Auditors’ Role in China: The Joint Effects of Incentive and Regulatory Sanction on Earnings Management Attempts Ning Du Associate Professor School of Accountancy and Management Information Systems DePaul University One East Jackson Boulevard, Chicago, Il 60604 Phone: 312-362-8308 Email: [email protected] Joshua Ronen Professor Stern School of Business New York University 44 West 4th St. New York, NY 10012 Phone: 212-998-4144 Email: [email protected] Jianfang Ye Associate Professor Institute of Accounting and Finance Shanghai University of Finance and Economics No. 777 Guoding Road, Shanghai, P.R.China 200433 Phone: 86-21-65903253 Email: [email protected] 1 Auditors’ Role in China: The Joint Effects of Incentive and Regulatory Sanction on Earnings Management Attempts In this study we strive to gain insights into auditors’ behaviors in the unique setting of China. Specifically, we focus on the role of Chinese auditors in detecting and preventing earnings management. We conduct a 2X2 between-subject randomized experiment with 174 Chinese auditors evaluating a short case where managers have incentive to classify financial assets for earnings management. We manipulate two conditions, 1) managers’ incentives for earnings management attempts (EMA) by varying prior operating performance, and 2) the severity of regulatory sanctions/penalties. Our results show that auditors are aware of the use of investment transactions for earnings management; however, they believe managers’ choices are ethical when there is a high need for earnings management. In addition, we find harsh penalty/sanction to be effective in improving performance, especially when earnings management incentive is high, but the use of harsh penalty/sanction can be a double-edged saw, in that, when managers have low earnings management incentives, harsh penalty/sanction may undermine auditors’ ability to correct earnings management attempts. 2 I. Introduction Since the latter part of 2010 investors have lost billions of dollars as stocks of many Chinese companies have plunged. The string of accounting scandals at many publicly traded Chinese companies has sparked deep concerns about the quality of financial reporting of Chinese firms. Recently the PCAOB and the SEC have sought to investigate some of the audit firms involved with US listed Chinese companies, but their efforts have been stymied by Chinese authorities. These tensions reached a climax when Deloitte's Chinese arm refused to turn over documents tied to a U.S.-listed client under SEC investigation, citing prohibition by the Chinese government. In September 2012, after trying for years to gain access to China, the PCAOB finally reached a tentative agreement to observe official auditor inspections in China. The agreement permits the observers to watch Chinese officials' examination of audit firms' quality controls, but do not allow detailed reviews of specific audits. The concerns about audit quality of Chinese companies are further fueled by a recent rule by the Chinese government to assert more control over Chinese affiliates of major accounting firms. The new rule limits the percentage of foreign-qualified partners and requires the Big Four accounting firms to appoint Chinese citizens to head their mainland operations. The shift to domestic auditors highlights the importance of understanding whether or not Chinese auditors are able to maintain independence in the financial reporting process. Similar to managers in other countries, managers of Chinese companies have strong incentives to manage earnings. In China, listed companies have to meet the target profitability level at the time of an IPO or to avoid being delisted (Jian and Wong 2010). In a recent study, He et al. (2012) find that Chinese managers “cherry pick” their investment portfolio and are more likely to sell AFS securities for a gain to avoid reporting financial losses. However, limited 3 understanding exists about Chinese auditors’ role in detecting and preventing opportunistic management behaviors and curtailing aggressive financial accounting practices. China has been trying to harmonize its audit standards with the international standards and to regulate the behavior of auditors. Prior research evidence (e.g. DeFond et al. 2000) indicates that auditors can and do provide high-quality audits in China, especially after regulations intended to increase auditor independence. However, enforcing those regulations have been problematic in China. The new Chinese Accounting Standards (CAS) adopted in 2007 are substantially in line with IFRS and cover most of the topics therein, but the Chinese market is unique in many aspects: it has high ownership concentration with a strong government influence, a weak legal system, a negligible market control mechanism, the prevalence of related-party transactions, and an inefficient managerial labor market (Firth et.al., 2006). For example, investigating the frequency of modified audit report, DeFond et al. (2000) find that in fear of receiving modified report, Chinese managers would prefer smaller, less independent auditors, and avoid larger, more independent ones. The demand for lower, rather than higher, audit quality suggests a compromise of auditor independence in China. Prior studies identified various economic and institutional factors, but few have examined the psychological factor that may have contributed to the pattern of Chinese auditors’ behavior. In China, the conduct of business is often based on personal relationships (the guanxi code of conduct). This relationship, more than just economic dependence, is personal and psychological. With the strong psychological bond between auditors and manages, it might be impossible maintain