude that their 5 See Tversky and Kahneman (1974) and many other papers. underlying story is supported and the process measure explains the observed effects on the dependent variable. We believe that applications of this approach have provided important process insights (e.g., Hodge, Martin, & Pratt, 2006; Koonce & Lipe, 2010). However, future research in accounting should consider the strengths and weaknesses of different versions of mediation analysis to guide its application. Some of the most important pitfalls in many accounting applications relate to the choice of the mediators themselves. Sometimes the “mediators” are simply different ways of eliciting the same dependent variable. In such a case, the mediation analysis is not informative. Also, researchers must always choose whether to include the mediator scales before or after the dependent variable scale, or the order can be manipulated. In the first two cases, specific types of carryover effects are a concern (i.e., the first scale may contaminate the second). When mediator scales are placed before the dependent variable scale, there is a significant risk that they will be reactive and cause participants to respond to the dependent variable scale in a certain way (e.g., the participants may infer that the researcher believes the mediator variables should be weighted heavily in the subsequent decision or choice). This is often called a demand effect. If the dependent variable question is asked first, subsequent responses to the mediator scales may reflect participants' attempts to answer in a fashion consistent with or to justify their choices. When order is varied, often times the tests for order effect interactions have little statistical power, and when they are significant, they are often difficult to explain. Any significant interaction effects with order can result from differences in the carryover effects. Manipulating order is preferred when sample sizes are very large. When they are not, we recommend that when the main focus is on the effects on the decision or choice, then the decision or choice scales should be administered first. When the focus is on the judgments concerning the mediators, they should go first. Finally, many papers ask many more debriefing questions than they report as mediators, raising a cherry-picking problem. Such analyses should be described as exploratory in nature. This leaves us with an important question: What makes a great mediator? Our general answer is that good process measures are (1) as unobtrusive as possible (see Webb, Campbell, Schwartz, & Sechrest, 1966), (2) distinct from the dependent variable, (3) not simply comprehension checks, and (4) at the least are not leading. Some of the best of these have traditionally been thought of as “real” process measures. Examples include time spent, information accessed, and a variety of physiological measures.6 Important examples of creative use of measures in accounting include Rasso (2015), Griffith et al. (2015), and Elliott, Rennekamp, and White (2015). Although not always discussed explicitly as process measures, these papers use unobtrusive measures that are unrelated to the primary dependent variables in order to provide evidence without leading participants to a certain response. For example, Rasso (2015) asks participants to complete an unrelated task developed by Fujita, Trope, Liberman, and Levin-Sagi (2006). In the Fujita et al. (2006) task, participants are given a variety of ideas to consider (e.g., “sweeping the floor”) and asked to choose one of two interpretations to describe it (e.g., “moving a broom”, which represents a low-level construal focused on how the item is done, or “being clean” which represents a high-level construal focused on why the item is done). The combined responses to the different items provide an unobtrusive measure of whether participants are thinking primarily at a high- or low-level of 6 Most of the physiological measures (skin conductance, respiration, heart rate, and neural activity) are not available in accounting studies. Although see Farrell, Goh, and White (2014) for an exception using fMRI. R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 construal. Griffith et al. (2015) ask their auditor participants to make reasonableness assessments of a client's fair value estimate, and then to recommend next steps to take. Auditor participants are then asked to provide open-ended explanations for their responses. These open-ended responses are coded for whether they mention four errors seeded in the case, which serves as an unobtrusive measure of the extent to which auditors employed a deliberative mindset (i.e., identified those seeded errors). Finally, Elliott et al. (2015) demonstrate that concrete disclosures help to reduce investors' feelings of psychological distance, which increases their willingness to invest in a firm. As a supplemental measure of psychological distance, they ask participants to estimate the distance, in miles, between their current location and the target firm that is being evaluated. This unobtrusive measure is captured at the end of the study, and allows Elliott et al. (2015) to show that more concrete disclosures do, in fact, reduce psychological distance (reflected in reduced estimates of geographical distance), without influencing responses on the dependent variables related to investment decisions. Recent papers point out other issues that accounting researchers should consider when using mediation analysis. Zhao, Lynch, and Chen (2010) suggest that “many research projects have been terminated early in a research program or later in the review process because the data did not conform to Baron and Kenny's criteria, impeding theoretical development.” Specifically, Zhao et al. (2010) point out that independent variables may affect dependent variables