Material Weakness in Internal Control and Stock Price Crash Risk: Evidence from SOX Section 404 Disclosure Abstract: This study investigates the hitherto unexplored questions of whether and how the presence of undisclosed internal control weaknesses (ICWs) and their initial disclosure differentially influence the likelihood that extreme negative outliers occur in firm-specific return distributions, which we refer to as stock price crash risk. We predict and find that firms with ICW problems are more crash-prone than firms with effective internal controls. We also find that stock price crash risk is greater for fraud-related ICWs. We provide strong evidence that the positive association between ICWs and crash risk is observed at least two years prior to the initial disclosure of the ICW. More importantly, we find that the positive association gradually decreases over the two-year period following the disclosure and essentially disappears after publicly disclosed ICW problems are remediated. The above results hold after controlling for various firm-specific determinants of crash risk and ICWs. Overall, our results suggest that the presence of undisclosed ICWs tends to exacerbate managers’ bad news hoarding until the ICW problems are disclosed to the public, which increases crash risk. On the other hand, public disclosure of ICWs constrains managerial incentive and ability to withhold bad news from outside investors, thereby mitigating crash risk. Keywords: Internal control weakness, crash risk, Sarbanes-Oxley Act (SOA) JEL Classification Codes: G12, M41, K22 1. Introduction The past two decades have witnessed a series of large-scale corporate debacles and accounting and auditing failures around the world, including the cases of Enron, Tyco and Worldcom. These scandals, which cost investors billions of dollars when the share prices of the affected companies collapsed, dramatically shook public confidence in the stability of capital markets and the reliability of accounting disclosures. In an effort to restore investor confidence, the U.S. Congress passed the Sarbanes-Oxley Act (SOX) in 2002. Section 404 of SOX (hereafter SOX 404) requires a firm’s auditor to attest to the management’s internal control evaluation and report the auditor’s own conclusion regarding internal control effectiveness. 1 This study investigates a hitherto unexplored question of whether and how internal control weaknesses and their disclosure are associated with the likelihood that extreme negative outliers occur in firmspecific return distributions, which we refer to as stock price crash risk. Prior research shows that material weaknesses in internal control over financial reporting—or simply internal control weaknesses (ICWs)—are associated with negative stock returns and higher cost of (both equity and debt) capitals.2 This line of research has typically analyzed the impact of ICWs on ex post realized returns or ex ante implied costs of capital, which is conveniently referred to as the first moment study because its focus is on the effect of ICWs on the first moment of a firm’s return distribution.3 On the other hand, the ICW disclosure 1 In this study, we focus on SOX 404 disclosures because compared to unaudited SOX 302 disclosures, auditorattested SOX 404 disclosures are more reliable indicators of a firm’s financial reporting system quality. 2 See, for example, Hammersley, Meyers and Shakespeare, 2008; Ogneva, Subramanyan, and Raghunandan, 2007; Kim, Song and Zhang, 2011; Costello and Wittenberg-Moerman, 2012; Ashbaugh-Skaife, Collins, Kinney and LaFond, 2009; Beneish, Billings and Hodder, 2008; and Dahliwal, Hogan, Trezevant and Wilkins, 2011. 3 In this study, we classify prior research into the first, second, and third moment studies if it focuses on the effect of accounting regulation such as SOX 404 or IFRS adoption on the mean, variance, and skewness or tail risk, respectively, of firm-specific return distributions. For example, if researchers examine the impact of IFRS adoption (an accounting regulation) on the cost of capital (i.e., the required rate of return and thus the first moment of return 1 requirements under SOX 404 were in response to the abrupt, large-scale decline in stock prices and the associated loss of investor confidence in the quality and reliability of financial reporting. Nevertheless, previous literature has paid little attention to the effect of ICWs on negative tail risk or the likelihood of observing extreme negative outliers in firm-specific return distribution (which is conveniently referred to the third moment effect of ICWs).4 As a result, little is known about whether and how ICWs are associated with the occurrences of extreme negative returns or stock price crashes. To better understand the role of internal control quality in stock price formation process, our study first investigates whether the presence of (not-yet-disclosed) ICWs prior to the initial ICW disclosure is positively associated with stock price crash risk. In so doing, we attempt to isolate the presence effect (the effect associated with the presence of undisclosed ICW problems prior to the initial public disclosure of an ICW) from the disclosure effect (the effect associated with the initial public disclosure of an ICW under SOX 404). Second, we predict that the public disclosure of an ICW is likely to improve firm-level transparency, and thus, mitigate a firm’s crash risk subsequently. To test this prediction, we further examine whether the public disclosure of an ICW under SOX 404 leads to a decreases in stock price crash risk from the pre- to the postICW-disclosure period. Finally, we examine whether and how the remediation of publicly disclosed ICW problems impacts crash risk in the post-ICW-disclosure period. We are motivated to examine the above research questions for the following reasons. First, as noted in SEC (2003), internal control is a much broader concept that encompasses not only the financial reporting process but also the overall information environment of a firm. Kim distribution) and idiosyncratic return volatility or synchronicity (i.e., the second moment of firm-specific return distribution), such research is conveniently referred to as the first and second moment studies, respectively. 4 This third moment effect enables researchers to better capture the accumulated effect of an information-related event such as the initial disclosure of ICWs (Kim and Zhang, 2012). 2 et al. (2011) provide evidence that internal control quality captures the overall quality of a firm’s information production system. 5 Furthermore, Hutton, Marcus and Tehranian (2009, hereafter HMT) document a positive association between information opaqueness (captured by the threeyear moving sum of absolute abnormal accruals) and future crash risk. Given the above evidence, our study examines whether the impact of internal control deficiencies on stock price crash risk goes beyond and above the effect of HMT’s information opaqueness on crash risk. In other words, we are interested in examining whether the lack of internal control quality, as reflected in ICWs, is incrementally important over and beyond the lack of earnings quality in determining crash risk. Second, SOX 404 requires managers of all public firms to assess the effectiveness of internal controls over financial reporting and to provide periodic auditor-attested evaluations of internal control effectiveness. In comparison with SOX 302 disclosures of ICW, Section 404 disclosures is viewed as a more comprehensive, objective, and unambiguous indicator for the quality of a firm’s information production system. 6 Therefore, establishing the link between internal control quality under SOX 404 and stock price crash risk can provide useful insights into whether and how the reliability and quality of a firm’s overall information production system, not a specific attribute per se, are incorporated into stock price formation process, particularly the third moment of firm-specific return distribution. Lastly and more importantly, our research setting allows us to: (i) differentiate the ICW presence effect on crash risk from the ICW disclosure effect; and (ii) evaluate whether and how the initial disclosure of ICWs and its subsequent remediation affect stock price crash risk. Given 5 Kim et al. (2011) provide strong evidence that ICW is significantly associated with a higher cost of private debt, as reflected in unfavorable loan contracting terms (e.g., higher loan spread and more restrictive covenants) even after controlling for financial reporting quality. 6 See Feng, Li and McVay (2009), Kim, Song and Zhang (2011), and Cheng, Dhaliwal and Zhang (2012). 3 that prior research on the economic consequences of ICW disclosures does not explicitly differentiate the presence effect from the disclosure effect, our study allows us to make cleaner inferences on whether the ICW disclosure requirement under SOX 404 accomplishes its intended policy objectives. In short, the results of our investigation provide new insights into the ongoing debate about the costs and benefits of SOX 404 disclosure and compliance. Briefly, our results, using a large sample of firms with auditor-attested ICW disclosures during the post-SOX period of 2004-2011, reveal the following. First, we find that, in the years prior to the initial disclosure of ICW, firms with ICW problems are more prone to experience stock price crashes relative to firms without such problems. Our results are robust to different measures of crash risk and alternative research designs and econometric methods. The above findings support the view that effective internal controls mitigate stock price crash risk, and thus, help to maintain stability in stock markets. Second, we find that firms with more severe fraudrelated ICWs face higher crash risk than those with less severe ICWs. This finding suggests that fraud-related material weaknesses point to more fundamental problems, such as maintaining an ethical culture in the workplace (Kizirian, Mayhew and Sneathen, 2005). Finally, the results of our over-time analyses show that the crash risk of ICW firms declines in the years subsequent to the initial disclosure of ICWs, and virtually disappears after the firms remediate the publicly disclosed ICW. This finding suggests that the ICW disclosure under SOX 404 constrains managers’ ability to hoard bad news, which mitigates firm-specific crash risk and increases stability in equity markets. Our study adds to the existing literature in the following