AUDIT FIRM TENURE, NON-AUDIT SERVICES AND INTERNAL ASSESSMENTS OF AUDIT QUALITY Timothy Bell University of North Florida Monika Causholli University of Kentucky W. Robert Knechel University of Florida April 2012 Draft: Please do not quote without permission. 1 AUDIT FIRM TENURE, NON-AUDIT SERVICES AND INTERNAL ASSESSMENTS OF AUDIT QUALITY Abstract In this study, we use data from internal assessments of audit quality in one of the Big 4 accounting firms to investigate two issues of interest to researchers and regulatory policy: the impact of audit-firm tenure and auditor-provided non-audit services (NAS) on audit quality. We find that first-year audits are more likely to receive a lower assessment of audit quality. Importantly, this result does not extend to years 2 and 3 of the audit engagement, suggesting that the lower audit quality is limited to the first year of engagement. We also find that the audit quality is sustained for very long tenure. In supplemental analysis, we find lowballing for first-year engagements, but lowballing is not associated with less effort from the audit team. Overall, our results do not support regulators’ perspective that long audit firm tenure adversely affects audit quality. On the issue of NAS, we find that fees received from management advisory services and fees from services related to new equity offerings are positively associated with audit quality especially among publicly traded clients. We find that tax services and other NAS are not significantly associated with audit quality. None of our measures of NAS is negatively associated with audit quality. Overall the results provide support for the knowledge spillover argument and that some NAS can improve audit quality. Key Words: auditor tenure, non-audit services, audit quality 2 AUDIT FIRM TENURE, NON-AUDIT SERVICES AND INTERNAL ASSESSMENTS OF AUDIT QUALITY I. Introduction In spite of extensive regulation in the past decade, two issues continue to be of key interest to auditing regulators, practitioners, and academics, namely, the association between audit firm tenure and fees from non-audit services and audit quality. Both of these issues have been subject to extensive research and debate but the results and conclusions have been decidedly mixed (U.S. Senate 1976; AICPA 1978; SEC 1994; GAO 2003; Levitt 2000; EC Green Paper 2010; EC Proposal 2011; PCAOB 2011). Typically, interest in these issues intensifies following economic downturns when business performance decline and business improprieties lead to litigation. Such was the case following the dramatic slide of the NASDAQ market index in early 2000 and the implosion of Enron and Worldcom, precipitating calls for mandatory audit firm rotation and passage of the Sarbanes-Oxley Act of 2002 banning many auditor-provided non-audit services. The financial crisis of 2008 reignited the debate surrounding these issues and regulators worldwide are once again calling for mandatory audit firm rotation and new restrictions on auditor-provided non-audit services (EC Proposal 2011; PCAOB 2011). The first question we examine in this study is the association between audit firm tenure and audit quality. Most prior research suggests that financial reporting quality is lower when auditor tenure is short (see Myers et al. 2003). What is less clear is the cause of this phenomenon. Is a decline in financial reporting quality after an auditor switch due to lowballing and inadequate audit work, economic bonding with a client, or a lack of 3 knowledge on the part of the auditor? Audit firm tenure (i.e., the decision to switch auditors) is endogenous. Conflicts between an auditor and client over financial reporting choices can trigger auditor changes. Consequently, a negative association between reporting quality and short auditor tenure may be attributable to the outgoing auditor, and unrelated to the quality of the new auditor’s own effort.1 This has made regulators somewhat reluctant to rely on academic studies for policy purposes when it comes to setting new policies that relate to audit firm tenure.2 A second potential problem is the absence of reliable measures of audit quality. The most common measures—discretionary accruals and restatements—are jointly determined by management and the auditor, limiting the ability of researchers to isolate the effect of auditors on financial reporting quality. In this paper, we extend the current state of knowledge by examining data from internal quality performance reviews in an international audit firm. The data comes from the observations made by an internal review team comprised of staff with significant auditing expertise. The review team examined selected engagements within the firm and directly assessed the quality of the audit process along multiple dimensions. We use the evaluations made by the review team as our measure of audit quality. Our second research question examines the association between fees received from auditor-provided non-audit services (NAS) and audit quality. For the most part, prior research has failed to find a substantial link between NAS and audit quality (Habib 2009). This may be partly explained by the presence of two potentially opposing effects. On one 1 We use the term audit firm tenure and auditor tenure interchangeably. For example, in its release issued in 2011 the PCAOB noted that “A limitation of this literature is that studies tend to focus on environments where auditor rotation is voluntary rather than mandatory. Voluntary rotation may be associated with auditor issuer disagreements, other financial reporting issues, or economic issues” (see PCAOB 2011, 16). 2 4 hand, NAS could exacerbate economic bonding between the client and auditor, impairing auditor independence and audit quality. On the other hand, the presence of knowledge spillovers could improve audit quality. The problem is compounded because different types of NAS could have different consequences for audit quality (Kinney et al. 2004; Beck et al. 1988; Paterson and Valencia 2011). Further, the lack of reliable measures of audit quality in prior research is also relevant for assessing the effect of NAS on audit quality. In this paper, we extend research on NAS by examining the effect of fees received from NAS on internal assessments of audit quality while separately considering the effect of management advisory services, tax services, services related to a new equity offering, and other NAS. The data we utilize in this study were collected by a large international audit firm during its annual internal quality control reviews performed for a sample of audit clients with 2002 and early-2003 fiscal year ends. These reviews occurred after the enactment of the Sarbanes-Oxley Act of 2002 and the collapse of Arthur Andersen, but prior to the effective date of SOX. During this period, audit firms expected that their audits, especially those audits of newly-acquired Arthur Andersen clients, would receive increased public scrutiny since their quality control processes would be scrutinized by a new regulator, the Public Company Accounting Oversight Board (PCAOB). Our dataset includes direct assessments of overall audit quality for 265 U.S. audit engagements. Our findings can be summarized as follows. On the question of whether audit firm tenure affects audit quality, we find that first year audits have lower audit quality but quality rises to an “average level” in the second year and is sustained for even long tenure 5 engagements. This result is not consistent with some recent findings that suggest a nonlinear association between audit firm tenure and audit quality (see Davis et al. 2009). In supplemental analysis, we also find fee lowballing associated with first-year engagements. More importantly, however, lowballing is not associated with a drop off of auditor effort. To the contrary, the evidence suggests higher levels of audit effort intensity during the first-year. Higher intensity of effort expended in the first year is consistent with the argument that auditors lack client-specific information and spend considerable time learning about a client. Altogether, our findings suggest that tenure improves clientspecific knowledge capital resulting in improved audit quality. With respect to our second research question, we find that of the different types of NAS, fees received from management advisory services and fees from services related to new equity offerings are positively associated with audit quality especially among publicly traded clients. We find that tax services and other NAS are not significantly associated with audit quality. None of our measures of NAS are negatively associated with audit quality. Overall the results provide support for the knowledge spillover argument and that some NAS can improve audit quality. This research contributes directly to recent policy initiatives both in the U.S. and abroad. The PCAOB has recently solicited input regarding the costs and benefits associated with mandatory audit firm rotation. Our findings suggest that rotation can impose significant costs related to the effectiveness of the audit because auditors may lack adequate knowledge about a client during the period immediately after a change in auditors. Our results should be informative to regulators worldwide as they consider new 6 policies related to NAS, e.g., the