independence in mind. In addition, the expectation for auditors is different in China. Chinese firm managers, counting on this relationship, often expect auditors to help them increase profit, conceal frauds (illegal spending, tax evasion) or cover weaknesses of their businesses 4 (Yang 1995, Xiao et al. 2000). Thus, Chinese auditors may be vulnerable to management pressure and likely to succumb to managers’ demand for earning management. In China, auditors operate in a less litigious environment that also lacks traditional corporate governance mechanisms (Gul et al. 2010). Despite its increase in recent years, litigation against managers and auditors fails to protect investors. Instead, Chinese authorities often rely on regulatory sanctions, such as warnings, fines, or withdrawal of license or certificates to regulate the auditing industry (Yang et al. 2001). In a recent study, Keune and Johnstone (2012) find that auditors’ incentives to protect their reputations weaken the effect of managerial incentives for earnings managements. As regulatory sanctions damage auditors’ reputation, penalty/sanction may serve as a mechanism to improve auditor independence and substitute for a litigious environment to encourage high quality auditing. In this study we strive to gain insights into auditors’ behaviors in the unique setting of China. Specifically, we focus on the role of Chinese auditors in detecting and preventing earnings management. We propose that due to the unique culture in China, Chinese auditors may not perceive earnings management, especially, those related to accounting transactions, as unethical. This belief may undermine auditors’ willingness to correct earnings management. In addition, we investigate whether an increased level of regulatory sanctions may weaken the psychological tie between manager and auditor, and improve auditors’ performance. Because both auditors and managers’ decisions are embedded in the resulting financial statements (Nelson et al. 2002), we use an experiment to disentangle auditors’ decisions from those of managers. We conduct a 2X2 between-subject randomized experiment with 174 Chinese auditors evaluating a short case where managers have incentive to classify financial assets for earnings management. We manipulate two conditions, 1) managers’ incentives for earnings management 5 attempts (EMA) by varying prior operating performance, and 2) the severity of regulatory sanctions/penalties. Our results show that auditors are aware of the use of investment transactions for earnings management; however, they believe managers’ choices are ethical when there is a high need for earnings management. In addition, we find harsh penalty/sanction to be effective in improving performance, especially when earnings management incentive is high, but the use of harsh penalty/sanction can be a double-edged saw, in that, when managers have low earnings management incentives, harsh penalty/sanction may undermine auditors’ ability to correct earnings management attempts. Our study contributes to prior literature on auditors’ judgments. We identify and find evidence of a psychological force that may impair auditors’ independence in China. In addition, we provide direct evidence about the effects of regulatory sanctions on auditors’ behaviors. Our evidence suggests that in countries with limited investor protection, such as China, auditors will play a meaningful role in curtailing earnings management attempts as long as there is a adequate regulatory enforcement in place. II. Background and Literature Review Auditors and Earnings Management The quality of financial reporting depends on auditor independence. Prior research find that auditor independence is affected by many factors such as audit fees, client sizes, non-audit service, competition, audit firm size, regulation and reputation (DeFond et al. 2002, Ashbaugh et al. 2003, Shockley 1981, Magee and Tseng 1990, Arrunada 2000, Wilson and Grimlund 1990, DeAngelo 1981b, DeFond et al. 2000). Because auditors have to consider client retention, sufficient evidence, immateriality, and/or compliance of rule and regulation, whether or not and how much to correct earnings management attempts is a complex decision (see Nelson et al. 6 2003). Anderson et al. (2004) find that auditors are sensitive to the potential for earnings management. They examine how quantification and the strength of earnings management incentive influence the persuasiveness of management-provided explanations for an unexpected balance in an account requiring significant estimation (i.e., revenue). They find that auditors are skeptical of managers’ explanation when managers have strong incentives for earnings management and are not more persuaded by a quantified explanation from management. In addition, the authors find that auditors’ planning judgments were influenced similarly by incentives to manage earnings. Results from Anderson et al. (2004) suggest auditors are quite capable of maintaining independence in mind. Other studies find that auditors’ ability to curtail earnings management may be limited. Hackenbrack and Nelson (1996) find auditors’ decisions about earnings management attempts depend on perceived audit risk. Specifically, auditors responded to moderate engagement risk by permitting the aggressive reporting method and justified their choice with aggressive interpretations of accounting standards; when faced with high engagement risk, the auditors responded by requiring conservative reporting and justified their choice with conservative interpretations of accounting standards (Hackenbrack and Nelson 1996). In addition, evidence in Libby and Kinney (2000) shows that auditors are often opportunistic in