ways. First, this is the first study that examines the third moment effect of ICWs, that is, the effect of ICWs on negative tail risk. Second, to the best of our knowledge, our study is the first that explicitly separates the 4 consequences associated with the presence of undisclosed ICW problems from those associated with the initial disclosure of ICW. Third, our study provides new evidence on the benefits of SOX 404 compliance: the disclosure of ICWs limits management’s bad news hoarding, and thus, improves firm-level transparency, which in turn mitigates future crash risk. Fourth, our research provides strong and reliable evidence that internal control quality is an incrementally significant determinant of stock price crash risk above and beyond earnings quality and other known determinants of crash risk. This finding is particularly relevant given the evidence that investors are increasingly concerned about negative tail risk (Pan, 2002; Yan, 2011). Finally, the results of our study provide an important policy implication to accounting and security market regulators: internal control deficiencies are a significant factor driving stock price crashes, and thus, internal control quality plays an important role in influencing future crash risk and maintaining stability in equity markets. The paper proceeds as follows. Section 2 provides a brief review of prior literature and develops research hypotheses. Section 3 describes the sample, data, and variable measurement. Section 4 discusses our empirical results. Section 5 presents the results of further analyses and robustness checks. The final section concludes. 2. Literature Review and Hypotheses Development Our study is related to two strands of research. One strand examines the relation between financial reporting quality and stock price crash risk; the other strand investigates the determinants and consequences of SOX 404 disclosure. We offer a brief review of prior research in each strand, and then develop our research hypotheses. 2.1 Prior research on firm-specific determinants of stock price crash risk 5 Stock price crash risk at the firm level refers to the likelihood that extreme negative outliers occur in the distribution of firm-specific returns, that is, stock returns after netting out a portion of returns that co-move with common factors (Jin and Myers, 2006; HMT; Kim et al., 2011a; 2011b). The investment community and security regulators have given considerable attention to research on stock price crash risk, since a series of corporate debacles and highprofile accounting scandals occurred in the early 2000s. The recent financial crisis in 2008 has further brought about renewed interest in firm-specific causes for stock price crash risk. Jin and Myers (2006) examine whether the agency conflicts and information asymmetries between corporate insiders and outsiders is related to stock price crash risk.7 Specifically, their model predicts that opaque stocks are more likely to deliver large negative returns. Since then, much effort has been dedicated to empirically test this prediction. Notably, HMT use the threeyear moving sum of absolute abnormal accruals as a proxy for information opaqueness and document a positive association between information opaqueness and stock price crash risk. Their study concludes that financial reporting transparency is crucially important for maintaining stability in stock markets. Similar in spirit to HMT, Kim et al. (2011b) hypothesize that complex tax shelters and tax planning allow managers to manage earnings via restructuring real transactions, which provides a useful means for hiding negative information. Consistent with their hypothesis, they find that corporate tax avoidance is positively associated with stock price crash risk. In another study, Kim et al. (2011a) find that when a firm’s managers—particularly, the chief financial officers (CFOs)—are given option-based compensation contracts, they tend to hide bad news within the firm to maximize their incentive compensation, which in turn engenders relatively 7 Other analytical studies include Bleck and Liu (2006), and Benmelech, Kandel and Veronesi (2010). 6 high crash risk. DeFond et al. (2012) examine whether and how mandatory IFRS adoption by European Union countries affects stock price crash risk. They provide evidence suggesting that mandatory IFRS adoption decreases crash risk for industrial firms by increasing transparency or decreasing information opaqueness, while it increases crash risk for financial firms by magnifying stock return volatility for these firms. In another related study, Kim and Zhang (2012) posit that conservatism curbs managerial incentives to delay the release of bad news, and thus constrains managerial ability to withhold bad news. Consistent with this view, they find that the degree of conditional conservatism is negatively associated with future crash risk. Hamm, Li and Ng (2012) examine how management earnings guidance, an important voluntary disclosure channel, is related to future crash risk. They find that the positive association between opacity in reported earnings and crash risk, as documented in HMT, is stronger when opacity interacts with more frequent earnings guidance. Collectively, this line of research shows that financial reporting quality is negatively associated with stock price crash risk. However, these earlier studies rely, in large part, on researchers’ self-constructed earnings quality proxies and/or focus only on a specific earnings attribute such as accrual quality and accounting conservatism (e.g., HMT; Kim and Zhang, 2012). To our knowledge, no prior research has investigated the impact of internal control quality, an unambiguous and comprehensive measure of a firm’s information production system, on stock price crash risk. 2.2. Prior research on economic determinants and consequences of SOX 404 disclosure Earlier studies on SOX 404 disclosures are of descriptive nature. For example, Doyle, Ge and McVay (2007b), among others, find that firms with weak internal controls tend to be 7 smaller, younger, less profitable, more complex, or undergoing restructuring changes. 8 More recent studies examine the economic consequences of SOX 404 disclosure, particularly, the impact of ICWs on the cost of equity (e.g., Ogneva et al., 2007; Ashbaugh-Skaife et al., 2009), the cost of public debt (Dhaliwal et al., 2011), and the cost of private debt (Kim et al., 2011). Overall, this line of research focuses its attention on the first moment effect of initial ICW disclosures, namely, the effect of initial public disclosures of ICWs under SOX 404 on ex post realized stock return and ex ante expected stock returns or implied costs of capital. The main finding of this research is that initial ICW disclosures have a negative impact on the market, as manifested in higher costs of capital. However, no prior research has investigated the impact of internal control deficiencies on the likelihood of observing extreme negative outliers in firm-specific return distribution. Moreover, prior research on the economic consequences of ICW disclosures under SOX 404 does not explicitly isolate the ICW presence effect (the consequence associated with the presence of undisclosed ICWs) from the ICW disclosure effect (the consequences associated with initial ICW disclosures under SOX 404). As will be further explained below, it is important to separate the ICW presence effect from the ICW disclosure effect, when examining the impact of ICWs on stock price crash risk. 2.3 Hypotheses development 2.3.1. The effect of the presence of undisclosed ICW on crash risk The effectiveness of internal controls is an important factor that determines the quality and reliability of a firm’s information production system. The quality of internal controls can 8 See also Ashbaugh-Skaife, Collins and Kinney, 2007; Ge and McVay, 2005. 8 affect not only the quality of public information disclosed via external financial reports, but also the quality of (undisclosed) private information. For example, Doyle et al. (2007a) find that ICWs are generally associated with poorly estimated accruals that are not realized as cash flows. Feng et al. (2009) find that management forecasts are less accurate among firms with ICW problems. Their results suggest that internal control quality not only influences earnings reports, but also has an economically significant effect on voluntary disclosure that relies on internal management reports (e.g., management earnings guidance). The presence of (undisclosed) ICW problems entails procedural and estimation errors as well as opportunistic earnings management,9 thereby deteriorating corporate transparency. Prior research provides evidence that lack of transparency in financial reports enables managers to opportunistically withhold bad news or unfavorable information (Jin and Myers, 2006; HMT; Kim et al., 2011a; Kim and Zhang, 2012), thereby increasing future crash risk.10 However, there is a limit to the amount of unfavorable information that managers can absorb or successfully hide from outside investors. This is because, once the total amount of hidden negative information reaches a certain threshold, it becomes too costly or impossible to continue to withhold it. When the total amount of the hidden negative information that has accumulated over time reaches a tipping point, it will come out abruptly, leading to a large negative, extreme return on the individual stocks concerned, i.e., a stock price crash (Jin and Myers, 2006; HMT; Kim and Zhang, 2012). One can therefore expect that ceteris paribus, firms with (undisclosed) ICW 9 A material ICW is defined as “[a] deficiency, or a combination of deficiencies, in internal controls over financial reporting such that there is a reasonable possibility that a material misstatement of the registrant’s annual or interim financial statements will not be prevented or detected on a timely basis by the company’s internal controls” (www.sec.gov). 10 Prior research shows that firms with ICWs tend to disseminate less transparent or more opaque financial reports than those with no ICWs. (Doyle, Ge and McVay, 2007a; Ashbaugh-Skaife, Collins and Kinney, 2007; Feng, Li and McVay, 2009). 