EU is considering a complete ban on NAS. Our study also addresses recent calls for research to develop more precise proxies of audit quality. As Bamber and Bamber (2009) note “…it is time to move beyond these generic proxies, especially if we want regulators to act on our research…” We are able to overcome this issue by using internal assessments of the overall quality of the audit.3 The remainder of the paper is organized as follows. Section 2 provides a review of the relevant literature reviews and development of hypotheses. Section 3 explains the data and research design. Section 4 analyses the results. Section 5 provides additional tests, while section 6 concludes the paper. II. Background and development of hypotheses Audit quality is traditionally defined as the joint probability of discovering and reporting a material misstatement (DeAngelo 1981). The auditor’s ability to discover a material error, when one exists, depends on the auditor’s technical competence, whereas the willingness to report a discovered error relates to the auditor’s independence, and both these aspects may be affected by tenure. In this paper we examine two circumstances that are believed to influence the quality of an audit: auditor tenure and non-audit services. Auditor tenure and audit quality The question of whether audit firm tenure impacts audit quality has long been one of the major issues concerning auditing regulators. Some believe that lengthy auditor tenure undermines independence and objectivity, while others believe that long tenure 3 The internal quality reviewers include some of the most experienced, best and brightest practicing auditors within the firm giving credence to the reliability of our audit quality metric. 7 increases auditor knowledge and competence. The proponents of mandatory rotation have argued that a lengthy auditor-client relationship can erode professional skepticism and impair auditor objectivity and independence. One argument as to why this might occur is because an economic bond forms when the auditor expects to receive a continuous stream of revenue from the client. A second argument relates to the development of social ties with management that result in a “slow, gradual, almost casual erosion of [an auditor’s] honest disinterestedness” (Mautz and Sharaf 1961, 208). In either case, audit quality may suffer. Regulators have often argued that limiting the number of years that the auditor can serve a client can reduce the amount of audit fees receivable from the client, thus mitigating the potential for economic bonding. In addition, rotation removes any “coziness” between management and their auditor, and instills a fresh view about a client’s financial reporting issues (U.S. Senate 1976; SEC 1994; EC Green Paper 2010; PCAOB 2011; EC Proposal 2011). In the midst of corporate failures in the early 2000s, Congress re-visited the issue but the Senate Banking Committee decided to not include mandatory firm rotation as part of SOX. Instead, Congress charged the General Accounting Office (GAO) to study the potential effects of mandatory rotation. As part of their study, the GAO concluded that “mandatory audit firm rotation may not be the most efficient way to strengthen auditor independence and improve audit quality” (GAO 2003, 8). The GAO also added that “the most prudent course of action at this time is for the Securities and Exchange Commission and the Public Company Accounting Oversight Board to monitor and evaluate the effectiveness of existing requirements for enhancing auditor independence and audit 8 quality” (GAO, 5). Thus, the GAO left the issue open for discussion if SOX did not prove to be effective. During the 2008 financial crisis, the debate surrounding mandatory audit firm rotation was reignited (EC Green Paper 2010; EC Proposal 2011; PCAOB 2011). Opponents of mandatory rotation argue that it will significantly impede the ability to accumulate knowledge about a client which is important for accurately assessing risks and interpreting audit evidence so as to conduct an effective audit. Specifically, auditors develop a rich understanding of a client’s systems, transactions and risks over time through repeated interactions with the client and its personnel. The resulting knowledge is necessary for developing a deep understanding of a client’s business, operations and financial reporting system (PCAOB AS #5, paragraph 9; PricewaterhouseCoopers 2012). The accumulated client-specific knowledge can improve audit quality because it allows auditors to properly plan the audit and identify areas of high risk. In particular, such knowledge can assist the auditor with identifying emerging issues and with connecting “the dots between what might otherwise appear to be isolated issues in different company divisions” (Ernst & Young 2012, 7). Another potential cost of short tenure that would result from mandatory audit firm rotation is the significant burden placed on audit firms and clients related to the tendering process, transition costs for the client, start-up costs for the auditor, and the steep learning curve for all parties involved (Causholli 2012).4 For example, the GAO (2003) reported that incremental costs in the initial year of an audit can be as high as 20 percent of the 4 Other undesired effects arising from mandatory audit firm rotation may include (1) less competition among audit firms, (2) higher internal costs for clients, (3) capacity constrains and scheduling problems among personnel in audit firms. (4) shifting focus and effort towards repeat preparation of proposals for new audit engagements, (5) lower incentives to invest in specialization and developing expertise, and (6) higher audit fees (GAO 2003;PCAOB 2011; Ernst and Young 2012) 9 overall audit cost. A third argument against mandatory rotation is that conflicting economic incentives can also be present during a short tenure audit engagement. That is, to the extent that auditors practice lowballing in order to obtain new clients, their objectivity and independence may be influenced by the desire to retain a client long enough to recover related start-up costs (Dye 1991). Academic research has extensively investigated the relationship between audit firm tenure and various indirect measures audit quality. Early research provided some indirect evidence that short audit firm tenure is associated with lower audit quality. For example, Palmrose (1987, 1991) and Stice (1991) show that auditors face higher litigation risk in the earlier years of an audit relationship. Subsequent research focused on establishing a more direct link between tenure and measures of audit quality. Although the results can be characterized as mixed, the majority find that audit quality improves as tenure increases. Johnson et al. (2002), Myers et al. (2003), Chung and Kallapur (2003), and Gul et al. (2009) find that short tenure audits (defined as tenure of three years or less) have higher and more dispersed accruals and lower earnings persistence. Similarly, Chen et al. (2008) find that the absolute value of discretionary accruals declines as audit firm tenure lengthens in Taiwan. Carcello and Nagy (2004) find that short tenure audits are associated with the likelihood of a company being the focus of an Accounting and Auditing Enforcement Release (AAER). Stanley and DeZoort (2007) find that financial reporting restatements are more likely to occur in short tenure audits. Taken together, these studies raise questions about the potential effectiveness of mandatory audit firm rotation. However, regulators and other academics have correctly pointed out that all of the cited studies are conducted under a regime of voluntary rotation. 10 Consequently, the research may not be a valid basis for drawing conclusions regarding the benefits of mandatory rotation (PCAOB 2011). In order to overcome this criticism, some studies have focused on settings more closely resembling a mandatory rotation environment. Elizur and Falk (1996) use an analytical model to show that when an auditor knows the end of their term, the quality of planning declines over time and is lowest for the last period of a fixed term. Some research has utilized the dissolution of Arthur Andersen, which forced many companies to engage new audit firms, to mimic mandatory rotation. In this setting, Blouin et al. (2007) do not find significant improvements in the quality of reporting for ex-Andersen clients, but Nagy (2005) and Cahan and Zhang (2006) find that the quality of abnormal accruals increased for former Arthur Andersen clients after their forced change to new auditors. These results provide some support for the view that short tenure offers the benefit of a fresh perspective, leading to better audit quality.5 However, in these cases, it is unclear whether the effect is attributable to lengthy audit firm tenure or the unique incentives the new auditor had when dealing with an ex-Andersen client. Other studies have used data from countries where some form of mandatory rotation has been tried. Cameran et al. (2009) examine the effect of mandatory rotation in Italy, where the rotation rule has been in effect for more than 20 years. They find that financial reporting quality improves over time in a mandatory regime. But they also find that forced changes are associated with lower audit quality while voluntary changes of auditors tend to improve audit quality. Using data from Spain, where rotation of audit firms was mandatory between 1988 and 1995, Ruiz-Barbadillo et al. (2003) find that the likelihood of an auditor issuing a going concern opinion is lower during the period of 5 The result in Nagy (2005) is obtained only in the sample of small clients. 