correcting managers’ overstatement. They find that Big Five audit managers are less likely to correct managers’ overstatement in earnings when the correction would cause the company to miss the analysts’ consensus earnings forecast. Nelson et al. (2003) surveyed audit partners and managers from one Big Five firm with a focus on managers’ decisions to attempt earnings management (EM) and auditors’ decisions to waive earnings management attempts (EMAs). Results from their survey show that even when auditors require adjustment for EMAs, they sometimes waive these 7 adjustments because a) they believe the EMA is allowed by GAAP, b) they lack sufficient evidence of client’s incorrect position, or c) because of other reasons such as immateriality. In addition, they find that auditors are more likely to waive an EMA that is structured (Nelson et al. 2003). Auditor Independence in China Though Chinese auditing standards are very similar to the international audit standards, Chinese auditing operates in a very different environment from those experienced in Western countries. The close links between the government and the audit practices and the adherence to the guanxi code of conduct in the business culture deepens the concern about the lack of independence in the Chinese auditing industry. First of all, significant conflicts of interests exist in Chinese auditing practice. Historically, the majority of CPA firms were established by the government and sponsored by the state. At the national level, the Chinese auditing profession is not self-regulated, but government regulated. The audit-government association suggests that the audit firm, in essence, is a government entity. Similarly, the controlling shareholders of many listed or unlisted companies are also government entities. The government ownership of both clients and their auditing firms makes it difficult for auditors to distance themselves from the client and thus have a truly independent state of mind. Even though many firms have gone through a disaffiliation program and are no longer owned by the government, the association still exists informally because of the profession's historical ties with the government. Despite the institutional feature, the unique business culture in China presents a challenge for auditor independence. Auditors’ reputation is established and maintained by fulfilling the obligations of guanxi (personal relationship), rather than by reporting modified opinions fairly 8 and trustfully. In the Chinese language guanxi refers to the network(s) of existing informal relationships and favors’ exchange that dominate all businesses and social activities throughout the country (Lovett et al. 1999). Guanxi is deeply rooted in the Chinese culture. Business people first build personal relationships with potential customers, and then business will normally follow the formation of a group (Hwang and Staley 2005). Guanxi creates obligations to conduct business within the formed group and obligations to pay back associated debts. To ensure the smooth operation of Guanxi, group members are expected to do favors for each other and meet the expectation of the other members. If they fail then a loss of prestige and trust will follow. Thus, in the Chinese culture, the establishment, development and maintenance of the guanxi code are a fundamental priority of many business people in the country (Hwang and Baker 2000). The force of guanxi is often subtle and unspoken, but it is well understood by the members of the network. Auditing industry is no exception. Unlike the economic dependence exists between auditors and their clients (e.g., DeAngelo 1981b), guanxi connects auditors and their clients psychologically and establishes a personal relationship between these two parties. Auditors are expected to help managers in their business and meet managers’ expectations. In China, the delisting rule (i.e., a firm will be delisted if it reports a loss in three consecutive years) creates strong incentives for firms to manage earnings in order to maintain listing status. Given this strong focus on profit, managers may expect auditors to help them avoid losses. Knowing this expectation, auditors may become a willing participant in the act of earnings management. In fact, many problems relating to Chinese auditing practice can be attributed to the guanxi network where auditors act as an advocate for the manager, and even collaborate with the manager in the illegal or unethical acts. For example, Yang et al. 2003 find that the clients in many cases committed illegal acts, such as the forgery of accounts to mask true financial positions, evade tax, 9 embezzle state revenue, and appropriate state assets; the auditors involved in these cases were found to be materially negligent or fraudulent, guilty of intentionally helping clients to falsify accounts, or guilty of providing false certificates of capital contribution verification and unqualified audit reports (Yang et. al 2003). This line of reasoning suggests that there exists a personal relationship between Chinese managers and their auditors. The strong psychological bond makes it difficult for Chinese auditors to maintain dependence in mind during the audit work. Thus, we provide our hypothesis one in a null form. H1: Chinese auditors are not sensitive to earnings management attempts. Regulatory Enforcement in China Prior research identifies investor protection and securities regulations as key institutional factors which may jointly affect corporate policy choices (see Shleifer and Vishny 1997, La Porta et al. 2000). Extensive investor-protection rights empower investors to sue management and auditors if audited earnings are questionable (Francis and Wang 