9 problems are more prone to experience stock price crashes than firms with effective internal controls. Given the scarcity of evidence on the issue, it is interesting and important to test whether the quality and reliability of a firm’s information production system, as reflected in ICWs, go above and beyond HMT’s information opaqueness measure in predicting future crash risk. To provide systematic evidence on this unexplored issue, we test the following hypothesis in alternative form: H1: All else being equal, the presence of material weaknesses in internal control over financial reporting, or simply material internal control weaknesses (ICWs), prior to their initial disclosures is positively associated with the likelihood of stock price crashes. 2.3.2. Does the severity of undisclosed ICW problems matter? Admittedly, however, there are also other reasons why our prediction may not hold empirically. First, prior research suggests that ICWs are attributed primarily to a firm’s complexity and insufficient resources (Doyle, Ge and McVay, 2007b). The disclosure of ICWs simply implies that the firm’s internal controls are not sufficient to prevent or detect potential accounting misstatement. Therefore, ICWs do not necessarily suggest the existence of accounting misstatement. One way to further substantiate our prediction in H1 is to see if the association between ICWs and crash risk is stronger for firms with more severe ICW problems. Specifically, we interpret ICWs related to unethical issues or potential restatements, i.e., fraud-related ICWs, as a signal for an environment in which the probability of managerial rent extraction is at its highest. Prior research suggests that restatements are often linked to aggressive accounting and management culpability (Efendi, Srivastava and Swanson, 2007; DeFond and 10 Jiambalvo, 1994). 11 Skaife, Veenman and Wangerin (2012) also find that managers whom external auditors identified as lacking integrity tend to engage in more profitable insider trading. We expect that fraud-related ICW problems are more fundamental and severe in nature, and thus, are more closely associated with managerial opportunism in financial reporting, such as bad news hoarding. We therefore predict that the association between ICW and crash risk is stronger for fraud-related ICWs than for other types of ICWs. To provide empirical evidence on the above prediction, we test the following hypothesis in alternative form: H2: All else being equal, stock price crash risk prior to the initial disclosure of ICW is positively associated with fraud-related ICWs, to a greater extent, than it is with other non-fraud-related ICWs. 2.3.3. The effect of initial public disclosure of ICW on crash risk In comparison with previous ICW-related research, our study uses the relatively long (post-SOX) sample period of 2004-2011. This, along with our unique research setting, provides us with an opportunity to evaluate the changes in crash risk around the first-time disclosure of ICWs as required by SOX 404. Ex ante, it is not clear how the disclosure of ICWs will impact crash risk. On the one hand, one can expect the disclosure of ICWs to have a negative impact on the market. To the extent that the presence of ICW problems allows corporate insiders to withhold bad news within the company and accumulate the hidden unfavorable information over time, initial public disclosures of ICWs may enable outside investors to evaluate the adverse consequences of hidden unfavorable information. In such a case, the initial ICW disclosure by a firm may cause an increase in crash risk of that firm. 11 For example, Efendi et al. (2007), among others, find that managers’ compensation incentives are associated with restatements. In a similar vein, DeFond et al. (1994) suggest that capital market pressure is one motivating factor leading to restatements. 11 On the other hand, the disclosures of ICWs are expected to cause a dramatic change in a firm’s information environment for the following reasons. First, while the presence of undisclosed ICWs increases future crash risk, public disclosure of ICWs per se can improve corporate transparency almost immediately, and thus mitigate stock price crash risk subsequently. This may occur because upon the initial public disclosures, investors become aware of ICW problems inherent in these firms, and are more likely to exercise a heightened degree of scrutiny over these firms. Second, upon the ICW disclosures, boards of directors may impose additional monitoring mechanisms to discipline managers. Third, facing the adverse consequences from the public disclosures of ICWs,12 managers are likely to have strong incentives to exert greater effort to remediate publicly disclosed ICW problems. For example, managers are likely to become more forthcoming with respect to bad news disclosure. In such cases, the disclosures of ICWs may mitigate stock price crash risk. Given the two opposing predictions above, the directional effect of initial ICW disclosure on stock rice crash risk is an empirical question. To provide systematic evidence on this unexplored question, we test the following hypothesis in alternative form: H3: The initial public disclosure of ICWs and the subsequent remediation of publicly disclosed ICWs lead to a decrease in stock price crash risk, all else being equal. 3. Sample selection and variable measurement 3.1 Data and sample selection 12 These adverse consequences may include lower compensation and higher forced turnover (Johnstone, Li and Rupley, 2010; Wang, 2010). 12 As reported in Panel A of Table 1, the initial sample for this study includes all firm-year observations that are jointly included in the three databases, Compustat, CRSP (Center for Research in Security Prices), and Audit Analytics. This initial sample consists of 34,565 firmyears for our post-SOX sample period of 2004-2011. The sample period begins in 2004 as accelerated filers were required to comply with SOX 404 starting from the fiscal year ending on November 15, 2004. We merge CRSP weekly stock return data with Compustat financial statement data and Audit Analytics SOX 404 audit report data. In so doing, we eliminate 338 firm-years with fewer than 26 weeks of stock-return data. We also drop 2,940 low-priced stocks with their average price for the year less than $2.50. Finally, we eliminate 11,890 firm-years with insufficient financial data to calculate control variables. The final sample consists of 19,397 firm-year observations for the sample period of 2004-2011. Out of 19,397 firm-years in our final sample, 1,397 (7.2%) report ICW problems. In our regression analyses, we create an indicator variable, denoted by MW, that equals one if the firm reports ICW problems in a sample year and zero otherwise. Panel B of Table 1 reports the number of sample firms in each sample year and the percentage of firms with ICW problems in each sample year. As shown in Panel B, we clearly observe a declining pattern in the percentage of firms with ICW disclosures over our sample period. The percentage of ICW disclosures gradually declines from a high of 17.2% in 2004 to 3.0% in 2011. This declining pattern is consistent with the findings of some recent related studies (e.g., Cheffers, Whalen and Thrun, 2010; Kinney and Shepardson, 2011). 3.2 Measuring firm-level crash risk 13 Following prior literature, we employ three measures of crash risk.13 We first estimate the following augmented market model to calculate firm-specific weekly returns for each firm in each year: where is the return on stock in week , and is the return on the CRSP value-weighted market index in week . We include the lead and lag terms for the market index to allow for nonsynchronous trading (Scholes and Williams, 1972). The residual from Eq. (1), i.e., εjt, captures firm-specific weekly return. Since these residuals are highly skewed, we transform them by obtaining a log-transformed form of firm-specific weekly return, Wjt, that is the natural log of one plus the residual return from Eq. (1); Wjt = ln (1+εjt). The first measure of crash risk for each firm in each year, denoted by CRASH, is an indicator variable that equals one for a firm-year that experiences one or more firm-specific weekly returns (i.e., Wjt) falling 3.2 standard deviations below the mean firm-specific weekly returns for that fiscal year, with 3.2 chosen to generate a frequency of 0.1% in the normal distribution. This measure captures the likelihood of observing extreme negative outliers in firmspecific weekly return distribution. The second measure of crash risk is the negative conditional return skewness, denoted by NCSKEW. We calculate NCSKEW by taking the negative of the third moment of daily returns, and dividing it by the standard deviation of daily returns raised to the third power. Therefore, for any stock in year , we obtain: 13 For space limitation, we report results using two measures of crash risk, CRASH and NCSKEW. We conduct robustness analysis using the third measure, DUVOL, but do not tabulate the results. 14 ∑ where ∑ is the number of weakly return observations in the period. Our third measure of crash risk is the down-to-up volatility ratio measure that was first used by Chen, Hong and Stein (2001). For any stock over year , we separate all the weeks with returns below the period mean (“down” weeks) from those with returns above the period mean (“up” weeks), and compute the standard deviation for each of these sub-samples separately. Then, for any stock over year , we calculate DUVOL as follows: ] where and are the number of up and down weeks in the period, respectively. Panel C of Table 1 reports the incidence of stock price crashes, measured by CRASH, for each sample year. As shown in Panel C, on average, 19.8% of firms in our sample experience at least one crash event during a given year. Not surprisingly, crash incidence is the highest in 2008 (the year of U.S. stock market crash) at 22.8%. It is also interesting to observe that the likelihood of observing firm-level stock price crashes is greater during the pre-crisis period of 2004-2007 than during the post-crisis period of 2009-2011. 