11 mandatory rotation. Kwon et al. (2010) examine the effect of mandatory audit firm rotation in South Korea and find that since the implementation of the mandatory regime in 2006, audit quality either did not change or slightly decreased. Taken together, studies using data from these environments do not provide much support for mandatory rotation.6 Prior research findings provide a very mixed picture regarding the association between auditor tenure and audit quality. Importantly, the mixed findings could indicate the dynamics of the trade-off between increased knowledge and decreased skepticism, both of which can occur simultaneously with tenure. Alternatively, the results may reflect problems in the metrics used to proxy for audit quality. Consequently, our first hypothesis regarding auditor tenure is non-directional: H1: Audit firm tenure is associated with the internally assessed quality of the audit process. Non-audit services and audit quality Whether and how NAS impacts audit quality has been an issue of concern to regulators, auditors, investors, and academics for decades. As was the case with auditor tenure, there are two opposing views: Regulators argue that fees from NAS can exacerbate the economic bond between an auditor and client which can be detrimental for audit quality because the auditor is unwilling to challenge a client’s management on questionable accounting choices for fear of losing lucrative NAS fees (U.S. Senate 1976; AICPA 1978; Levitt 2000). It is primarily this perspective that has served as the basis for 6 Vanstraelen (2000) uses data from Belgium where renewable long-term audit mandates exist and reports that auditors are less likely to qualify the opinion when tenure lengthens. Moreover, it is shown that auditors are more likely to issue a clean opinion on the first two years of the mandate than in the last year. These findings are interpreted as supporting mandatory rotation. Knechel and Vanstraelen (2000) also use data from Belgium and do not find evidence that tenure impacts the likelihood of going concern opinions. 12 a regulatory ban included in SOX on auditor-provided NAS, e.g., the failure of Enron is often attributed to the existence of high NAS fees paid to the auditor. Currently, the European Union is also considering a similar ban (EC Proposal 2011).7 In spite of such bans, several theoretical arguments suggest that auditor-provided NAS does not impair audit quality. First, auditor behavior is a function of other market and regulatory-based mechanisms which can serve to discipline an auditor and limit the effects of economic bonding, e.g., litigation and reputation risk (DeAngelo 1981; Palmrose 1988; Weber et al. 2008). Second, auditor-provided NAS may facilitate better audits through knowledge spillovers (Simunic 1984; Beck et al. 1988; Antle and Demski 1991). Specifically, NAS may constitute an important source of information that enriches auditor’s knowledge about the client’s operations beyond the knowledge gained simply through the audit process (Wu 2006). The incremental knowledge gained from NAS enables the auditor to perform the audit more efficiently and effectively. To date, empirical research that has examined the association between auditorprovided NAS and audit quality remains inconclusive. A handful of papers show some evidence that auditor-provided NAS are associated with poor financial reporting quality. For example, Frankel et al. (2002) shows that firms that purchase high levels of NAS from their auditor exhibit low quality financial reporting as measured by larger discretionary accruals and the propensity to meet or beat earnings. Similarly, Srinidhi and Gul (2007) find evidence of a negative association between NAS and the quality of accruals measured 7 SOX prohibits bookkeeping, information systems design and implementation, appraisals or valuation services, actuarial services, internal audits, management and human resources services, broker/dealer and investment banking services, legal or expert services unrelated to audit services. Other non-audit related services (e.g., tax services) are still allowed if approved by the Board. 13 by the extent to which accruals map into cash flows. Using data from Australia, Ye et al. (2011) find that NAS fees are associated with a lower likelihood of issuing a going concern opinion. Geiger and Blay (2011) find that the magnitude of NAS fees is negatively related to the probability that the auditor issues a going concern opinion. The findings of Frankel et al. (2002) are disputed by several follow-up studies. Ashbaugh et al. (2003) find that the results are sample-specific and do not hold under alternative tests. Consistent with Ashbaugh et al. (2003), the overwhelming majority of papers find no evidence linking NAS to audit quality (Simunic 1984; Dopuch and King 1991; Barkess and Simentt 1994; DeFond et al. 2002; Chung and Kallapur 2003; Raghunandan et al. 2003; Geiger and Rama 2003; Reynolds et al. 2004; Larcker and Richardson 2004; DeFond and Francis 2005; Francis 2006; Schneider et al. 2006; Ruddock et al. 2006; Bloomfield and Shackman 2008; Callaghan et al. 2009; Habib 2009).8 Further, other research finds evidence of knowledge spillovers. For example, Antle et al. (2006) use data from the UK and find that knowledge spillovers flow from NAS to auditing. Koh et al. (2011) utilize fee disclosures during the period 1978 to1980 in the US and find that NAS is positively associated with discretionary accruals, the propensity to meet or beat earnings, and earnings response coefficients.9 One limitation of the above cited research stream is that it mostly treats all types of NAS the same. Simunic (1984) points out that different types of NAS may have different 8 Some papers examine the effect of NAS on investor perceptions (Francis and Ke 2006; Koh et al. 2011). Knechel et al. (2012) and Knechel and Sharma (2010) suggest that another benefit of NAS is shortened a audit lag in New Zealand and US respectively. 9 14 implications for audit quality.10 Recent empirical studies have examined the effect of different types of NAS on audit quality, with the majority focusing on the issue of tax services (which are still allowable under SOX). The evidence related to tax services is somewhat mixed. Kinney et al. (2004) find a negative association between fees received for tax services and the likelihood of a restatement implying that tax services improve audit quality. Fees from tax services have been found to be associated with fewer restatements, (Seetharaman et al. 2009), a higher incidence of going concern opinions (Robinson 2008), and reduced earnings management (Krishnan and Visvanathan 2011).11 However, Elder et al. (2008) and Paterson and Valencia (2011) find some evidence that provision of tax services is associated with lower audit quality,12 while Cook and Omer (2012) fail to find an association between tax services and reporting quality.13 A handful of other studies have examined the effect of other types of NAS on audit quality, including information services, internal auditing, and other audit-related services. Kinney et al. (2004) do not find a significant effect of information services on measures of 10 The fact that the Sarbanes-Oxley banned only some, but not all, NAS suggests that different NAS can have a differential effect on audit quality. 11 Gleason and Mills (2011) find that tax services lead to better estimate of tax reserves suggesting benefits to having tax services from the external auditor. 12 Consistent with the prediction in Beck et al. (1988), Paterson and Valencia (2011) find that only nonrecurring tax services are associated with lower audit quality measured by the propensity to issue 13 Another line of research argues that because auditor behavior is a function of economic incentives and other market-based mechanisms it is important to identify settings in which economic incentives dominate or vice versa. Reynolds and Francis (2001) argue that reputational concerns exceed economic dependence among large clients. Reynolds et al. (2004) find that auditors are more likely to yield to economic pressures associated with NAS when auditing small, high-growth clients, suggesting that economic concerns override other incentives in this setting. Larcker and Richardson (2004) find that economic bonding is particularly strong in firms with good corporate governance. Krishnan et al. (2011) find that provision of harmful NAS those banned by SOX – can lead to lower audit quality. Causholli et al. (2012) suggest that independence impairing nature of NAS, is particularly strong under severe compensation pressures that pressured partners to pursue NAS growth prior to SOX. Lim and Tan (2008) find that the effect of NAS on audit quality is conditional on auditor specialization and that auditor specialists have stronger incentives to provide higher quality audits and are more likely to benefit from knowledge spillovers 15 audit quality, whereas Koh et al. (2011) find