2008). The Chinese market is characterized as low in investor protection. In China, auditors operate in an environment which is almost devoid of investor litigation and lacks traditional corporate governance mechanisms (Graham1996, DeFond et al. 2000, Gul et al. 2003, Gul et al. 2010). Despite the increase in litigation against managers and auditors in recent years, the auditing industry is mostly regulated by the government’s use of warnings, fines, withdrawal of certificate, and other sanctions (Yang et al. 2001). The enforcement of securities regulations is jointly carried out by the Chinese Institute of Certified Accountants (CICPA) and China Securities Regulatory Commission (CSRC). CICPA is responsible for developing and enforcing Independent Auditing Standards by periodically 10 conducting auditor practice reviews and taking “punitive measures” against auditors for noncompliance. Penalties for violating auditing standards in China can be harsh. Examples include revocation of the auditor's license to practice and even imprisonment. CSRC was created in 1992 and governs over all securities exchanges and futures markets activity within China. Similar in its role to the Securities and Exchange Commission (SEC) in the United States, the CSRC is the regulatory body that enforces securities laws and regulations. The CSRC imposes various sanctions against auditors such as admonitions (correcting the situation, internal criticism, public criticism in newspapers and on websites), fines, and temporary loss of license to practice, or more severe measures such as permanent loss of license to practice, damages, penalties, and even criminal prosecution. The subjects of punishment include listed firms, the directors of listed firms, supervisors, listing sponsors, and secretaries of boards of directors (Chen et al. 2005, Mao 2002). In a recent study, Jaggi and Low (2011) document a positive relationship between audit quality and the strictness of securities regulation in low investor-protection countries. They hypothesize that when audit risk is low in low investor-protection countries, investors lack power and incentives to sue managers and auditors, but strict securities regulations increase audit risk and the scope of audit work because violation of securities regulations may result in fines and other penalties. Moreover, DeFond and Hung (2004) argue that law enforcement institutions are more important than investor protection laws in encouraging good corporate governance practices, which, in turn, leads to increased investor confidence. In a recent study, Keune and Johnstone (2012) examine the detected misstatements, and find that auditors are less likely to allow managers to waive material misstatements when managers have strong incentives to manage earnings. Their evidence supports the notion that despite auditors’ catering to managers 11 for economic reason, auditors protect their reputation by rejecting managers’ demands when downside risk to doing so is high (Reynolds and Francis 2001). Being penalized by regulatory agency potentially ruins auditors’ reputation and bring disgrace to all members in the guanxi network. Thus, we expect auditors’ incentives to protect their reputations may improve auditor independence. The above discussion suggests that Chinese auditors are entrenched in the guanxi culture and psychologically connected to their clients. This psychological tie created by guanxi leads auditors to trust their clients and acted as an advocate for the client. However, regulatory sanction may ruin the reputation of auditors, and constrains auditors’ catering to managers. Because of weak investor protection in China, regulatory enforcement plays an important role in maintaining the integrity of the financial reporting process, we expect the strictness of punishment and sanction by the regulatory agency to influence the extent to which Chinese auditors are willing to challenge managers’ position. As the harshness of penalties increases, auditors will assess higher audit risk, which affects the level of effort planned for the audit, and be more likely to correct earnings management attempts. We consider harsh penalties such as the permanent loss of license to practice, damages, penalties, and even criminal prosecution, as well as mild penalties including admonitions (such as internal or public warning and criticism on the newspaper or website), fines, and temporary loss of license to practice. This leads to our second and third hypotheses. H2: The effect of earnings management on auditors’ recommendation for corrective action is greater under harsh penalties than under weak penalties. 12 H3: The effect of earning management on auditors’ risk assessment is greater under harsh penalties than under weak penalties. III. METHOD We test our hypotheses in a randomized 2X2 experiment. We manipulate earnings management incentives (weak vs. strong) and the severity of regulatory punishment (mild vs. harsh) as between-subjects variables. Participants evaluated a short case and then made judgments related to the case. Participants The experiment was conducted at the Chinese National Accounting Institute, where Chinese CPAs attend annual training sessions held by the Chinese Institute of Certified Public Accountants (CICPA) for continuing education credits. All of the auditors are from the top 100 accounting firms in China and audit domestically listed companies (A shares) on the Shanghai and Shenzhen stock exchange in 2012. Auditors volunteered to participate at the end of a training session in response to in-class announcements made by the training officer. All experimental instruments were translated from English to Chinese and presented to participating auditors in Chinese. In total, we received 181 completed instruments. Seven were deleted because of failing the manipulation check; so our sample includes 174 auditors, 93 male and 81 female. 