4. Empirical results 4.1 Descriptive statistics Table 2 presents descriptive statistics on the main variables used in this study, as well as additional variables that are used as controls in our multivariate analysis. Detailed definitions of all variables are provided in Appendix A. The mean value of 15 is 0.198 for the full sample, suggesting that, on average, 19.8% of firm-years experience one or more extreme, negative returns. Here, the mean is higher than that reported by Kim et al. (2011b) and Kim and Zhang (2012).14 It should be noted, however, that our sample period is more recent and covers the financial crisis of 2008. We find that mean crash likelihood is significantly higher for the ICW sample (26.0%) than for the non-ICW sample (19.3%), which is consistent with the prediction in H1. The mean value of is also much larger than that reported by Kim et al. (2011b) and Kim and Zhang (2012), suggesting that firms in our study are, on average, more crash-prone than those in these two studies. We also find that both mean and median of are significantly greater for the ICW sample (0.178) than for the non-ICW sample (0.059), which is again consistent with the prediction in H1. As is the case for CRASH and NCSKEW, we also find that, on average, the down-to-up volatility ratio (DUVOL) is significantly higher for the ICW sample (0.115) than for the non-ICW sample (0.031), which is, anew, in line with the prediction in H1. We find that the mean value of is 7.2%, which is lower than those reported by Feng et al. (2009) and Kim, Song and Zhang (2011). This finding is not surprising, because our sample period covers more recent years up to 2011, and the percentage of firms with ICWs under SOX 404 disclosure has been steadily declining over the recent years.15 With respect to our control variables, we find that firms with ICW problems are smaller, less levered, less profitable, more opaque in financial reporting, less dependent on foreign sales, more likely to incur a loss, have restructuring activities, appoint non-Big 4 auditors, and experience auditor changes, compared with firms without ICW problems. These differences in 14 For example, Kim et al. (2011b) reports an average crash probability of 0.161 based on the sample period from 1995-2008. 15 See Table 1 Panel C for the incidence of ICW by each year. 16 firm characteristics between ICW and non-ICW firms are, in general, consistent with those reported in prior research on cross-sectional determinants of ICWs (e.g., Doyle et al., 2007a). Table 3 presents the correlation matrix for the main variables used in our regression analysis. Our three measures of crash risk, , , and , are all significantly positively correlated with each other, suggesting that they capture the same underlying construct. We find that the correlations between the ICW indicator, i.e., , and the three measures for crash risk are all positive and significant at less than the 1% level. Though only suggestive of the underlying relation, this finding is consistent with the prediction in H1 that the presence of ICW is positively associated with stock price crash risk. It should be noted, however, that it is premature to draw any conclusion from the univariate analysis, because other confounding factors can potentially drive the positive ICW-crash risk association. In the next section we therefore perform multivariate regression analyses to test our hypotheses. 4.2 Are ICWs positively associated with stock price crash risk? 4.2.1 Test of H1 Hypothesis H1 is concerned with whether stock price crash risk is higher for firms with undisclosed ICW problems (i.e., ICW firms) than for firms with no such problem (i.e., non-ICW firms). To test H1, we estimate the following regression of crash risk on the presence of ICW and control variables (firm subscripts are subsumed for brevity): 17 In the above equation, CrashRisk refers to one of our two proxies for stock price crash risk, CRASH and NCSKEW.16 To isolate the presence effect (the effect of the presence of ICW on crash risk) from the disclosure effect (the effect of the initial public disclosure of ICW on crash risk), we take the following approach. As illustrated in Figure 1, suppose that a firm initially discloses its ICW problem in year t, i.e. interval (t, t+1) in Figure 1. For each year t-1, i.e., interval (t-1, t), we construct a treatment sample of ICW firms (MW = 1) and a control sample of non-ICW firms (MW = 0).17 For the purpose of testing H1, crash risk is measured as of year t in which ICW problems have existed but have not been disclosed yet. Note also that, as illustrated in Figure 1, MW and our control variables are measured as of year t-1. Implicit here is the assumption that a firm that discloses its ICW problem in year t should have had the same problem in year t-2, i.e., interval (t-2, t-1), though the problem is not yet disclosed to the public (Doyle et al. 2007a; Schrand and Zachman 2012). The above approach allows us to effectively exclude the disclosure year (year t) from our sample period so that the observed difference in crash risk between the two samples of ICW and non-ICW firms captures the presence effect that is not confounded by the initial disclosure effect. Hypothesis H1 translates into a significantly positive coefficient on MW, i.e., which suggests that crash risk is significantly higher for firms with undisclosed ICW problems than for those without such problems. We control for seven firm-specific crash risk characteristics that are known to determine firm-level crash risk. Chen et al. (2001) predict that stock price crashes are more likely to occur when there are large differences of opinion among investors. Following their study, we control 16 As mentioned earlier, we also use DUVOL as an additional proxy for crash risk. Untabulated results are explained in section 5.6. 17 The construction is based on the initial disclosure between time t and t+1. In our sample, most firms disclose their internal control quality for year t-1 after fiscal year end, i.e., between time t and t+1. 18 for the detrended average monthly trading turnover, denoted by DTURN, which proxies for differences of opinion among investors or investor heterogeneity. In addition, Chen et al. (2001) also document several other variables that predict crash risk. Specifically, they find that firms with high return skewness in the prior year, measured as lagged , are likely to have high return skewness in current year as well. Meanwhile, they also document a positive association between prior stock return volatility, denoted by lagged , and crash risk, and that stocks with high past returns are more crash-prone in current year. Therefore, we control for return ( ) in prior period. Finally, both Chen et al. (2001) and HMT find that crash risk is associated with firm size ( leverage ( ), market to book ratio ( ), return on asset ( ), and ). We therefore include these variables as controls in our regression model. HMT use the three-year moving sum of absolute abnormal accruals, denoted by , to proxy for information opaqueness. They find that and crash risk are positively related. We argue that our measure of internal control quality, namely MW, is a more comprehensive and unambiguous measure of the quality of a firm’s information production system. We therefore include in our regression model for two purposes. First, we would like to validate the effects of information opaqueness on crash risk as documented in HMT and Jin and Myers (2006) using our sample with more recent observations.18 Second, we want to ensure that our test variable, , captures some aspects of financial reporting quality that are incremental over and beyond HMT’s information opaqueness. Previous research has identified firm-specific characteristics that determine the presence of ICW. For example, both Ge et al. (2005) and Doyle et al. (2007a) show that ICW firms are 18 In particular, HMT suggest that the effect of information opaqueness, measured as a three-year moving sum of absolute discretionary accruals, on crash risk has diminished after the passage of SOX. 19 smaller, younger, financially weaker and more complex. To alleviate possible problems of omitted correlated variables and potential endogeneity concerns associated therewith, we include in regression (2) a set of control variables that are associated with ICWs. We control for a firm’s financial performance by including a variable capturing recent losses, , which is defined as the percentage of the most recent three years in which the firm reports a loss. We include a foreign sales indicator ( ( ) and the natural log of one plus the number of business segment ) to control for business complexity. We also include three additional indicator variables representing restructuring activities ( auditor changes during each sample year ( , Big 4 auditors ( and to isolate the effect of these variables from the effect of MW on crash risk. To address potential cross-sectional and serial dependence in the data, we report z/t-statistics (two tailed) that are based on robust standard errors corrected for double (firm and year) clustering (Peterson, 2009; Gow Ormazabal and Taylor, 2010). Throughout the paper, all regressions include year and industry indicators to control for year and industry fixed effects, respectively. Panel A Table 4 reports the results of logistic regressions using CRASH as the dependent variable. The baseline model presents the estimated results for Eq. (2) by excluding a set of ICW determinants. The regression results for the baseline model show that the coefficient on our key variable of interest, 4.84 , is highly significant with an expected positive sign and z-statistic of . To assess the economic significance of our test results, we compute the marginal effect of that captures the change in associated with a change of from 0 to 1, holding all other independent variables at their mean values. The marginal effect of is about 0.05, suggesting that crash risk is higher for ICW firms by about five percentage 20 points, compared with firms with no ICW problems. This is economically significant, given that the average unconditional probability of crash occurrence is 19.8% in our sample. Throughout our study, seven crash risk determinants, which are used as our control variables, are all measured with a one year lag (i.e., measured in one year prior to the year when CRASH is measured) so that current-year return distribution fully reflects the impact of these control variables, if any. With respect to the estimated coefficients on our seven control variables, the following are noteworthy. We find that the coefficients on known determinants of crash risk are broadly in line with the findings of prior research. Crash risk is positively and significantly associated with lagged detrended trading turnover ( firm size ( and lagged market-to-book ratio lagged stock return lagged The coefficient on lagged opaqueness is positive but insignificant. This result, along with a significantly positive coefficient on MW, indicates that the effect of ICW on increasing crash risk is incremental above and beyond prior-period accounting opaqueness. 