that information system services are positively associated with audit quality. Using a proprietary dataset, Prawitt et al. (2011) find that outsourcing the internal audit function to the external auditor results in lower accounting risk relative to either in-house internal audit or outsourcing to a professional service firm that is not the external auditor. Kinney et al. (2004) do not find a relationship between internal audit services and audit quality but do find that “other” services are negatively related to audit quality. Paterson and Valencia (2011) find that audit-related services are negatively related to audit quality. The mixed results for different types of NAS lead to our second, non-directional, hypothesis: H2: Different types of non-audit services are differentially associated with internally assessed audit quality. III. Data and research design Data The data used in this study consist of audit quality assessments, audit firm tenure, audit and NAS fees, total and staff-level audit labor hours and other key client and engagement characteristics for 265 U.S. audits conducted by a Big 4 firm during the period 2002 to 2003. Audit firm personnel collected the data as part of their annual internal quality reviews during the period of late spring through early fall of 2003. The data pertain to the most recent annual audits at the time. Consequently, these audits all are for client fiscal years ending before the effective date of the audit provisions of SOX. Firm policy mandates compliance with quality reviews so the response rate was 100%. The firm initially selected 307 audit engagements for internal quality review using a stratified sampling approach that resulted in oversampling of engagements with higher 16 assessed auditor business risk and audit risk (the exact selection criteria is proprietary). Approximately one-third of the original sample (113 out of 307 engagements) consisted of first-year audits where Arthur Andersen LLP had been the predecessor auditor.14 We drop 19 engagements because of missing data and drop another 20 engagements in the government and non-profit sectors. Our analysis is based on the 265 remaining audits engagements. The engagements are from various industries: consumer and industrial products (113), financial services (68), information, communications and entertainment (57), and health care (27). Of the final sample, 120 are first-year engagements (96 of which are former Arthur Andersen engagements) and 145 are continuing engagements. Research Design Audit quality measures For each audit in the sample, a review team under the supervision of the firm’s risk management department assessed the contents of the audit work papers, interviewed audit personnel, and performed reasonableness tests on a variety of data provided by the audit team (including audit labor hours, fees and other entity and engagement characteristics). The members of the review team had not previously worked on the audits of clients they reviewed. During the process, the review team assessed 55 individual audit activities for each engagement. For each activity, the team judged whether audit-team performance was 14 Firm personnel indicate a subsample of about 50% of the 307 audit engagements was selected randomly, i.e., without considering assessments of auditor business risks and audit risks. 17 satisfactory or deficient15 (see Appendix A for the list of the 55 activities and the frequency of deficiencies for each activity and by audit phase). At the conclusion of the review, the team evaluated their findings and made four composite assessments: (a) the sufficiency of evidence obtained to support the audit opinion, (b) the appropriateness of the accounting principles used, (c) the appropriateness and completeness of presentations and disclosures embodied in the financial statement, and (d) the appropriateness of the auditor opinion. The review team also made and documented a final composite assessment of the overall audit quality for the engagement. The following 4-point scale was used for each of these composite assessments: (1) unqualified satisfactory, (2) satisfactory with comments, (3) needs improvement and (4) unsatisfactory. Audit firm quality control policies mandate “a negative response form should be completed and discussed with the reviewing partner in charge” for all engagements receiving assessments other than “unqualified satisfactory” on any of the five composite assessments. Table 1, Panel A, presents the frequency distribution of overall audit quality for the 265 engagements used in this study. As shown, 112 (42%) audit engagements are assessed “unqualified satisfactory,” 133 (50%) are assessed “satisfactory with comments” and 18 (7%) and 2 (1%) are assessed “needs improvement” and “unsatisfactory,” respectively. For our primary tests, we create a dichotomous dummy variable AQ equal to 1 for audit engagements rated “unqualified satisfactory,” and equal to 0 for the remainder of engagements (i.e., the other three categories). As shown in Table 1, Panel A, AQ=1 for 15 Mean (median) hours incurred by review teams during this fieldwork portion of the reviews is 52 (41) hours and the maximum hours incurred is 854.5. Reviews were conducted on a surprise basis for 25 (9%) of the 265 sample engagements. 18 112 (42%) engagements and AQ=0 for the remaining 153 (58%). Panel A also presents the frequency AQ ratings by industry sector. Audits of clients operating in the financial services sector received the highest proportion of “unqualified satisfactory” assessments (AQ=1 for 57 percent), followed by non-financial/non-health care (AQ=1 for 38 percent) and health care (30%).16 Table 1, Panel B, presents the frequency distribution of the total number of deficiencies per engagement (TOTDEFIC) for the 55 assessed individual audit activities. As shown in Panel B, TOTDEFIC ranges between 0 and 12, with 17 percent of the engagements having 0 deficiencies, 28 percent having only 1 deficiency, 33 percent having 2 or 3 deficiencies, and 22 percent having more than 3 deficiencies. Table 1, Panel C, breaks down the distribution of TOTDEFIC into more detail by separating engagements rated as “Unqualified Satisfactory” (RATING=1) from those that are rated “Satisfactory with Comments” (RATING=2) and from those that are assessed as “Needs Improvement” or “Unsatisfactory” (RATING=3). Notably, 94 percent of the engagements with RATING=1 received two or fewer TOTDEFIC, while only 47 percent and 20 percent of the engagements receiving RATING2 and RATING3 had fewer than three TOTDEFIC. Table 1, Panel C, also presents descriptive statistics for the association between TOTDEFIC and RATING and TOTDEFIC and AQ. Tukey tests for differences between TOTDEFIC across pairs of ratings are all significant (i.e., 2 vs. 1, 3 vs. 1 and 3 vs. 2). Also, a t-test for the difference between TOTDEFIC for engagements where AQ=1 vs. The χ2 test for differences between observed and expected frequencies in the 2x3 table is significant at the .01 level. 16 19 AQ=0 indicates that TOTDEFIC is significantly lower for engagements where AQ=1 (unqualified satisfactory). We also create an alternative measure of overall audit quality (AQREV) where we split the “satisfactory with comments” into two groups based on the logic that some of the engagements assessed “satisfactory with comments” may have had only minor issues (e.g., use of terminology by ex-Andersen personnel that differed from the new firm’s customary terminology) and, thus, could be considered engagements of sufficiently high quality to warrant treatment as “unqualified satisfactory.” Since Table 1, Panel C, shows that no engagement receiving a “needs improvement” or “unsatisfactory” assessment (i.e., RATING=3) had fewer than 2 deficiencies , we split the “Satisfactory with Comments” category based on the number of comments received. As shown in Table 1, Panel D, AQREV includes 31 additional observations in the “unqualified satisfactory” because they received fewer than 2 individual audit deficiencies for a total of 143 observations (54%). All remaining engagements (122 or 46%) remain in AQ=0. Measures for tenure and non-audit services Our primary measure for audit firm tenure is a dichotomous variable, FIRST, which indicates first-year engagements for the audit firm. As shown in Panel A of Table 2, first-year engagements comprise 45 percent of the sample.17 Panel A shows the mean (median) level of audit-firm tenure for the full sample of 265 engagements is 6 (2) years 17 As discussed earlier in the paper, the majority of first year clients in our sample are former clients of Arthur Andersen. In some cases, some members of the Arthur Andersen audit team may have followed their clients to the new audit firm, in which case an audit team member’s tenure on the client, but not audit-firm tenure, could be longer than one year. However, it is our understanding that ex-Arthur Andersen personnel were trained in the new firm’s audit methodology. The fact that some first-year clients may not be staffed by new auditors may run against us finding an association between tenure and audit efficiency. Alternatively, it is possible that a greater proportion of qualified assessments were made for this subset of audits because the Andersen auditors were not completely up to speed on the new firm’s audit methodology. 