139 of them have CPA designation. Among all the auditors, 24 are partners, 83 managers, 43 senior auditors, and 24 junior auditors. In terms of education, 155 auditors have bachelor’s degrees, 17 have master degrees, and 2 have doctor’s degrees (see Panel A of Table 1). The average auditing experience for the sample is 8.83 years. In terms of audit firm size, 19 auditors work for audit firms with less than 50 auditors, 24 for firms with 50 to 100 auditors, and 131 for firms with 13 more than 100 auditors. In addition, we examine the industry specialization of participating auditors, 65% specialize in the manufacturing industries, 14% in the service industry, 7% in the finance industry, 4% in real estate, 2% in the not for profit sector, and 8% in other industries. To gain a better understanding of the Chinese auditing practice, we asked auditors to answer three questions about corporate policy decisions. Our first question was as follows: “Given your experience, please indicate who hires the auditor.” Ninety-eight auditors selected management, 17 selected audit committees, and 59 selected the Board of Directors. Second, we asked: “Given your experience, indicate who decides on the audit fee”. Ninety-two selected management, 26 selected audit committees, and 56 selected the Board of Directors. Last, “Given your experience, indicate who most likely chairs the Board of Directors.” Forty-six selected management, and 128 selected major stakeholders. Clearly, auditors view management as exerting a significant influence on auditor hiring and audit fee decisions, and indicates a weak corporate governance structure in China. Lastly, we asked auditors to list the common penalties for CPAs and CPA firms. Internal criticism was listed 14 times, warnings, 24 times; public criticism in newspaper or websites, 9 times; fines, 4 times; temporary loss of license and certificate, 23 times; permanent loss of license and certificate, 78 times; criminal prosecution, 27 times; and civil liability, 12 times. [Insert Table 1] Procedure and Task In this study, we investigate the role played by Chinese auditors to limit earnings management with a focus on managers’ investment transactions decisions. We select the sale of financial assets in the Chinese market as the experiment setting for two reasons. First, the adoption of the new Chinese Accounting Standards (CAS 22) in 2007, which is essentially in line with IFRS, requires a shift from historical cost to fair value accounting in investment 14 valuation. The shift represents a significant change in standards and requires adjustments in practices at both the firm and the individual levels, and presents opportunity for earnings management. It also allows us to examine the extent to which auditors tolerate managers’ aggressive accounting choices. Second, Unlike SFAS 115 and IAS 39 which state that AFS can be classified as either current or noncurrent assets, CAS 22 classifies AFS as noncurrent assets. By this classification any investment with intent to sell within 12 months should be designated as trading securities and beyond 12 months as AFS. Because the longer time horizon associated with AFS allows managers to sit on the financial assets and wait for the right moment to sell, many Chinese companies choose not to designate the securities as part of a trading portfolio; rather, they simply classify the investment as AFS despite the initial intention to sell in the short term. Once an opportunity for sale arises within a year (e.g., as a result of higher stock prices), some managers claim a change in initial holding intent and sell the investment for gains. Falsifying the initial investment holding intention (designed to manage earnings) is clearly in violation of CAS 22. Thus, earnings management associated with investment classification in China presents an unambiguous setting to investigate auditors’ role in curbing EM. In the experiment, we asked the participating auditors to assume they are independent auditors recently hired by Company A. Specifically, they were told that A is an investment firm listed in the Shanghai stock exchange with a fiscal year ending on December 31, 2011; and during their 2011 audit, they had noticed some transactions which may require further investigation. In the weak earnings management (EM) incentives condition, participants were told that “During your audit, you noticed that Company A has been profitable in the past two years.” In the strong EM condition, they are told that “During your audit, you noticed that Company A has suffered financial losses in the past two years. In addition, the management of 15 Company A approached you and expressed concerns that future losses may lead to delisting the firm from the Shanghai stock exchange.” In both conditions, participants were provided the following information about A’s investment in X: As of December 31, 2011, Company A has 3% equity ownership of Company X. This ownership was purchased on August 15, 2011 and was subsequently sold on February 21, 2012. This ownership was initially classified as available for sale (AFS) equity investment. However, the holding period for these equity shares turned out to be only 6 months, less than one year. An explanation was provided about the sale of the investment in X. The management stated that it decided to sell the X shares because it changed its intended holding period. You also noted that on February 21, 2012, Company X shares were trading at an all-time high. The realized gain resulting from this sale on February 21 is