indirectly via process measures, even in the absence of significant direct effects. This suggests that process measures may be one key to understanding “failed” experiments where no significant differences are observed in dependent variables. Furthermore, this could be especially useful in research on regulations where the initial conclusion is that a given proposal does not have its intended effect. For example, suppose that a given proposal is intended to reduce earnings management by increasing auditors' independence from client management. Further suppose that researchers test the proposal, but find no significant effect on auditors' willingness to correct a material misstatement. Without a significant direct effect to report, the authors may choose to abandon the project, despite the fact that their (lack of) results may not present the complete picture of the proposal's effects. One possibility suggested by Zhao et al. (2010) is that there are multiple indirect effects with opposite signs, and that they are canceling out any observation of a direct effect. Returning to the example, suppose the proposal does increase auditors' feelings of independence, which has a positive indirect effect on willingness to correct the misstatement. At the same time, the proposal may increase auditors' concerns about building rapport and commitment, which could have a negative indirect effect on willingness to correct. Combined, the positive and negative indirect effects may cancel out, leading the researchers to erroneously conclude that there is no effect of the proposal on willingness to correct the misstatement. In contemplating the usefulness of this approach, consider the benefits of the study in the above example to regulators and researchers under two hypothetical outcomes. First, assume the study collects no process measures but does, in fact, show that the proposed regulation directly increases auditors' willingness to correct a misstatement. Regulators now have evidence that implementing the regulation will have a certain directional effect, but they do not know what is driving the improvement, or how altering the regulation might impact its efficacy. Researchers have gained practical knowledge concerning the effects of the regulation, but the theoretical implications and conclusions to be drawn are likely to be limited to the specific regulation involved. Second, assume the study collects the aforementioned process measures 39 but obtains no direct effect. Regulators now know that implementing the regulation may not have the desired effect, but they also know that it has both intended and unintended effects. This enables them to adjust the regulation to combat any potential negative effects. Further, knowledge of the unintended consequences of the regulation should also aid in identifying such problems in future proposed regulations. Insights into the positive and negative impacts of the regulation at a conceptual level should also aid in theory development and the design of future research studies on the effects of regulation. 4.4.3. Non-conscious processes and the comparison of between- vs. within-subjects responses While the above suggests that process measures can certainly be useful (and perhaps in some cases even more useful than researchers or regulators previously realized), we do not believe that they are necessary for telling an interesting and informative story. This is particularly true in cases where effects are driven by nonconscious processes. By definition, participants cannot consciously provide an explanation for their judgments in these cases, and we would not expect typical n-point scale measures to capture these processes. Even in cases where effects are driven by conscious processes, participants' perceptions may not correlate with responses that can be sufficiently captured on an n-point scale. We encourage both researchers and reviewers of accounting research not to become too reliant on process measures, or to place too much emphasis on the importance of demonstrating “successful” process measures. Instead, we suggest that researchers may need to use alternative methods to provide evidence on underlying processes. For example, researchers may use two or more different operationalizations of a construct to provide convergent evidence in different settings. Finding convergent evidence in multiple settings provides more support for the authors' proposed underlying story, and makes it less likely that there is a parsimonious alternative explanation for the observed results. One underutilized method for determining whether an effect is non-conscious in the first place involves the use of a combination between- vs. within-subjects design. Kahneman and Tversky (1996) argue that a between-subjects design allows for a clean test of participants' natural reasoning, whereas a within-subjects design draws attention to the manipulated independent variables and allows participants to correct for any unintentional errors or biases in their responses. Using a combination of a between- and within-subjects design therefore allows for both a clean test of participants' natural reactions to the independent variables, as well as a test of whether those reactions appear to be intentional (Libby et al., 2002). If participants change their original (between-subjects) responses when presented with within-subjects materials, it suggests that their initial reactions were unintentional, or nonconscious. Kang (2014) uses this method to show that, in response to within-subjects questions, audit committee members do not believe that investor sophistication would affect their propensity to ask probing questions about management's significant accounting estimates, despite the fact that investor sophistication does have a significant effect on between-subjects responses. Libby and