19 The coefficient on lagged return on assets is both significant with a predicted negative sign. One may argue that our test variable, MW, may suffer from potential endogeneity bias, because MW is, to a large extent, subject to managers’ self selection. In an effort to alleviate potential endogeneity concerns associated with this self-selection bias, we also estimate Eq. (2) by including well-known determinants of ICW as additional controls. As shown in the second section of Panel A, we find that the coefficient on MW remains highly significant with an expected positive sign. This suggests that ICW is incrementally significant in explaining crash risk even after controlling simultaneously for all known determinants of both crash risk and 19 We find that the coefficient of is insignificant when we exclude our main test variable, . One possible reason is that after SOX, the relation between and crash risk has significantly diminished, as documented by HMT. 21 ICWs. We also find that the sign and significance of estimated coefficients on seven crash risk determinants are, overall, similar to those obtained for the base model.20 Interestingly, we find that crash risk is higher for firms with foreign sales (FSALE) and restructuring charges (RESTRUCTURE), while it is lower for firms with more frequent losses (LOSS) 21 and more business segments (SEGMENTS). Panel B of Table 4 reports the results of ordinary least squares (OLS) regressions for Eq. (2), using of as the dependent variable. As shown in Panel B of Table 4, the coefficient is significantly positive in both the baseline model and the augmented model, which strongly supports the prediction in H1. This result is economically significant as well: Taking the baseline model as an example, the coefficient of is 0.126, suggesting that ineffective internal control is associated with an approximate 85% increase (0.126/0.068-1) in . Overall, the results reported in both Panels A and B of Table 4 are similar to each other and generally consistent with the prediction in H1 that the presence of (undisclosed) ICW prior to its initial disclosure increases stock price crash risk. This finding is robust to different measures of crash risk, and holds even after controlling for Chen et al.’s (2001) investor heterogeneity (DTURN), HMT’s information opaqueness (OPAQUE), and other firm-specific determinants of crash risk. Our results hold, irrespective of whether or not we control for firmspecific characteristics that are known to determine ICW. In short, our findings are consistent with the view that effective internal control plays a significant role in limiting managerial incentive, ability, and opportunity to withhold or delay the disclosure of bad news, which in turn 20 One notable difference is that the coefficient on becomes significant in the augmented model. One possible explanation for this finding is that firms that had losses are more likely to have actually disclosed bad news, and hence less prone to experience stock price crashes. 21 22 significantly lowers the likelihood of bad news being stockpiled within a firm, and thus, stock price crash risk. 4.2.2 Test of H2 Hypothesis H2 is concerned with the impact of the severity or seriousness of ICW on crash risk. To test whether (more serious) fraud-related ICWs have a stronger association with crash risk than (less serious) other ICWs, we estimate the following regression in which ICWs are decomposed into fraud-related and other (non-fraud related) ones: In Eq. (3) above, as discussed earlier, CrashRisk refers to either CRASH or NCSKEW. is an indicator variable that differentiates fraud-related ICWs from other ICWs. Fraud-related internal control problems are based on the reason key fields in Audit Analytics that describe the nature of the material weaknesses contributing to ineffective internal control. Specifically, is coded one if Audit Analytics classifies a material weakness as related to “restatement or non-reliance of company filings” (reason key #5) or “ethical or compliance issues with personnel” (reason key #21), and zero otherwise. Similarly, is coded one if a firm has non-fraud related ICWs and zero otherwise. Based on this classification, we identify 573 firm-year observations as having fraud-related weaknesses (2.95%).22 The difference between the coefficients of and captures the incremental crash risk for firms that have been identified by their auditors as not in compliance 22 551 firm-year observations are identified as having problems with “restatement or nonreliance of company filings,” 74 firm-year observations are identified as having problems with “ethical or compliance issues with personnel,” and 52 firm-year observations are identified as having both types of problems. 23 with regulation and standards and having a higher probability of misstatement, relative to firms with other types of internal control problems. Panels A and B of Table 5 present the regression results for Eq. (3), using CRASH and NCSKEW, respectively, as the dependent variable. We find that the coefficients on both MW_fraud and MW_other are positive and highly significant at less than the 1% level, irrespective of whether the base model or the full model is used. More importantly, we also find that the coefficient on MW_fraud is larger in magnitude and more significant than the coefficient on MW_other. As indicated in the bottom part of the table in Panel A, the results of Chi-square tests for the difference in magnitude between the two estimated coefficients indicate that the difference is statistically significant (at about the 5% level in two-tailed tests) for the base model as well as for the full model. This suggests that firms with fraud-related ICWs are more likely to experience extreme negative outliers in their weekly firm-specific return distribution than firms with other types of ICWs. As shown in Panel B of Table 5, when also find that the coefficients on and is used as the dependent variable, we are both significantly positive, and the former is larger in magnitude and more significant than the latter. As shown in the bottom part of the table, the results of an F test for the difference in magnitude between the two coefficients, MW_fraud and MW_other, indicate that the difference is statistically significant at less than the 5% level (at two-tailed tests). Overall the results in Panel B are qualitatively identical with those in Panel A. In short, our results reported in both panels of Table 5 are consistent with H2, suggesting that (a) firms with fraud-related ICWs and those with other types of ICWs are likely to have 24 higher crash risk than firms with no such problems and (b) fraud-related ICW problems are more serious than other ICW problems in terms of their impacts on increasing crash risk. 4.3 Does the disclosure of ICW reduce stock price crash risk? --- Difference-in-differences tests Recall that hypothesis H1 is concerned with cross-sectional differences in crash risk between ICW firms and non-ICW firms prior to the ICW disclosure under SOX 404. This is based on Doyle et al.’s (2007a) conjecture that ICW problems may have actually existed in years prior to the ICW disclosures under SOX 404. 23 In contrast, hypothesis H3 is interested in whether and how the ICW disclosures bring about an over-time change in crash risk from the pre-disclosure period to the post-disclosure period. To test H3, we pool pre-SOX observations in years prior to the initial ICW disclosure and post-SOX observations in years subsequent to the initial ICW disclosure. 24 If ICWs facilitate bad news hoarding by corporate insiders, then the increased crash risk associated with the presence of undisclosed ICW (that existed in years prior to the initial ICW disclosure) should diminish once firms reveal their ICW problems to the public. This is because the ICW disclosure itself improves corporate reporting transparency subsequently and crash risk is inversely associated with transparency (Jin and Myers, 2006). Specifically, one can expect that in the years after ICW firms publicly disclose their ICW problems, there should be no significant difference in crash risk between firms with effective internal controls and firms that report ICWs. Stated another way, ICW firms have now become transparent as they publicly disclosed their ICW problems, and thus, in the post-disclosure period, the difference in crash risk should not be significant 23 In a similar spirit, Schrand and Zachman (2012) report a “slippery slope” to financial misreporting for firms that are subject to AAERs. 24 By doing so, we effectively exclude observations in the initial disclosure years. 25 between firms with public disclosures of their ICW problems and firms with no ICWs (and thus no disclosure of ICWs). Since it is unclear how long it will take ICW firms to remediate their publicly disclosed ICW problems, we construct an expanded sample of 22,421 firm-years that covers two years prior to and two years subsequent to the year of the ICW disclosure under SOX 404. To test H3, we stack the four-year observations together, and then, estimate the following regression model: In the above equation, CrashRisk refers to either CRASH or NCSKEW. is an indicator variable that equals one if the observation is within the 1-year (2-year) period before the year of the adverse internal control opinion under SOX 404 disclosure and zero otherwise. To the extent that publicly disclosed ICW problems existed in years prior to the public disclosure, we expect that the coefficient on to be significantly positive. is an indicator variable that equals to one if the observation is within the 1-year (2-year) period after the ICW disclosure under SOX 404 and zero otherwise.25 Our hypothesis H3 translates into . Panel A of Table 6 reports the results of the logistic regression in Eq. (5) using CRASH as the dependent variable. This regression allows us to assess the temporal variation in stock price crash surrounding the initial public disclosure of ICW. As shown in Panel A, for both baseline and full models, we find that the coefficients on and are both significantly positive. This is consistent with the prediction in H1, suggesting that crash risk is higher for ICW firms 25 For example, is equal to one for fiscal year 2003 if the firm discloses a material weakness for fiscal year 2004. is equal to one for fiscal year 2005 if the initial disclosure of a material weakness occurs in fiscal year 2004. and are defined similarly. 