considered to be material. The management of A states that given the accounting rule, they had the option of classifying Company X shares either as trading or available for sale securities. We manipulated the severity of penalty and sanctions against auditors at two levels, mild or harsh. In both conditions participants were told: “While conducting your audit, you heard news that Firm Y, a fellow CPA firm was recently sanctioned by the Chinese Securities Regulatory Commission (CSRC). The CSRC found that the financial statements of the company audited by Firm Y were materially misstated, and thus imposed significant penalties on Firm Y.” The harsh penalty condition includes the following statement: “Sanctions against Firm Y included the permanent loss of license to practice, damages, penalties, and criminal prosecution.” On the other hand, the statement in the low penalty condition was: “Sanctions against Firm Y included admonitions (such as public warning and criticism on the newspaper), fines and temporary loss of license to practice.” After reading the short case, participants were asked to answer a series of questions. At the end of the experiment participants answered a series of manipulation checks and demographic 16 questions and were fully debriefed. The entire experiment took 30 minutes on average to complete. IV. RESULTS Manipulation Checks and Post Experimental Questions To ensure that auditors had the adequate knowledge for this experiment, we asked them to evaluate the following questions on an 11 point scale, 1 being small and 11 being large: 1) Indicate the extent of your familiarity with the Chinese delisting rule upon 3 years’ consecutive losses; 2) Please indicate to what extent you are familiar with the investment classification (trading vs. available for sale) rule. Descriptive statistics provided in Table 2 indicate that auditors are very familiar with the delisting rule (mean = 9.44) and fairly familiar with the investment designation rule (mean = 8.47). To evaluate the validity of the earnings management incentive manipulation, we asked participants whether Company A suffered losses in the past two years. Seven auditors failed to choose the correct answer. Therefore, we excluded these auditors from the sample we analyzed (Note: Results do not change if these seven auditors are included in the analysis). All these questions suggest that our manipulation for EM incentive is effective. In addition, we asked one question related to penalty: “Please rate the severity of CSRC sanctions against the CPA firms” on an 11 point scale (1 being low and 11 being high). We find that participants in the mild and harsh penalty groups differ significantly across penalty conditions, with means of 7.48 for the mild condition and 8.70 for the harsh condition (mean difference = 1.21, t=2.4, p<0.05). This evidence suggests the manipulation of severity of penalty is effective. [Insert Table 2] Analysis 17 Hypothesis 1 focuses on auditors’ ability to detect earnings management. Panel A of Table 3 presents the descriptive statistics. In the experiment, we asked the auditors to rate “How likely is it that Company A’s sale of its Company X shares was designed to manage earnings?” on an 11 point scale (1 being very unlikely, 11 being very likely). The high average likelihood rating (grand mean =9.09) suggests that auditors are aware of the fact that in the present case managers are strategically using investment decisions for earnings management. This awareness is heightened as EM incentives increase. Table 3 presents results for ANOVA with likelihood rating as the dependent variable. The two independent variables are EM incentives and the severity of penalty. The analysis shows only a main effect of EM incentives (F (1, 170) =4.41, p < 0.05) with no significant penalty and interaction effects. Apparently, auditors are more suspicious of EM attempts as the likelihood rating is significantly higher in the strong EM incentive condition (mean =9.46) than in the weak EM incentive condition (mean = 8.65). This evidence rejects our null hypothesis of H1. To unravel the psychological force underlying auditors’ responses, we asked two additional questions related to earnings management on an 11 point scale (1 small, 11 large): 1) Please indicate to what extent A needs to increase its earnings for 2011; 2) Please indicate how ethical it is to manage earnings for a specific goal. Results in Table 2 indicate that auditors rate the need for earnings management significantly higher in the strong incentive condition (mean = 10.52) than in the weak condition (mean =6.66, mean difference =3.86, t=10.6, df =172, p<0.05). On average, auditors rate earnings management attempts as quite ethical, with an average rating over 8. This supports the complex reactions auditors have towards the real earnings management using transaction decision such as investment classification. Specifically, auditors in the strong incentive condition (mean = 8.82) rate earnings management as more ethical than those in the 18 weak incentive condition (mean =7.43, mean difference = 1.39, t=3.67, p<0.05). The relation between loss and the ethical rating for EM suggests that auditors may internally justify EM activities. This evidence is consistent with our conjecture that auditors form personal relationship with managers, and view themselves as an advocate for managers. [Insert Figure 1] [Insert Table 3] Being able to detect EM does not necessarily mean that auditors are willing to challenge managers’ positions. H2 predicts that auditors are more likely to recommend error correction under strong incentives than under weak incentives, and that harsh penalties intensify this likelihood. In the