20 and tenure at the 90th percentile is 16 years. Audit-firm tenure exceeds 20 years for 16 engagements. We report tests of alternative measures for audit-firm tenure later in the paper. To test NAS, we split fees paid for non-audit services into five categories: tax services (TAX), management advisory services (MAS), services pertaining to client public securities offerings (OFFER), merger & acquisition activities (MA), and other unspecified fees (OTHER). Descriptive statistics for NAS fees by type of service are shown in Panel B of Table 2. For the full sample of 265 engagements, mean fees billed for TAX services are the largest ($102,618), followed by OTHER ($27,162), OFFER ($24,778), MAS ($21,952) and MA fees ($7,842). Panel B in Table 2 also shows that 67 percent of sample engagements purchase TAX services, 17 percent purchase MAS services, 20 percent purchase OFFER services, 28 percent purchase OTHER services, and only 7 percent purchase MA services.18 In the analyses reported later in the paper, we combine MA fees with OTHER.19 For testing purposes, we scale NAS fees by dividing fees for each type of NAS by the square root of total assets. Specifically, the test variables TAXFEESQRT, MASFEESQRT, OFFRFEESQRT, and OTHFEESQRT are equal to the ratio of TAX, MAS, OFFER, and MA+OTHER fees to the square root of total assets, respectively.20 The Empirical Model 18 Mean fees (n) for subsamples including only those clients purchasing the indicated service type are: Tax=$152,773 (178), MAS=$132,212 (44), OFFER=$126,270 (52), MA=$115,447 (18) and OTHER=$97,270 (74). 19 Our results remain qualitatively equivalent when MA fees are tested separately. 20 Scaling fees by the square root of total assets helps to linearize the relation between fees and size, and to reduce heterogeneity of variance due to size (see Simunic [1980]). 21 We use the following empirical model to test our hypotheses using our primary test variables and a number of control variables:21 AQ/AQREV= a0 + a1(LAST) +a2(PUB) + a3(ROMM) + a4(LEV) + a5(FIRST) + a6(TAXFEESQRT) + a7(MASFEESQRT) + a8(OFFRFEESQRT) + a9(OTHFEESQRT) + u (1) where: AQ = 1 for engagements receiving an “unqualified satisfactory” assessment for overall audit quality; 0 otherwise. AQREV = 1 for engagements for which AQ = 1 plus those engagements that received a “Satisfactory with comments” assessment but had fewer than 2 deficiencies; 0 otherwise. FIRST = 1 for first-year audit engagements; 0 otherwise; TAXFEESQRT = fees received for tax services divided by the square root of total assets. MASFEESQRT = fees received for management consulting services divided by the square root of total assets. OFFRFEESQRT = fees received for services relating to the public security offerings divided by the square root of total assets. OTHFEESQRT = fees received for services relating to merger & acquisition activities and other unspecified NAS services divided by the square root of total assets. LAST = natural log of total assets. LEV = long-term debt divided by total assets. ROMM = 1 if the assessed risk of material misstatement at the overall financial statement level is moderate or high and equals 0 if the assessed risk of material misstatement is low. PUB = 1 if the client has publicly-listed equity securities; 0 otherwise. 21 The following studies use these or similar control variables in tests for associations between tenure, NAS and audit quality: Pratt and Stice 1994; Frankel et al. 2002; DeFond et al. 2002; Ashbaugh et al. 2003; Carcello and Nagy 2004; Nagy 2005; Gul et al. 2007; Carey and Simnett 2006; Lim and Tan 2008; Knechel et al. 2009. 22 In addition to performing tests on the full sample of 265 audit engagements, we perform tests on the subsample of audits including only public-listed clients (i.e., those of greatest interest to audit regulators) and on a subsample excluding audits of clients in the financial services and health care sectors (i.e., those studied most often in prior research). IV. Results Table 3 presents the correlation matrix of variables included in equation (1). AQ and AQREV are positively correlated (by construction) with a correlation coefficient of 0.79 (p<.01). Both AQ and AQREV are highly correlated with TOTDEFIC—the correlations between TOTDEFIC and AQ and AQREV are -0.55 and -0.70, respectively (p<.01). First-year clients exhibit lower audit quality evidenced by the negative and significant correlations between FIRST and AQ, AQREV, and TOTDEFIC (coefficients are -0.15, -0.16 and 0.14, respectively). Pairwise correlations between NAS by servicetype and audit quality are not significant with the exception of OFFRFEESQRT and AQREV (0.14) and OTHFEESQRT and TOTDEFIC (0.13). Correlations among the independent variables indicate no problems with multicollinearity. Tests of Hypothesis H1 Table 4 presents the results of our multivariate tests. In all analyses, we present our multivariate results with and without control variables. Panel A presents the results for the entire sample (265, i.e., both public and private companies), while Panel B presents the results for publicly listed companies only (138). In the discussion that follows, we focus primarily on results for the models that include control variables, i.e., columns 2 and 4 in all panels. In this, and all subsequent analyses, all logit regressions show good fit as 23 evidenced by significant p-values (ranging between 0.0000 and 0.0026) and Naglekerke’s r-squared (ranging between12 percent and 34 percent). The overall results for the control variables are generally consistent with expectations. The association between assets and measures of audit quality is negative and often significant, suggesting that audits of large clients are more likely to receive lower quality ratings. Audit quality is often negatively and significantly associated with leverage (LEV) and risk of material misstatement (ROMM), and only marginally negatively associated with whether the client is public a company (PUB).22 H1 asserts that audit quality will be associated with audit firm tenure. In Panel A the coefficient for FIRST is negative for both AQ (-0.6237, p<.019) and AQREV (-0.6741, p<.009).23 We get similar results for the subsample of public companies in Panel B (AQ: 0.7492, p<.046; AQREV: -0.8481, p<.019). These results indicate that first year audits are more likely to receive a low audit quality assessment than other engagements.24 The evidence is consistent with prior research which shows that short tenures are positively associated with a higher propensity to restate earnings (Stanley and DeZoort 2007), lower propensity to issue going concerns (Geiger and Raghunandan 2002), and lower quality of abnormal accruals (Myers et al. 2003). It is also consistent with the notion that a lack of client-specific information can have negative consequences for audit quality. 22 While we are unable to test the possibility, we speculate that the negative association is due to reviewers being more conservative when judging the audits of large and risky clients. 23 All our tests are two-tailed. 24 We also run a test where we replace FIRST with a dummy variable that indicates an audit in the first 3 years of tenure (i.e., those included in FIRST plus second and third year audits). This variable is consistent with prior research (Johnson et al. 2002). In an untabulated analysis, we find that our short tenure variable is not significant so the primary effect of interest is experienced in the first year of the audit. 24 We repeat our tests of H1 using a subsample that excludes financial and health care enterprises because these are essentially regulated industries. These results are presented in Table 5. Panel A reports the results for both private and public entities, while Panel B reports the results for public companies only. As in Table 4, the results suggest a negative association between first-year clients and audit quality measures. In Panel A, the coefficients on FIRST for AQ (-0.7596, p<.029) and AQREV (-0.8237, p<.012) are both negative and statistically significant. Similar, but weaker, results are found in Panel B for the public companies in the reduced sample for AQ (-0.6969, p<.110), although AQREV is fully consistent with the full sample analysis (-2.1121, p<.035). These results suggest that the link between audit quality and auditor tenure is not influenced by whether clients are in a regulated industry. Additional Analyses As an alternative test, we re-estimate equation (1) with two tenure-related variables: FIRST (as previously defined) and LONG, which takes a value of one for audits with tenure of 9 years or more. This variable is based on prior research (Johnson et al. 2002; Carcello and Nagy 2004). The results (untabulated) indicate that the coefficient on FIRST remains significant and negative, suggesting that relative to medium tenured audits, firstyear audits are of lower audit quality. However, the coefficient on the dummy indicating long tenure (LONG) is not significant, suggesting that audit quality remains relatively constant even over long tenures. This result indicates that the primary quality effect occurs in the first year of an audit. 