26 than non-ICW firms in up to two years prior to the initial ICW disclosure of an adverse SOX 404 audit opinion. On the other hand, the coefficient on is significantly positive for both models. As shown in the bottom part of Panel A of Table 6, the results of Chi-square test for the difference in magnitude between the two regression coefficients suggests that the difference, , is significantly negative. This is consistent with our hypothesis H3 that stock price crash risk declines significantly from the pre-ICW-disclosure period to the post-ICW-disclosure period, once ICWs are publicly disclosed. Interestingly, the coefficient on is not statistically different from zero, suggesting that crash risk differentials between ICW firms and non-ICW firms disappear, in large part, in the second year following the initial disclosure. In other words, it takes about two years for the crash risk differentials to dissipate in the post-disclosure period. Panel B of Table 6 reports the results of OLS regressions for Eq. (5) using as the dependent variable. The results in Panel B are qualitatively identical to those in Panel A, except that the coefficient on , which is insignificant in Panel A, becomes significant at the 5% level in the full-model specification.26 The F-statistics in the bottom part of Panel B indicates that the decline of crash risk from the PRE1 period to the POST1 period is highly significant. In short, the results in Panels A and B are, overall, consistent with our hypothesis H3 that the disclosure of ICWs leads to a significant decline in stock price crash risk during the postdisclosure period. Stated another way, our results in Table 6 can be interpreted broadly in such a 26 An F-test indicates that the difference between pre and post coefficients, our main variable of interest, is negatively significant. 27 way that the public disclosure of ICW improves corporate reporting transparency, particularly, bad news hoarding, thereby leading to a decline in crash risk in the post-disclosure period. 5. Further Analysis and Robustness Check 5.1 Post-remediation analysis In our main analyses, we provide evidence that the presence of ICW is positively associated with stock price crash risk. We also provide evidence suggesting that upon the initial ICW disclosure, managers of ICW firms tend to exert extra effort to improve internal control quality as manifested in a reduced crash risk in the post-ICW-disclosure period. For completeness of our story, we further analyze whether the difference in crash risk, if any, between ICW and non-ICW firms disappears after firms with adverse internal control opinions under SOX 404 remediate publicly disclosed ICW problems. To address this issue, we estimate the following model: where is an indicator variable that equals one if the observation is within the 1-year (2-year) period after previously disclosed ICW problems are remediated and zero otherwise.27 Once firms with adverse internal control opinions successfully remediate their ICW problems and subsequently receive clean internal control opinions, stock price crash risk for such firms should not differ significantly from crash risk for firms with no ICW problems. In other words, we predict that the coefficient on 27 is insignificant. For example, is equal to one for fiscal year 2006 if the firm discloses a material weakness for fiscal year 2004 and a clean opinion for fiscal year 2005. 28 Under this prediction, no differential crash risk exists between ICW firms and firms that remediate previously disclosed ICW problems. Panels A and B of Table 7 reports the regression results, using CRASH and NCSKEW, respectively, as the dependent variable. In Panel A, we find that the coefficients on and are both insignificant at any conventional level. This is consistent with the view that the remediation of ICW problems constrains managerial opportunism in financial reporting, including bad news hoarding by corporate insiders. As shown in Panel B, the results using as the dependent variable are, overall, qualitatively similar to those in Panel A, except that we find the coefficient on is significant, but becomes insignificant once we extend the post-remediation period up to two years. In short, the results of our postremediation analyses reinforce our main inference that the crash risk differential between ICW and non-ICW firms decreases or largely disappears, once previously disclosed ICW problems are ex post remediated. 5.2 Positive jump risk Our regression results in Table 4 suggest that internal control quality is a significant predictor of negative tail risk or crash risk. An alternative explanation of this finding is that firms with ICW problems operate in volatile environments, and thus, these firms are more prone to experience not only large, abrupt price declines but also large, unexpected price jumps. In such a case, one can expect internal control quality or the lack thereof to be a significant predictor of not only negative crash risks but also positive jump risks. To better understand the role of internal control quality in predicting extreme tail risks, whether negative or positive, we now examine the impact of ICWs on positive jump risk. For this purpose, we define a positive jump risk, denoted 29 by JUMP, symmetrically to a negative crash risk, that is the likelihood that a firm’s weakly return falls 3.2 standard deviation above the mean of firm-specific weekly return distribution, that is, Wit = ln (1 + εit), and then re-estimate Eq. (2), using JUMP as the dependent variable. Table 8 reportsh the results of this logistic regression. As shown in table, we find that the coefficient on MW is negative and marginally significant at the 10% level. This finding does not support the argument that ICWs are associated with volatile environments, suggesting that the observed impact of ICWs on increasing crash risk or negative tail risk (Table 4) is unlikely to be a mere manifestation of the increased volatility associated with ICWs. This is so because, if the increased volatility is the main cause for the increased crash risk, we should also observe a positive association between MW and JUMP or a significantly positive coefficient on MW in Table 8. . 5.3 ICW and Restatement Hammersley et al. (2008) find that ICW disclosures are often accompanied by restatements. To evaluate the possibility that findings are driven by the effect of financial restatements on crash risk, we construct a reduced sample by excluding firms from our sample if ICW problems are preceded by restatements in our sample. We then repeat our regression analyses. Untabulated results show that ICWs remains still positively associated with crash risk suggesting that our reported results are unlikely to be driven by restatements. 5.4 Endogeneity of ICW ICW disclosure under SOX 404 is an exogenous event, and thus, potential endogeneity in the ICW-crash risk relation is of less concern in our study. Nevertheless, we conduct additional analyses to alleviate this endogeneity concern. Specifically, we re-estimate our main regressions 30 using a two-stage least squares (2SLS) approach. We first predict the likelihood of firms having ICWs, using well-known ICW determinants from existing studies, and obtain the predicted values of ICWs. We then re-estimate our main regression results reported in Table 4, using the predicted values of ICWs as our test variable in replacement of ICWs. Untabulated results shows that the results of 2SLS regressions are qualitatively the same as those reported in Table 4, suggesting that our main results reported in Table 4 are unlikely to be driven by potential endogeneity. We also employ a propensity score matching (PSM) procedure to address the endogeneity concern. We use a probit model to estimate propensity scores for the probability of realizing an internal control weakness. The propensity score model includes ICW determinants and year and industry fixed effects. The ICW determinants are the same as the ones used as instruments in the 2SLS model. The MW observations are matched one to one with the non-MW observations with replacement using the estimated propensity scores. Untabulated results show that the regression results using the PSM sample are qualitatively identical with those reported in the paper, suggesting, anew, that our results are robust to potential endogeneity concerns. . 5.5 The Cox hazard model approach Jin and Myers (2006) point out that time can enter investors’ assessment of crash probabilities in the sense that the probability of crash occurrence in current period depends on the occurrence of a crash in the previous period. In a related vein, Kim and Zhang (2012) argue that a proportional hazard approach is more appropriate for the purpose of examining firmspecific determinants of crash risk, because this approach controls for the past history of crashes when predicting future crash likelihood. However, one drawback of this approach is that it 31 necessarily leads to a substantial reduction in sample size, because it requires that a firm be included into the sample only when such a firm experienced at least one crash event during the sample period. Similar to Kim et al. (2012), in an attempt to check the robustness of our main results, we estimate the Cox proportional hazard model as specified below: ( ) is the “hazard” or instantaneous likelihood of crash occurrence, for firm at time , where conditional on crashes having occurred in firm by time ;28 event; and is an unspecified function that captures the baseline hazard. Hypothesis H1 predicts that is the time of the th , which can be interpreted as the extent to which the hazard of crash occurrences increases with the lack of internal control quality given the past crash history. To estimate the hazard model in Eq. (7), we identify a sample of firms with at least one crash event during the sample period. For each crash event of a firm, we calculate the crash interval, which is the length of time (in weeks) from the current crash event to the next. If no further crash event is observed, the interval is the length of time from the current event until the firm’s delisting date or the ending date of the sample period, whichever occurs first. The control variables are the same as in Eq. (2) and year dummies are included. The model is estimated using partial likelihoods developed by Cox (1975). The partial likelihood estimation makes it possible to estimate all coefficients without specifying a particular functional form of 28 The hazard function is defined as follows: where is the number of events that have occurred to firm by time . 