experiment, we asked auditors to answer this question: “Before the financial statements are issued, how likely is it that you would recommend to management to include the Company X investment in the 12/31/2011 financial statements as trading securities, rather than available for sale securities as initially declared by Management?” on an 11 point scale (1 being very unlikely, 11 being very likely). In this case the stocks were bought on August 15, 2011 but subsequently sold on February 21, 2012 with a holding period of less than 6 months. CAS classifies available for sale investment as non-current assets, so Company A clearly erred by classifying the stocks as AFS instead of trading securities. Therefore, the corrective action would be to reclassify AFS from noncurrent assets to trading securities as current assets in the balance sheet. Panel A of Table 4 provides descriptive statistics about auditors’ recommendation for reclassification. In general, the likelihood rating is quite high (grand mean = 8.83). We observe that the mean rating under strong EM incentive (mean=9.22) is higher than under weak EM incentive (mean=8.35). ANOVA results (see Panel B of Table 4) indicate that, in addition to the 19 significant effects of EM incentive (F(1, 170)=10.93, p<0.05), the interaction between EM incentive and penalty is statistically significant (F(1,170)=3.61, p<0.05). This suggests that penalty and EM incentive jointly affect auditors’ reclassification decision with harsh penalties intensifying the rating for reclassification. Analysis of simple effects suggests that in the mild penalty condition, the difference in rating between weak and strong incentives is not significant, but in the harsh penalty condition, the rating under strong EM incentives (mean = 9.45) is significantly higher than under the weak EM incentives (mean = 8.09), (mean difference = 1.36, p<0.05). In other words, harsh penalties magnify the effect of earnings management incentives on auditors’ behavior. Therefore, the evidence supports H2. [Insert Figure 2] [Insert Table 4] H3 investigates auditors’ assessment of audit risk. In general, auditors assess relatively high audit risk for Company A, as the grand mean rating is 8.61 on an 11 point scale (1 being very low, 11 being very high). ANOVA results (see Panel B of Table 5) suggest that both independent variables of EM incentives (F(1,170)=14.88, p<0.05) and Penalties (F(1, 170)=3.81, p<0.05) and their interactions (F(1,170)=5.89, p<0.05) are statistically significant. This suggests that auditors’ audit risk assessment is jointly affected by EM incentives and the harshness of penalties. Analysis of simple effects suggests that harsh penalties intensify the assessed audit risk. In other words, auditors are more sensitive to EM incentives under that harsh penalties condition. Specifically, auditors assess higher audit risk (mean=9.14) when they face strong EM incentives than when facing weak EM incentives (mean=7.26), and the difference is statistically different only under the harsh penalty condition (mean difference = 1.88, p<0.05), but the difference is not significant under the mild penalties condition. 20 [Insert Figure 3] [Insert Table 5] It is puzzling that auditors rate audit risk the lowest and are least likely to recommend reclassification in the low incentive/harsh penalty condition. This seems very counter-intuitive. We conduct simple effect analysis for re-classification recommendation and audit risk across two different incentive conditions. The difference of re-classification decision between mild and harsh penalty is not statistically significant in the weak incentive condition, but the difference of audit risk is statistically significant (see Panel C of Table Five). We provide a possible explanation for why auditors rate audit risk significantly lower in the low incentive/harsh penalty condition. We think that auditors in our study believe harsh penalty is very serious, but highly unlikely, and thus, they are unwilling to assess high audit risk and exert extra audit effort. This explanation is consistent with our conjecture that auditors highly value the personal relationship (guanxi) with manager. This evidence shows that harsh penalty/sanction can be effective in improving auditor performance, especially when earnings management incentive is high, but the use of harsh penalty/sanction can be a double-edged saw, in that, when managers have low earnings management incentives, harsh penalty/sanction may undermine auditors’ ability to correct earnings management attempts. V. Conclusions This study attempts to gain insight into auditors’ behavior in the unique Chinese setting. We investigate the auditors’ role in curtailing or allowing earnings management and the potential moderating effects of regulatory sanctions. We focus on Chinese auditors for two reasons: Chinese companies have strong incentives to manage earnings in order to maintain listing status and have also been historically tied to their auditors. We use a 2X2 experiment, where we 21 manipulate earnings management incentives (weak vs. strong) and auditor penalty severity (mild vs. harsh). 