Brown (2013) also use this method, but their study confirms that betweensubjects responses were intentional. Both the between-subjects and within-subjects results show that presenting disaggregated information on the face of the financial statements increases the perceived materiality of errors in the disaggregated accounts, although both sets of results also demonstrate that there is substantial disagreement among experienced auditors. We encourage researchers to expand their use of the betweenvs. within-subjects comparison design. This type of design may be 40 R. Libby et al. / Accounting, Organizations and Society 47 (2015) 25e42 particularly valuable in studies using experienced managers, auditors, and directors. Given these individuals' strong institutional knowledge, it is especially worthwhile to understand whether their reactions to regulations are intentional or not. Like studies using npoint scales as mediators, such analyses are subject to carryover effects. 4.5. Replication A fundamental tenet of the scientific method is the need for replication of research results. Recent articles in the popular press reiterate the need for replication, while acknowledging that it is often neglected (Lehrer, 2010; Zimmer, 2011). This perhaps comes as no surprise to researchers, who understand that a successful publication outcome often depends on, at the very minimum, finding support for at least some of their hypotheses. Research projects that fail to document significant results are typically modified or abandoned. This could be especially costly when it comes to research on the effects of regulations. If a proposed regulation has no effect on earnings management and accounting choice, then that is important information for regulators to consider before implementing costly requirements. A promising development in accounting research to address this problem is the recent call by Rick Hatfield, Editor of the journal Behavioral Research in Accounting calling for submissions of (1) replications of prior work and (2) studies with non-significant results (BRIA, 2014). The stated goal of this call is “to inform the literature, which is often biased against publishing these types of studies, and to aid researchers working in the field of behavioral accounting.” Replication requires that researchers provide complete documentation of their materials, preferably in the appendices to a paper. We encourage researchers to make this information available and editors to require inclusion of the information in published papers (or online supplements) in order to facilitate replication and vetting of ideas in the accounting literature. 5. Conclusion This paper discusses what we have learned since the review by Libby and Seybert (2009) about how financial reporting, auditing, and corporate governance regulations influence the earnings management and accounting choice decisions of managers, auditors and directors. For managers, our review focuses on how regulations change their ability as well as their incentives to engage in earnings management, with an emphasis on (1) rules- vs. principles-based standards, (2) standards that affect the amount and location of additional information, and (3) standards that affect the frequency and timing of reporting. For auditors and directors, whose primary role is to constrain earnings management, our review distinguishes between regulations that affect their behavior by increasing their independence (from management) and/or accountability (to non-management). Despite the recent uptick in experimental studies of accounting regulation, we also recognize that there is substantial room for future work. Specifically, we argue that future work can do more to examine the interactions of the different parties that are affected by regulatory changes, or the interactions between different regulations on a given party. We also argue that future work can do more to understand both (1) the causal mechanisms underlying the effects of regulatory changes (whether they are primarily economic or psychological in nature) and (2) whether a given effect, or outcome, is actually desirable. For example, much of the research treats increased audit effort as a desirable outcome, without considering whether actual audit quality improves as a result of that effort. Lastly, we encourage researchers to broaden their definition of what constitutes a “regulation” when deciding which research questions to tackle. While changes in formal regulation may be an obvious choice for research, changes in the interpretation or enforcement of existing regulations may be just as important. To help guide future research on the topics that we propose, we also discuss methodological considerations that are likely to impact the effectiveness and efficiency of experimental research. We suggest that researchers who study the effects of regulation should be especially cognizant of issues surrounding realism of stimuli (since proposed standards can change often), the selection of accounting setting (since the setting needs to represent the broad constructs of interest), and the selection of participants (since experienced participants are particularly difficult to obtain). We also make recommendations about different possibilities for examining underlying processes that drive participants' reactions. While process is important to research on regulation, our discussion of process evidence relates more broadly to all experimental research in accounting. Our discussion reflects our belief that experiments and surveys are uniquely suited to investigating the effects of both existing and proposed regulation. For existing regulation, experiments can isolate specific components of a regulation to disentangle the underlying factors that drive accounting choice. 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