32 . Industry-level stratification allows different industries to have different baseline hazard functions, while constraining the coefficients to be the same across industries (Allison, 2005). Table 9 reports the estimated results for the hazard model in Eq. (7). As shown in Table 8, we find that the coefficients on are significantly positive in both models. This is in line with our earlier finding in Table 4, suggesting that the instantaneous crash likelihood of firms with ineffective internal control at time is higher than that of firms with no ICW, even after controlling for past crash history. This lends further support to our main finding that the presence of ICW is positively associated with stock price crash risk. 5.6 Alternative measures of crash risk as the dependent variable 29 and re- As our third proxy for crash risk, we use estimate all the regressions reported in Table 4 through Table 7. Though not tabulated for brevity, the results using this alternative measure of crash risk are qualitatively similar to those reported in the paper. 6. Conclusion We examine whether and how the presence of ICW and its initial disclosure and subsequent remediation are associated with stock price crash risk. Consistent with our prediction, we find that the presence of (undisclosed) ICW is positively associated with crash risk, and this positive association exists up to two years prior to the initial ICW disclosure. Moreover, we find that the impact of ICWs on crash risk gradually declines upon the initial disclosures, and largely disappears after remediation of previously disclosed ICW problems. In addition, we find that firms with fraud-related ICWs are more crash-prone than other ICWs. The above results are 29 See section 3 and Appendix A for an empirical definition of 33 . incrementally significant even after controlling for HTM’s information opaqueness, Chen et al.’s (2001) investor heterogeneity, other firm-specific factors that prior research identified to be associated with stock price crash risk, and firm-specific determinants of ICWs identified by prior research on internal control quality. Our results are robust to the use of alternative proxies for crash risk and different econometric designs. Collectively, our findings support the view that the quality of a firm’s internal controls plays an important role in constraining stock price crash risk and maintaining the stability of stock markets. More importantly, our results highlight the importance of the disclosure of material weaknesses in internal controls over financial reporting: ICW disclosure induces a heightened degree of scrutiny and external monitoring by outside investors, and thus, encourages corporate insiders to be more forthcoming with respect to bad news disclosure. This contributes to lowering stock price crash risk. Our study provides new evidence on the market consequences of ineffective internal controls and the potential benefits associated with SOX 404 disclosure. 34 References Allison, P.D., 2005. Fixed effects regression methods for longitudinal data using SAS. Cary, NC: SAS Institute. 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Main Test Variables: Internal Control Weaknesses An indicator variable that equals to one if the firm reports ineffective internal controls and zero if the firm reports effective internal controls. An indicator variable that equals to one if the internal control weakness is fraud-related and zero otherwise. An indicator variable that equals to one if the firm-year observation is within the 2-year period before the year of the adverse internal control opinion and zero otherwise. An indicator variable that equals to one if the firm-year observation is within the 1-year period before the year of the adverse internal control opinion and zero otherwise. An indicator variable that equals to one if the firm-year observation is within the 1-year period after the initial disclosure of material weakness and zero otherwise. An indicator variable that equals to one if the firm-year observation is within the 2-year period after the initial disclosure of material weakness and zero otherwise. Crash Risk Control Variables Average monthly turnover in fiscal year t minus average monthly turnover in fiscal year t-1. Firm-specific average weekly returns. Standard deviation of firm-specific weekly returns. The natural log of market capitalization. Market to book ratio. Total long-term debts divided by total assets. Income before extraordinary items divided by lagged total assets. The prior three years’ moving sum of the absolute value of discretionary accruals (Hutton et al. 2009). Specifically, where )+ )+ ) is measured using the Modified Jones Model. 38 Internal Control Weakness Control Variables The proportion of loss years in the prior three years. An indicator variable that equals 1 if the firm has foreign sales and 0 otherwise. The natural log of one plus the number of reported business segments. An indicator variable that equals 1 if the restructuring charge is nonzero and 0 otherwise. An indicator variable that equals 1 if the firm is audited by a Big 4 firm and 0 otherwise. An indicator variable that equals 1 if the firm experiences auditor change in the year and 0 otherwise. 39 Figure 1: Timeline for variable measurement for testing H1 and H2 t-2 t-1 t MW and Control variables measured as of time t-1 40 t+1 Crash risk measured as of Auditor-attested report disclosed time t Table 1 Sample selection and summary statistics on stock price crashes Table 1 Panel A presents our sample selection process. Panel B and Panel C report over time pattern of stock price crashes and internal control effectiveness respectively. The sample period is from fiscal years 2004 to 2011. Panel A: Sample selection Initial sample of firm-year observations in the Compustat, CRSP, and Audit Analytics databases from fiscal years 2004-2011 Less: Firm-year observations with less than 26 weeks of stock data Less: Firm-year observations with an average stock price less than $2.50 Less Firm-year observations with insufficient data to calculate control variables Total Panel B: Internal control effectiveness over time 2004 2005 2006 2007 No. of firms 1,825 2,197 2,388 2,682 %firms with ICW 17.2% 12.2% 9.7% 7.8% problems 34,565 (338) (2,940) (11,890) 19,397 2008 2,586 2009 2,506 2010 2,653 2011 2,560 Total 19,397 5.0% 3.0% 3.2% 3.0% 7.2% Panel C: Summary statistics on the likelihood of stock price crashes measured by CRASH Fiscal year Number of firms Number of firms with Percentage of firms with stock price crashes stock price crashes 2004 2005 2006 2007 2008 2009 2010 2011 Total 1,825 2,197 2,388 2,682 2,586 2,506 2,653 2,560 19,397 384 513 522 521 589 412 442 457 3,840 41 21.0% 23.4% 21.9% 19.4% 22.8% 16.4% 16.7% 17.9% 19.8% Table 2 Descriptive statistics Table 2 presents the descriptive statistics for the total sample of 19,397 firm-year observations, as well as the descriptive statistics for the sub-samples partitioned on whether the firm reports and ineffective internal control. Bold text indicates the difference between the mean (median) for firms with ineffective internal control and firms with effective internal control is significant at the 0.05 level or better. Differences in means (medians) are assessed using a t-test (Wilcoxon rank sum test). All variables are defined in Appendix A. Full Sample N=19,397 Mean Median 0.198 0.068 0.037 0.072 0.009 0.050 -0.170 0.052 6.670 2.786 0.176 0.025 0.241 0.245 0.051 1.223 0.312 0.830 0.052 0.000 0.019 0.015 0.000 0.004 0.003 -0.101 0.045 6.555 2.017 0.126 0.045 0.152 0.000 0.000 1.099 0.000 1.000 0.000 Std. dev. 0.398 0.844 0.519 0.258 0.159 0.817 0.260 0.028 1.768 38.456 0.207 0.224 0.454 0.350 0.221 0.715 0.463 0.376 0.222 Non-ICW Sample (MW =0) N=18,009 Mean Median Std. dev. 0.395 0.193 0.000 0.837 0.059 0.013 0.514 0.031 0.009 0.000 0.000 0.000 0.004 0.156 0.008 0.048 0.000 0.813 0.255 -0.166 -0.099 0.028 0.051 0.045 1.776 6.730 6.622 2.781 2.017 39.861 0.207 0.177 0.129 0.221 0.029 0.048 0.462 0.238 0.150 0.345 0.236 0.000 0.218 0.050 0.000 1.223 1.099 0.714 0.462 0.310 0.000 0.369 0.838 1.000 0.211 0.046 0.000 42 ICW Sample (MW = 1) N=1,388 Mean Median Std. dev. 0.439 0.260 0.000 0.926 0.178 0.100 0.568 0.115 0.098 0.000 1.000 1.000 0.003 0.189 0.020 0.076 0.019 0.868 0.312 -0.222 -0.142 0.030 0.060 0.054 1.454 5.891 5.781 2.850 2.017 7.135 0.206 0.155 0.080 0.245 -0.025 0.013 0.330 0.277 0.182 0.380 0.365 0.333 0.250 0.067 0.000 1.233 1.099 0.729 0.474 0.339 0.000 0.445 0.729 1.000 0.325 0.120 0.000 Table 3 Correlation Matrix Table 3 presents the Pearson correlation matrix of selected variables. Bold text indicates statistical significance at the level of 0.05 or better. All variables are defined in Appendix A. 1 0.635 1 0.521 0.891 1 0.043 0.037 0.042 1 0.026 0.041 0.039 0.019 1 0.014 0.025 0.021 0.009 0.001 1 0.005 0.029 0.033 -0.056 -0.232 0.013 1 0.001 -0.026 -0.029 0.085 0.199 0.044 -0.886 1 0.010 0.061 0.053 -0.122 0.024 0.009 0.327 -0.480 1 0.015 0.015 0.012 0.001 0.008 -0.008 -0.003 -0.002 0.015 1 -0.026 -0.021 -0.023 -0.027 0.027 0.002 -0.026 -0.007 0.103 -0.020 1 -0.036 -0.026 -0.019 -0.061 -0.011 -0.012 0.182 -0.217 0.185 0.018 -0.024 1 0.014 0.014 0.009 0.022 -0.001 -0.017 -0.157 0.209 -0.143 0.017 -0.070 -0.093 43 1 Table 4 Internal control quality and stock price crash risk Table 4 Panel A reports the logit regression results with CRASH as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the z-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel A: Logistic Regression Using CRASHt as the Dependent Variable Controlling for ICW Pred. Baseline model determinants Variable Sign Coefficient z-statistics Coefficient z-statistics Test variable + 0.321*** (4.84) 0.312*** (4.49) Crash risk determinants + 0.411** (2.21) 0.381* (1.95) + 0.023 (0.94) 0.004 (0.17) + 0.364** (2.23) 0.510*** (2.63) + 2.872 (1.52) 5.585** (2.31) ? 