25 A follow up question then arises as to the cause of lower quality in first-year audits. Regulators are particularly concerned with this question because an auditor that obtains a client via a lowball fee may have incentives to reduce the effort level for such audits. To explore this issue in more detail, we examine the association between FIRST and audit fees and auditor effort. We use a fee model similar to Bell et al. (2008) which includes the usual controls for client and engagement specific variables (Hay et al. 2006) and a dummy for first-year audits. Our general results (untabulated) are similar to those presented in Bell et al (2008) and other prior research. The coefficient on FIRST is negative and significant consistent with the presence of lowballing in first-year audits. We next examine whether first-year audits are characterized by differences in the intensity of audit effort. We use four metrics to proxy for audit intensity based on the number of hours expended by each level of personnel rank—partners, in-charges, managers, and staff—each divided by total assets. We then use a model similar to Bell et al. (2008) with appropriate client and engagement-specific control variables, where the dependent variable is each measure of audit intensity. We include a dummy for first-year clients. Our results suggest that audit intensity is significantly higher for first-year audits using all four measures of audit intensity. This result suggests that although first-year audits are associated with lowballing of fees, this does not negatively affect audit effort since such audits involve more time by staff, in-charges, managers and partners. That is, auditors seem willing to do significantly more work in the first year of an engagement in spite of a relatively low audit fee. This result is also consistent with the presence of a significant learning curve reported by Causholli (2012). 26 Tests of Hypothesis H2 The results for H2 are also reported in Tables 4 and 5. H2 asserts that audit quality will be associated with different types of auditor-provided non-audit services. For the full sample (Panel A), we find no evidence that any of the 4 types of NAS are associated with audit quality, either negatively or positively, based on AQ. However, for AQREV, we find that OFFRFEESQRT is positively associated with audit quality (0.1917, p<.023). The results are quite different when we only consider publicly listed companies (panel B). Here we find that MASFEESQRT is positively associated with audit quality whether we use AQ (0.9603, p<.015) or AQREV (1.061, p<.042). We find a marginal positive relationship between AQREV and OFFRFEESQRT in Panel B (0.1593, p<.083). TAXFEESQRT and OTHFEESQRT are not significant in any of our analyses. More importantly, we do not find any evidence of a negative relationship between the various types of NAS and audit quality. The results for the sample excluding financial and health care clients are slightly stronger and also fail to reveal any negative effects on audit quality from any NAS (see Table 5). In the subsample, MASFEESQRT is found to be positive for the combined private/public sample (Panel A) for both AQ (0.4540, p<.016) and AQREV (0.6088, p<.021), although the results in Panel B are mixed with AQ remaining positive (1.252, p<.036) but AQREV losing its significance (1.6758, p<.111). Taken together, the results for MASFEESQRT suggest that there are knowledge spillovers to the audit (see also Kinney et al. 2004 and Koh et al. 2011). In sum, none of the results are consistent with the argument that NAS should be uniformly banned for all audit clients. 27 V. Summary and Concluding Remarks In this study we use data from internal assessments of audit quality in one of the Big 4 accounting firms to investigate two issues of interest to research and regulatory policy: the impact of audit firm tenure and auditor-provided NAS on audit quality. We find that first-year audits are more likely to receive a lower assessment of audit quality, suggesting that short tenure can negatively impact audit quality. Importantly, this result does not extend to years 2 and 3 of the audit engagement, suggesting that the lower audit quality is limited to the first year of engagement. Additional analyses also reveal that the improvement in audit quality continues even for audits with long tenure. Thus, our results do not support the regulators’ perspective that a long tenure adversely affects audit quality. In an attempt to understand the reasons that might cause audit quality to be lower in the first year, we examine whether lowballing and audit labor intensity is different in first-year engagements. The analyses reveal the presence of lowballing associated with first-year engagements, however lowballing does not seem to cause auditors to work less. To the contrary, the evidence suggests higher levels of audit effort intensity during the first-year, where audit intensity is measured as the total audit hours expended by various staff levels divided by total assets. Higher intensity of effort expended in the first year is consistent with the argument that auditors lack client-specific information and spend considerable time learning. Altogether, our findings do not provide support for mandatory rotation but instead suggest that tenure improves client-specific knowledge capital resulting in improved audit quality. 28 On the issue of NAS we find that different NAS types can have a different impact on audit quality. Specifically, fees received from management advisory services and fees from services related to new offerings are positively associated with audit quality especially among publicly traded clients. We find that tax services and other NAS are not significantly associated with audit quality. None of our measures of NAS is negatively associated with audit quality. Our study extends current research and may help to inform regulatory policy going forward. Because our measures of audit quality focus strictly on the quality of the audit process, as a separate activity within the financial reporting process, we are able to circumvent two of the usual problems associated with prior research: endogenous auditor tenure and proxies that impound management decisions about financial reporting. In addition, on the research stream investigating the effects of audit firm tenure, our study provides a more complete set of results that show not only the nature of the association between audit firm tenure and audit quality, but also the potential causes for this association as evidenced by our analysis of lowballing and audit labor intensity. Finally, our study suggests that regulators should consider the potential and unique effect of each NAS type on audit quality when developing policies regarding NAS restrictions. Our study has limitations. First, the data come from only one of the big accounting firms. To the extent the processes are unique to this firm, the results may not generalize to other settings. Second, the data are from a time period characterized by an increased awareness and scrutiny in the audit process. This may affect the rigor of internal audit quality assessments and produce evaluations that are more stringent than those produced 29 during normal periods. However, the setting we use more closely resembles the current regulatory environments in which audit firms are periodically evaluated by the PCAOB inspectors. 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Auditing: A Journal of Practice and Theory 30 (1): 121-148. 38 TABLE 1 AUDIT QUALITY MEASURES Panel A: Composite Review-Team Assessments for Overall Audit Quality Assessment Unqualified Satisfactory Satisfactory with comments Needs Improvement Unsatisfactory 1 N 112 133 18 2 265 Percent 42% 50% 7% 1% Dichotomous Measure of Overall Audit Quality (AQ) Engagements receiving “Unqualified 112 Satisfactory” Assessment 0 Financial Services Health Care Non-Financial/NonHealth Care Total Engagements receiving other than “Unqualified Satisfactory” Assessment AQ = 1 39 (57%) 8 (30%) 65 AQ = 0 29 (43%) 19 (70%) (38%) 105 112 153 (62%) 153 42% 58% Total 68 27 170 265 Panel B: Frequency Distribution of Total Deficiencies (TOTDEFIC) Per Engagement # of TOTDEFIC engagements 0 44 1 75 2 53 3 34 4 22 5 18 6 8 7 2 8 4 9 3 11 1 12 1 percent 16.6% 28.3% 20.0% 12.8% 8.3% 6.8% 3.0% 0.8% 1.5% 1.1% 0.4% 0.4% 39 Panel C: Descriptive Statistics for Individual Assessed Deficiencies(2) By RATING RATING(1) N 1 2 Unqualified Satisfactory Satisfactory with Comments 3 Needs Improvement & Unsatisfactory 112 133 20 Cumulative Distribution of Engagements By RATING 42 2 0 (37.5%) (1.5%) (0.0%) Total Sample 44 (16.6%) 1 88 (78.6 %) 31 (23.3%) 0 (0.0%) 119 (44.9%) Δ TOTDEFIC Means for: Signed p-value 2 105 (93.8%) 63 (47.4%) 4 (20.0%) 172 (64.9%) +.0000 *** 3 109 (97.3%) 91 (68.4%) 6 (30.0%) 206 (77.7%) RATING 2 minus 1 RATING 3 minus 1 4 111 (99.1%) 107 (80.5%) 10 (50.0%) 228 (86.0%) 5 112 (100%) 122 (91.7%) 12 (60.0%) 246 (92.8%) 6 112 (100%) 128 (96.2%) 14 (70.0%) 254 (95.8%) 7 112 (100%) 128 (96.2%) 16 (80.0%) 256 (96.6%) 8 112 (100%) 131 (98.3%) 17 (85.0%) 260 (98.1%) AQ=1 AQ=0 9 112 (100%) 133 (100%) 18 (90.0%) 263 (99.2%) .94 3.3 11 112 (100%) 133 (100%) 19 (95.0%) 264 (99.6%) t-Statistic = 11.8 p-value = .0000*** 12 112 (100%) 133 (100%) 20 (100.0%) 265 (100.0%) TOTDEFIC Means (Standard Errors) .94 (.1564) 2.96 (.1435) 5.30 (.3701) 2.10 (.1290) TOTDEFIC 0 Tukey Tests for Differences in Means +.0000 *** RATING 3 +.0000 minus 2 *** ANOVA Model F-Statistic = 81.5, 2 df p-value = .0000*** t-test for Difference in Mean TOTDEFIC By AQ Two audit engagements coded RATING=3 received the “Unsatisfactory” composite rating for Overall Audit Quality. See APPENDIX A for abbreviated definitions of individual audit activities and frequencies of engagements with assessed deficiencies by audit phase. (1) (2) 40 Panel D: Revised Measure of Overall Audit Quality (AQREV) for Sensitivity Tests AQREV = 1 Engagements receiving “Unqualified Satisfactory” RATING=1 plus the subset of engagements receiving “Satisfactory with Comments” RATING=2 that also had less than 2 assessed individual deficiencies 143 54% 0 Engagements receiving “Needs Improvement” or “Unsatisfactory” RATINGs=3 or 4 plus the subset of engagements receiving “Satisfactory with Comments” RATING=2 that also had 2 or more assessed individual deficiencies 122 46% Financial firms Health care firms Non-financial/nonhealth care firms Total AQREV = 1 43 (63%) 12 (44%) 88 143 (52%) AQREV = 0 25 (37%) 15 (56%) 82 (48%) 122 Total 68 27 170 265 *** denotes significance at .01 level Variables: RATING = 1 if review-team assessment for overall audit quality is “Unqualified Satisfactory,” 2 if review-team assessment is “Satisfactory with Comments” and 3 if assessment is “Needs Improvement. or Unsatisfactory.” AQ = 1 if review-team assessment for overall audit quality is “Unqualified Satisfactory,” 0 otherwise. TOTDEFIC = total number of assessed deficiencies documented by review teams for 55 individual audit activities. AQREV =1 for engagements with RATING=1 plus the subset of engagements with RATING=2 that also had less than 2 TOTDEFIC; 0 otherwise. 41 TABLE 2 AUDIT ENGAGEMENT CHARACTERISTICS Panel A: Client variables Assets ($thousands) LEV ROA Tenure PUB ROMM FIRST Mean Median Std Dev P10 P90 2,880,402 0.64 -0.048 5.89 0.52 0.52 0.45 261,038 0.60 0.016 2 1 1 0 16,600,000 0.503 0.676 8.743 0.50 0.50 0.50 37,809 0.16 -0.20 1 0 0 0 3,267,000 0.96 0.117 16 1 1 1 Standard Deviation 563,021 74,129 198,527 74,348 42,816 79,517 0.37 0.47 0.40 0.25 0.45 P10 69,000 0 0 0 0 0 0 0 0 0 0 P90 647,000 83,000 293,000 80,000 0 84,000 1 1 1 0 1 Panel B: Audit and non-audit fee variables Audit fees ($) MAS fees ($) TAX fees ($) OFFER fees ($) M&A fees ($) Other fees ($) MAS dummy TAX dummy OFFER dummy MA dummy OTHER dummy Mean 361,862 21,952 102,618 24,778 7,842 27,162 0.17 0.67 0.20 0.07 0.28 Median 210,000 0 25,000 0 0 0 0 1 0 0 0 This table presents the descriptive statistics related to 265 audit engagements performed by an international accounting firm prior to the effective date of the audit provisions of the Sarbanes-Oxley Act of 2002. The variables are defined as follows: LEV is the ratio of long-term debt to total assets; ROA is the ratio of net income to total assets; Tenure is the number of years for which a firm has been a client of the audit firm; PUB equals one for publicly traded companies, 0 otherwise; ROMM equals 1 if the risk of material misstatement as assessed by the auditor is high, zero otherwise; FIRST equals 1 for first-year engagements, 0 otherwise; FS equals 1 if the client is in the financial service industry; MAS equals 1 if the auditor performs management consulting services, 0 otherwise; TAX equals 1 if the auditor performs tax services, 0 otherwise; OFFER equals 1 if the auditor provides services related to securities offerings, 0 otherwise; MA equals 1 if the auditor provides services related to client M&A activity, 0 otherwise; OTHER equals 1 if the auditor provides other non-audit services that are not specified, 0 otherwise; Total NAS equals 1 if the auditor provides MAS, OFFER, MA, or OTHER, 0 otherwise; Total NAS + TAX equals 1 if the auditor provides MAS, OFFER, MA, OTHER or TAX, 0 otherwise. 42 TABLE 3 Correlation Matrix AQ AQREV TOTDEFIC FIRST TAXFEESQRT MASFEESQRT AQ AQREV TOTDEFIC FIRST TAXFEESQRT MASFEESQRT OFFRFEESQRT OTHFEESQRT LAST PUB ROMM LEV 1 0.79** -0.55** -0.15* -0.05 -0.02 0.10 -0.06 -0.12* -0.10 -0.06 -0.16** 1 -0.70** -0.16** -0.07 -0.05 0.14* -0.07 -0.07 -0.08 -0.04 -0.11 1 0.14* 0.10 -0.04 -0.03 0.13* 0.07 0.13* -0.04 0.02 1 -0.04 -0.03 -0.14* 0.01 -0.09 0.07 -0.02 0.03 1 0.00 0.00 0.06 -0.04 0.09 -0.04 0.04 1 -0.03 -0.06 -0.04 -0.09 0.02 0.21** 1 0.07 -0.08 0.16** -0.04 -0.08 1 -0.02 0.15** 0.03 0.02 1 0.11 -0.07 -0.02 1 -0.02 -0.16** 1 0.10 OFFRFEESQRT OTHFEESQRT LAST PUB ROMM 1 LEV AQ = 1 for engagements receiving an “unqualified satisfactory” assessment for overall audit quality, 0 otherwise; AQREV = 1 for engagements for which AQ = 1 plus those engagements that received a “Satisfactory with comments” assessment but had fewer than 2 deficiencies, 0 otherwise; FIRST = 1 for first-year audit engagements, 0 otherwise; TAXFEESQRT = fees received for tax services divided by the square root of total assets; MASFEESQRT = fees received for management consulting services divided by the square root of total assets; OFFRFEESQRT = fees received for services relating to the public security offerings divided by the square root of total assets; OTHFEESQRT = fees received for services relating to merger & acquisition activities and other unspecified NAS services divided by the square root of total assets; LAST = natural log of total assets; LEV = long-term debt divided by total assets; ROMM = 1 if the assessed risk of material misstatement at the overall financial statement level is moderate or high and equals 0 if the assessed risk of material misstatement is low; PUB = 1 if the client has publicly-listed equity securities, 0 otherwise. 43 TABLE 4 Logit Analysis Panel A: NAS fees, audit firm tenure, and audit quality on full sample of 265 engagements Dependent Variables Independent Variables Constant FIRST TAXFEESQRT MASFEESQRT OFFRFEESQRT OTHFEESQRT AQ = 1, 0 AQ1 N = 112, AQ0 N = 153 (1) (2) Coeff. p-value Coeff. p-value 0.0309 0.879 3.8899 0.010 -0.5720 0.026 -0.6237 0.019 -0.0158 0.428 -0.0137 0.509 -0.0099 0.745 -0.0023 0.942 0.0328 0.205 0.0337 0.256 -0.0450 0.296 -0.0302 0.483 Controls LAST PUB ROMM LEV - Model Fit Model χ2 p-value McFadden's Rho2 Cox and Snell R2 Naglekerke's R2 9.9646 0.0762 0.0276 0.0369 0.0496 - -0.1503 -0.4559 -0.235 -1.0199 0.046 0.085 0.369 0.009 25.3694 0.0026 0.0703 0.0913 0.1227 AQREV = 1, 0 AQREV1 N = 143 AQREV0 N = 122 (3) (4) Coeff. p-value Coeff. p-value 0.5119 0.016 2.945 0.044 -0.5685 0.028 -0.6741 0.009 -0.0245 0.215 -0.0229 0.252 -0.0250 0.431 -0.0208 0.515 0.1597 0.037 0.1917 0.023 -0.0647 0.136 -0.0553 0.201 - 19.9879 0.0013 0.0547 0.0727 0.0971 44 - -0.0954 -0.3466 -0.1823 -0.5119 27.5879 0.0011 0.0754 0.0989 0.1321 0.185 0.181 0.475 0.098 TABLE 4 continued Panel B: NAS fees and audit quality on subsample of 138 public companies Dependent Variables Independent Variables Constant FIRST TAXFEESQRT MASFEESQRT OFFRFEESQRT OTHFEESQRT Controls LAST ROMM LEV Model Fit Model χ2 p-value McFadden's Rho2 Cox and Snell R2 Naglekerke's R2 AQ = 1, 0 AQ1 N = 52, AQ0 N = 86 (1) (2) Coeff. p-value Coeff. p-value -0.6890 0.05 4.2578 0.049 -0.3316 0.398 -0.7492 0.046 0.0106 0.729 -0.0016 0.961 0.8109 0.021 0.9603 0.015 0.0384 0.136 0.0268 0.330 -0.0358 0.540 -0.0359 0.541 - 23.5567 0.0003 0.1288 0.1569 0.2137 - -0.1868 -0.7722 -0.6377 0.089 0.043 0.325 32.8578 0.0001 0.1797 0.2119 0.2886 AQREV = 1, 0 AQREV1 N = 69 AQREV0 N = 69 (3) (4) Coeff. p-value Coeff. p-value -0.1989 0.565 4.6265 0.027 -0.3802 0.318 -0.8481 0.019 0.0152 0.615 0.0026 0.933 0.8932 0.054 1.061 0.042 0.1542 0.064 0.1593 0.083 -0.0632 0.275 -0.0658 0.260 - 26.4897 0.0001 0.1385 0.1747 0.2329 - -0.1803 -0.5602 -0.6369 0.084 0.128 0.312 33.8195 0.0000 0.1768 0.2173 0.2898 AQ = 1 for engagements receiving an “unqualified satisfactory” assessment for overall audit quality, 0 otherwise; AQREV = 1 for engagements for which AQ = 1 plus those engagements that received a “Satisfactory with comments” assessment but had fewer than 2 deficiencies, 0 otherwise; FIRST = 1 for first-year audit engagements, 0 otherwise; TAXFEESQRT = fees received for tax services divided 45 by the square root of total assets; MASFEESQRT = fees received for management consulting services divided by the square root of total assets; OFFRFEESQRT = fees received for services relating to the public security offerings divided by the square root of total assets; OTHFEESQRT = fees received for services relating to merger & acquisition activities and other unspecified NAS services divided by the square root of total assets; LAST = natural log of total assets; LEV = long-term debt divided by total assets; ROMM = 1 if the assessed risk of material misstatement at the overall financial statement level is moderate or high and equals 0 if the assessed risk of material misstatement is low; PUB = 1 if the client has publicly-listed equity securities, 0 otherwise. 