0.054** (1.98) 0.041 (1.47) + 0.001*** (4.25) 0.001*** (4.65) + -0.008 (-0.09) -0.007 (-0.07) -0.267** (-2.38) -0.325*** (-2.76) + 0.041 (1.39) 0.081** (1.97) ICW determinants -0.332*** (-3.57) 0.110** (2.16) -0.075*** (-3.05) 0.275*** (10.88) -0.002 (-0.04) 0.001 (0.03) Year dummies Included Included Industry dummies Included Included n 19,397 19,352 2 Pseudo R 0.0225 0.0257 44 Table 4 (Continued) Internal control quality and stock price crash risk Table 4 Panel B reports the ordinary least squares (OLS) regression results with NCSKEW as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the t-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel B: OLS Regression Using NCSKEWt as the Dependent Variable Variable Test variable (β1) Pred. Sign Baseline model Coefficient t-statistics Controlling for ICW determinants Coefficient t-statistics 0.126*** (5.99) 0.123*** (5.55) 0.199*** 0.019 0.206** 1.774 0.039*** 0.000 -0.055 -0.096*** 0.030* (3.36) (1.20) (2.44) (1.63) (3.92) (1.38) (-1.34) (-2.89) (1.85) 0.191*** 0.013 0.239** 2.439* 0.036*** 0.000 -0.053 -0.112*** 0.055*** (3.11) (0.83) (2.53) (1.96) (3.65) (1.44) (-1.29) (-3.03) (2.76) -0.095*** 0.040* -0.027*** 0.080*** 0.001 0.018 (-5.33) (1.84) (-3.29) (9.62) (0.05) (0.59) Included Included 19,352 0.0236 + Crash risk determinants + + + + ? + + + ICW determinants Year dummies Industry dummies n Adjusted R2 Included Included 19,397 0.0213 45 Table 5 The impact of the relative seriousness of an ICW on stock price crash risk This table examines the effect of the relative seriousness of the ICW on crash risk. We consider firms with fraud-related weakness as having more severe internal control problems. Panel A reports the logit regression results with CRASH as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the zstatistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel A: Logistic Regression Using CRASHt as the Dependent Variable Controlling for ICW Pred. Baseline model determinants Variable Sign Coefficient z-statistics Coefficient z-statistics Test variable + 0.444*** (4.87) 0.433*** (4.72) (β1) (β2) + 0.229** (2.36) 0.221** (2.28) Crash risk determinants + + + + ? + + + 0.409** 0.024 0.362** 2.897 0.054* 0.001*** -0.010 -0.267** 0.041 (2.19) (0.95) (2.28) (1.54) (1.95) (4.26) (-0.11) (-2.40) (1.41) 0.379* 0.005 0.508*** 5.596** 0.041 0.001*** -0.009 -0.326*** 0.081** (1.94) (0.19) (2.69) (2.33) (1.46) (4.65) (-0.09) (-2.79) (1.97) -0.331*** 0.111** -0.075*** 0.276*** -0.006 0.003 (-3.58) (2.19) (-3.07) (10.76) (-0.09) (0.05) Included Included 19,352 0.0259 2.829 ICW determinants Year dummies Industry dummies n Pseudo R2 Chi-squared (β1= β2) p-value Included Included 19,397 0.0226 2.684 0.101 46 0.0926 Table 5 (Continued) The impact of the relative seriousness of an ICW on stock price crash risk Table 5 Panel B reports the ordinary least squares (OLS) regression results with NCSKEW as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the t-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel B: OLS Regression Using NCSKEWt as the Dependent Variable Pred. Sign Variable Baseline model Coefficient t-statistics Controlling for ICW determinants Coefficient t-statistics 0.186*** (4.02) 0.182*** (3.90) 0.083*** (3.86) 0.081*** (3.85) 0.198*** 0.019 0.207** 1.788 0.038*** 0.000 -0.055 -0.096*** 0.030* (3.33) (1.21) (2.47) (1.64) (3.88) (1.38) (-1.37) (-2.90) (1.85) 0.190*** 0.013 0.240** 2.447** 0.035*** 0.000 -0.053 -0.112*** 0.056*** (3.09) (0.84) (2.56) (1.97) (3.64) (1.44) (-1.32) (-3.04) (2.76) -0.095*** 0.040* -0.027*** 0.080*** -0.000 0.019 (-5.41) (1.86) (-3.30) (9.74) (-0.02) (0.61) Included Included 19,352 0.0238 3.325 Test variable (β1) (β2) + + Crash risk determinants + + + + ? + + + ICW determinants Year dummies Industry dummies n Adjusted R2 F (β1= β2) p-value Included Included 19,397 0.0215 3.242 0.0718 47 0.0682 Table 6 Disclosure of weak internal control and stock price crash risk: over-time analysis This table examines the association between internal control effectiveness and stock price crash risk before and after the disclosure of an ICW, based on an extended sample period including years 2002-2011. Panel A reports the logit regression results with CRASH as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the z-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel A: Logistic Regression Using CRASHt as the Dependent Variable Variable Baseline model Coefficient z-statistics Controlling for ICW determinants Coefficient z-statistics ? 0.373*** (4.99) 0.365*** (4.83) ? 0.470*** (5.94) 0.458*** (5.55) ? 0.211** (2.35) 0.226** (2.30) ? 0.056 (0.70) 0.074 (0.94) + + + + ? + + + 0.258* 0.024 0.554** 4.411* 0.077*** 0.002*** -0.006 -0.277** 0.038 (1.85) (1.06) (2.45) (1.94) (3.14) (3.06) (-0.07) (-2.51) (1.29) 0.232 0.003 0.681*** 7.058** 0.065*** 0.002*** 0.014 -0.338*** 0.078** (1.63) (0.11) (2.60) (2.51) (2.74) (3.29) (0.14) (-2.85) (1.96) -0.366*** 0.085 -0.071*** 0.272*** -0.013 -0.012 (-4.57) (1.57) (-3.81) (10.92) (-0.23) (-0.22) Included Included 21,995 0.0264 Pred. Sign Test variable (β1) (β2) (β3) Crash risk determinants ICW determinants Year dummies Industry dummies n Pseudo R2 Included Included 22,421 0.0231 Chi-squared (β2= β3) 11.73 8.75 p-value 0.001 0.003 48 Table 6 (Continued) Disclosure of weak internal control and stock price crash risk: over time analysis Table 6 Panel B reports the ordinary least squares (OLS) regression results with NCSKEW as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the t-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel B: OLS Regression Using NCSKEWt as the Dependent Variable Baseline model Coefficient t-statistics Controlling for ICW determinants Coefficient t-statistics ? 0.099** (2.20) 0.101** (2.19) ? 0.210*** (10.14) 0.212*** (10.18) (β3) ? 0.130*** (3.77) 0.140*** (3.79) (β4) ? 0.032 (1.52) 0.041** (1.96) + + + + ? + + + 0.093* 0.019 0.235*** 2.220** 0.056*** 0.000*** -0.074* -0.109*** 0.026 (1.89) (1.47) (3.15) (2.33) (5.43) (2.83) (-1.94) (-3.37) (1.64) 0.093* 0.013 0.270*** 3.018*** 0.051*** 0.000*** -0.068* -0.116*** 0.052*** (1.79) (0.96) (3.26) (2.70) (5.69) (3.03) (-1.90) (-3.36) (2.72) -0.118*** 0.018 -0.028*** 0.082*** 0.016 0.007 (-6.21) (0.69) (-4.16) (9.21) (0.66) (0.33) Included Included 21,995 0.0319 3.567 Variable Pred. Sign Test variable (β1) (β2) Crash risk determinants ICW determinants Year dummies Industry dummies n Adjusted R2 F (β2= β3) p-value Included Included 22,421 0.0288 4.66 0.03 49 0.06 Table 7 Weak internal control and stock price crash risk: post-remediation analysis This table examines the association between internal control effectiveness and stock price crash risk after the remediation of an ICW, based on an extended sample period including years 20022011. Panel A reports the logit regression results with CRASH as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the z-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel A: Logistic Regression Using CRASHt as the Dependent Variable Controlling for ICW Pred. Baseline model determinants Variable Sign Coefficient z-statistics Coefficient z-statistics Test variable ? 0.030 (0.42) 0.054 (0.80) (β1) (β2) ? -0.023 + + + + ? + + + 0.335** 0.043** 0.698*** 5.578** 0.081*** 0.002*** 0.043 -0.309*** -0.012 (-0.19) -0.014 (-0.11) Crash risk determinants (2.20) (2.03) (3.04) (2.53) (3.89) (3.13) (0.52) (-3.17) (-0.45) 0.311** 0.024 0.803*** 7.618*** 0.068*** 0.002*** 0.061 -0.367*** -0.002 (2.02) (1.08) (3.06) (2.78) (3.52) (3.27) (0.66) (-3.50) (-0.08) -0.323*** 0.047 -0.056** 0.259*** -0.029 -0.021 (-4.33) (0.71) (-2.21) (9.64) (-0.54) (-0.50) Included Included 27,256 0.0237 ICW determinants Year dummies Industry dummies n Pseudo R2 Included Included 27,927 0.0209 50 Table 7 (Continued) Weak internal control and stock price crash risk: post-remediation analysis Table 7 Panel B reports the ordinary least squares (OLS) regression results with NCSKEW as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the t-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Panel B: OLS Regression Using NCSKEWt as the Dependent Variable Pred. Sign Variable Baseline model Coefficient t-statistics Controlling for ICW determinants Coefficient t-statistics Test variable (β1) ? 0.036* (1.68) 0.047** (2.22) (β2) ? -0.010 (-0.24) -0.005 (-0.12) + + + + ? + + + 0.113** 0.028** 0.292*** 2.986*** 0.064*** 0.000*** -0.062 -0.132*** 0.010 Crash risk determinants (2.34) (2.41) (3.81) (3.31) (6.40) (3.02) (-1.61) (-4.14) (1.36) 0.109** 0.021* 0.324*** 3.717*** 0.059*** 0.000*** -0.058 -0.146*** 0.016 (2.29) (1.79) (3.89) (3.66) (6.63) (3.17) (-1.58) (-3.79) (1.50) -0.119*** 0.017 -0.022*** 0.085*** 0.004 0.003 (-5.53) (0.63) (-2.96) (10.56) (0.19) (0.12) Included Included 27,256 0.0371 ICW determinants Year dummies Industry dummies n Adjusted R2 Included Included 27,927 0.0340 51 Table 8 Internal control quality and jump risk Table 8 reports the logit regression results with JUMP as the dependent variable. Year dummies are based on Compustat fiscal year notation. Industry dummies are based on 2-digit SIC industry classifications from CRSP. The standard errors are clustered by firm and by year and the zstatistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Variable Baseline model Coefficient z-statistics Controlling for ICW determinants Coefficient z-statistics -0.150* (-1.86) -0.155* (-1.83) -0.456*** -0.012 -0.292*** -1.48 -0.125*** -0.001 0.239 -0.058 -0.116*** (-4.46) (-0.46) (-2.72) (-1.25) (-8.93) (-0.74) (1.25) (-0.76) (-2.93) -0.455*** -0.013 -0.285*** -1.35 -0.134*** -0.001 0.233 -0.059 -0.111** (-4.44) (-0.52) (-2.60) (-0.96) (-7.05) (-0.72) (1.23) (-0.76) (-2.52) Test variable Crash risk determinants ICW determinants -0.019 0.205*** 0.041 0.017 0.021 0.062 Year dummies Industry dummies n Pseudo R2 Included Included 19,397 0.0186 52 (-0.29) (-3.36) (0.81) (0.56) (0.38) (0.76) Included Included 19,352 0.019 Table 9 Weak internal control and stock price crash risk: Cox proportional hazards model This table examines the association between internal control effectiveness and stock price crash risk over time using a Cox proportional hazards model. Year dummies are based on Compustat fiscal year notation. The standard errors are clustered by firm and the z-statistic of each coefficient is provided. Significance levels are based on two-tailed tests. ***, **, and * denoted significance at the 1%, 5%, and 10% levels, respectively. All variables are defined in Appendix A. Cox Proportional Hazards Regression Using CRASHt as the Failure Risk Controlling for ICW Pred. Baseline model determinants Variable Sign Coefficient t-statistics Coefficient t-statistics Test variable + (β1) 0.204** (2.18) 0.186** (1.97) Crash risk determinants + + + + ? + + + 0.049 0.086*** -0.020 0.053 0.077*** 0.000 0.042 -0.597*** 0.087*** (0.27) (3.39) (-0.11) (0.02) (4.56) (0.33) (0.35) (-4.42) (5.60) 0.036 0.077*** 0.044 1.275 0.064*** 0.000 0.035 -0.614*** 0.090*** (0.20) (3.03) (0.23) (0.57) (3.34) (0.45) (0.29) (-4.26) (5.95) -0.160* 0.056 -0.031 0.150*** 0.052 0.115 (-1.81) (0.55) (-0.72) (2.88) (0.70) (0.98) Included Industry 10,932 -5687 ICW determinants Year dummies Stratification level n Log pseudolikelihood Included Industry 10,949 -5700 53
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