46 TABLE 5 Logit Analysis using subsample of non-financial and non-health care firms Panel A: NAS fees, tenure, and audit quality on subsample of 170 audit engagements in three industry sectors Dependent Variables Independent Variables Constant FIRST TAXFEESQRT MASFEESQRT OFFRFEESQRT OTHFEESQRT Controls LAST PUB ROMM LEV Model Fit Model χ2 p-value McFadden's Rho2 Cox and Snell R2 Naglekerke's R2 AQ = 1, 0 AQ1 N = 65, AQ0 N = 105 (1) (2) Coeff. p-value Coeff. p-value -0.2287 0.412 8.9054 0.000 -0.7202 0.031 -0.7596 0.029 -0.0099 0.686 -0.0150 0.588 0.251 0.094 0.4540 0.016 0.0292 0.236 0.0205 0.442 0.0044 0.933 0.0595 0.306 - 12.6238 0.0272 0.0558 0.0716 0.0973 - -0.4187 -0.4674 0.0709 -1.2122 0.001 0.227 0.843 0.044 38.1512 0.0000 0.1687 0.2010 0.2733 47 AQREV = 1, 0 AQREV1 N = 88 AQREV0 N = 82 (3) (4) Coeff. p-value Coeff. p-value 0.4743 0.102 4.9524 0.012 -0.8751 0.009 -0.8237 0.012 -0.0376 0.134 -0.0416 0.128 0.4495 0.051 0.6088 0.021 0.1624 0.089 0.1971 0.077 -0.0150 0.779 0.0328 0.571 - - - - 24.6403 0.0002 0.1046 0.1349 0.1800 -0.1828 -0.5409 0.2493 -1.1606 38.3306 0.0000 0.1628 0.2019 0.2693 0.068 0.147 0.462 0.044 TABLE 5 continued Panel B: NAS fees, tenure, and audit quality on subsample of 106 public companies in three industry sectors Dependent Variables Independent Variables Constant FIRST TAXFEESQRT MASFEESQRT OFFRFEESQRT OTHFEESQRT Controls LAST ROMM LEV Model Fit Model χ2 p-value McFadden's Rho2 Cox and Snell R2 Naglekerke's R2 AQ = 1, 0 AQ1 N = 37, AQ0 N = 69 (1) (2) Coeff. p-value Coeff. p-value -0.7636 0.073 6.5906 0.015 -0.4470 0.335 -0.6969 0.110 0.0112 0.736 -0.0034 0.925 0.8672 0.049 1.252 0.036 0.0374 0.148 0.0216 0.411 -0.0130 0.836 0.0127 0.850 - 17.9610 0.0030 0.1310 0.1559 0.2148 - -0.3202 -0.2861 -0.9892 0.023 0.529 0.228 29.6322 0.0002 0.2161 0.2439 0.3360 AQREV = 1, 0 AQREV1 N = 51 AQREV0 N = 55 (3) (4) Coeff. p-value Coeff. p-value -0.0999 0.813 4.3151 0.074 -0.6300 0.158 -2.1121 0.035 -0.0032 0.922 -0.0226 0.515 1.3000 0.124 1.6758 0.111 0.1688 0.086 0.1789 0.125 -0.0244 0.687 0.0115 0.870 - 23.5731 0.0003 0.1606 0.1994 0.2660 - -1.2664 -0.3225 -1.883 0.295 0.747 0.060 31.643 0.0001 0.2156 0.2581 0.3443 AQ = 1 for engagements receiving an “unqualified satisfactory” assessment for overall audit quality, 0 otherwise; AQREV = 1 for engagements for which AQ = 1 plus those engagements that received a “Satisfactory with comments” assessment but had fewer than 2 deficiencies, 0 otherwise; FIRST = 1 for first-year audit engagements, 0 otherwise; TAXFEESQRT = fees received for tax services divided 48 by the square root of total assets; MASFEESQRT = fees received for management consulting services divided by the square root of total assets; OFFRFEESQRT = fees received for services relating to the public security offerings divided by the square root of total assets; OTHFEESQRT = fees received for services relating to merger & acquisition activities and other unspecified NAS services divided by the square root of total assets; LAST = natural log of total assets; LEV = long-term debt divided by total assets; ROMM = 1 if the assessed risk of material misstatement at the overall financial statement level is moderate or high and equals 0 if the assessed risk of material misstatement is low; PUB = 1 if the client has publicly-listed equity securities, 0 otherwise. 49 APPENDIX A Definitions of Assessed Audit Activities and Frequencies of Engagements With Assessed Deficiencies By Composite Ratings and Audit Phase Appendix A presents abbreviated definitions (left-hand column) for each of the 55 individual audit activities for which deficiencies were documented by the firm’s internal quality control review teams. Individual audit activities were grouped by four audit phases in the review documentation: (1) planning, (2) internal control evaluation and control risk assessment, (3) substantive testing, and (4) audit wrap-up activities. For each individual audit activity the review team assessed whether audit team performance was deficient or not (i.e., a dichotomous rating). For example, for the Analytical Procedures-Precision activity within the substantive testing phase, review teams assessed the following activity: Did the engagement team perform planned analytical procedures at a sufficient level of precision, and investigate and obtain explanations and corroborative evidence for any variances from expectations outside an acceptable difference? Yes or No? Upon completion of these (and possibly other undocumented) assessments of individual audit activities, review teams formed composite assessments for, among other things, “overall audit quality.” The actual question addressed and rated by reviewers for the composite assessment is: “What is your overall evaluation of the quality of this engagement?” Reviewers assigned one of the following four assessments to each engagement reviewed: “Unqualified Satisfactory,” “Satisfactory with Comments,” “Performance Improvement Necessary,” and “Unsatisfactory.” No “Unsatisfactory” ratings were assigned to the sampled engagements for “quality of overall audit evidence.” Panels A through D below present frequencies of individual deficiencies (i.e., frequencies of “No” answers to the respective questions for each individual audit activity) for the total sample of 265 audit engagements and broken down by each assessment category for the overall audit quality composite rating. Individual audit activities are grouped in separate panels within the appendix based on the respective audit phase. Frequencies of total deficiencies per engagement are presented at the bottom of each panel. 50 APPENDIX A (continued) Definitions of Assessed Audit Activities and Frequencies of Engagements With Assessed Deficiencies By Composite Ratings and Audit Phase Panel A: Audit Planning Activities Abbreviated Definitions of Individual Audit Activities Business Understanding Analytical Procedures Fraud Risk Assessment Business Risks & Processes Client Information Technology Integration-Tech. Specialists Other Locations-Coordination Oth. Locations-Documentation Proper Audit Plan Audit Plan Consistency w Risk Evaluation of Internal Audit Work of Another Auditor Client’s Service Organizations Client’s External Experts Total N Assessment of Overall Audit Quality Needs Satisfactory Improvement Unqualified with or Satisfactory Comments Unsatisfactory 112 133 20 2 4 7 1 1 3 1 1 3 3 7 1 6 12 5 2 2 2 2 3 2 2 1 2 1 6 2 14 4 20 63 19 Total Sample 265 2 12 4 5 11 23 2 4 5 2 3 2 9 18 102 # Assessed Deficiencies Per Engagement 181 (68%) 68 (26%) 14 (5%) 2 (1%) 0 1 2 3 92 (82%) 20 (18%) 0 (0%) 0 (0%) # of Engagements (Percent) 83 6 (62%) (30%) 38 10 (29%) (50%) 11 3 (8%) (15%) 1 1 (1%) (5%) Panel B: Internal Control Evaluation and Control Risk Assessment Activities Abbreviated Definitions of Individual Audit Activities Cycle Approach – Proper Understanding of Processes Risk Assmt. & Control Eval. Audit Programs Controls Testing Total N Total Sample 265 6 5 5 22 21 59 Assessment of Overall Audit Quality Needs Satisfactory Improvement Unqualified with or Satisfactory Comments Unsatisfactory 112 133 20 5 1 1 3 1 2 3 3 15 4 5 15 1 11 41 7 215 (81%) 42 (16%) 7 (3%) 1 (0%) # of Engagements ( Percent) 45 (75%) 13 (22%) 2 (3%) 0 (0%) # Assessed Deficiencies Per Engagement 0 1 2 3 161 (85%) 26 (14%) 2 (1%) 1 (0%) 51 9 (60%) 3 (20%) 3 (20%) 0 (0%) APPENDIX A (continued) Definitions of Assessed Audit Activities and Frequencies of Engagements With Assessed Deficiencies By Composite Ratings and Audit Phase Panel C: Substantive Testing Activities Abbreviated Definitions of Individual Audit Activities Analytical Procedures-Precision Tests of Details Inventory Observation Receivables Confirmations Head-Office Consultations Revenue Recognition Client’s Tax Accounting Review by Tax Specialist Consolidations/ Equity Method Business Combinations Stock Options/Warrants/Rights Equity Transactions New Accounting Standards Valuation & Asset Impairment Derivative Instruments Other Significant Estimates Total N Total Sample 265 32 23 7 15 7 14 62 10 12 9 10 1 6 32 6 22 268 Assessment of Overall Audit Quality Needs Satisfactory Improvement Unqualified with or Satisfactory Comments Unsatisfactory 112 133 20 4 22 6 8 11 4 6 1 3 11 1 2 4 1 3 8 3 13 39 10 2 7 1 10 2 1 4 4 1 8 1 1 1 4 1 4 24 4 1 4 1 3 13 6 46 176 46 113 (43%) 85 (32%) 36 (14%) 19 (7%) 7 (3%) 4 (2%) 1 (0%) # of Engagements (Percent) 35 (26%) 47 (35%) 30 (23%) 17 (13%) 2 (2%) 2 (2%) 0 (0%) # Assessed Deficiencies Per Engagement 0 1 2 3 4 5 6 73 (65%) 34 (30%) 4 (4%) 0 (0%) 1 (1%) 0 (0%) 0 (0%) 52 5 (25%) 4 (20%) 2 (10%) 2 (10%) 4 (20%) 2 (10%) 1 (5%) APPENDIX A (continued) Definitions of Assessed Audit Activities and Frequencies of Engagements With Assessed Deficiencies By Composite Ratings and Audit Phase Panel D: Wrap-Up Activities Abbreviated Definitions of Individual Audit Activities Laws & Regulations Sworn Statements by Officers Management Certifications Letter of Audit Inquiry Mgmt. Representation Letter Related Party Transactions Subsequent Events Debt Covenant Violations Going Concern Evaluation Final Analytical Procedures F/S Consistency w Other Info Presentation & Disclosure Passed Audit Differences Work Paper Documentation Audit Checklists Other Required Workpapers Partner & Manager Reviews Required In-Depth Reviews Other Review Policies Auditor’s Report Total N Total Sample 265 1 1 13 14 12 7 16 6 9 24 3 17 15 14 2 5 5 3 1 8 176 Assessment of Overall Audit Quality Needs Satisfactory Improvement Unqualified with or Satisfactory Comments Unsatisfactory 190 60 15 112 133 20 1 1 6 6 1 1 12 1 1 10 1 1 3 3 2 9 5 1 2 3 2 5 2 4 14 6 1 1 1 3 13 1 2 13 6 8 2 1 4 1 3 1 1 1 1 1 28 114 34 # Assessed Deficiencies Per Engagement 0 1 2 3 4 5 6 149 (56%) 79 (30%) 24 (9%) 6 (2%) 5 (2%) 1 (1%) 1 (0%) 89 (79%) 19 (17%) 3 (3%) 1 (1%) 0 (0%) 0 (0%) 0 (0%) 53 # of Engagements (Percent) 56 4 (42%) (20%) 52 8 (39%) (40%) 17 4 (13%) (20%) 4 1 (3%) (5%) 4 1 (3%) (5%) 0 1 (0%) (5%) 0 1 (0%) (5%)