174 Chinese auditors participated in the experiment and reviewed a case about equity investment classification. Because the classification of AFS is often strategic in China, this setting presents an unambiguous opportunity to test for earnings management, where we can assess the auditors’ role in curbing earnings management. In the experiment, auditors were asked to judge the likelihood for earnings management attempts and assess the likelihood for corrective action and audit risk. Our results show that Chinese auditors are aware of the use of investment transactions for earnings management; however, they believe managers’ choices are ethical when there is a high need for earnings management. In addition, we find harsh penalty/sanction to be effective in improving audit performance, especially when earnings management incentive is high, but the use of harsh penalty/sanction can be a double-edged saw, in that, when managers have low earnings management incentives, harsh penalty/sanction may undermine auditors’ ability to correct earnings management attempts. This study has several limitations. The use of Chinese auditors may limit the generalization of our findings to other countries or regions where the institutional environment is different from that of China, or where accounting serves a different role. In addition, the participating auditors work in Chinese domestic public CPA firms. These auditors differ from other Chinese auditors who work for international firms, such as the Big-Four affiliates, in their experience, knowledge, and most importantly, cultural background. Future studies should investigate international auditors whose ability to detect and deter earnings management may be different from that of domestic auditors. Moreover, we find Chinese auditors rate earnings management as more ethical when managers suffer loss and have a need for earnings management; however, we also find that these auditors recommend corrective actions and assess 22 higher audit risk when earnings management incentives are high. This appears to be a disconnection between belief and action and requires further research. Finally, this study focuses on the psychological aspect of Chinese auditors’ independence, but we only provide a narrow view of the judgment and decision making process of Chinese auditors. Future studies should investigate the underlying cognitive process and gain broader understanding of their decision making. 23 Figure 1: Likelihood to Detect Earnings Management Rating (H1) 10 9.5 9 8.5 8 7.5 7 6.5 6 5.5 5 9.53 9.39 8.61 8.69 High Incen Low Incent Low Penalty High Penalty The figure shows the rating for the likelihood of detecting earnings management and is based on the question “How likely is it that Company A’s sale of its Company X shares was designed to manage earnings?” The rating is on an 11 point scale and presented in the vertical line. Figure 2: Re-classification Recommendation (H2) 10 9.5 9 8.5 8 7.5 7 6.5 6 5.5 5 9.45 8.98 8.61 8.09 High Incen Low Incent Low Penalty High Penalty The figure shows the rating for the question “Before the financial statements are issued, how likely is it that you would recommend to management to include Company X investment in the 12/31/2011 financial statements as trading securities, rather than available for sale securities as initially decided by Management?” The rating is on an 11 point scale (1 being very unlikely, 11 being very likely). The vertical line represents the rating scale. 24 Figure 3: Audit Risk (H3) 10 9.5 9 8.5 8 7.5 7 6.5 6 5.5 5 9 8.57 High Incen 9.14 7.26 Low Incent Low Penalty High Penalty The figure shows the rating for the question “Faced with Management’s decision on the classification as explained above, how would you assess Company A’s audit risk?” The rating is on an 11 point scale (1 being very low, 11 being very high). The vertical line represents the rating scale. 25 Table 1: Descriptive Statistics of Demographics Panel A: Demographics of Participating Auditors (in Frequency) Gender Male Female Position 93 81 Partner Manager Senior Auditor Junior Auditor CPA 24 83 43 Yes No Education 139 35 Bachelor Master 155 17 2 Doctor 24 Panel B: Questions about Corporate Policies Auditor Audit Hiring Fee Management 98 92 Appointment of Chairman of Board of Director 46 Audit Committee 17 26 Board of Directors 59 56 Major Stakeholder 128 Panel A of Table 1 presents the frequency of answers to demographic questions about gender, position, CPA designation, or education level. Panel B presents answers to three questions: 1) Given your experience, please indicate who hires the auditor. 2) Given your experience, indicate who decides on the audit fee. 3) Given your experience, indicate who most likely chairs the board of directors. For questions 1 and 2, auditors must choose one of the three: the company’s management (CEO or CFO), the audit committee, or the Board of Directors. For question 3, auditors must choose from the company’s management (CEO or CFO), an outsider, or a major stock holder. 26 Table 2: Descriptive Statistics of Post-Experimental Questions Familiarity with Delisting Rule Weak Incentive Mean Std. N Strong Incentive Mean Std. N Average Familiarity with Investment Rule Degree to Need for which Earnings Earnings Management Management is Ethical 9.61 8.33 7.43 6.66 1.77 2.26 2.51 3.27 80 80 80 80 9.36 8.57 8.82 10.52 2.30 2.05 2.44 1.21 94 94 94 94 9.44 8.47 8.18 8.74 Table 2 presents answers to these four questions: 1) Indicate the extent of your familiarity with the Chinese delisting rule upon 3 years’ consecutive losses on an 11 point scale (1 being small, 11 being large). 2) Please indicate to what extent you are familiar with the investment classification (trading vs. available for sale) rule on an 11 point scale (1 being small, 11 being large). 3) Please indicate how ethical it is to manage earnings for a specific goal on an 11 point scale (1 being unethical, 11 being ethical). 4) Please indicate to what extent A needs to increase its earnings for 2011 on an 11 point scale (1 being small 11 being large). 27 Table 3: Likelihood of Earnings Management (Test of H1) Panel A: Likelihood Rating (Mean) (std) Mild Penalty Harsh Penalty Weak Incentives 8.69 (0.36) n=31 8.61 (0.36) n=49 Strong Incentives 9.53 (0.37) n=45 9.39 (0.36) n=49 Panel B: Two-Way ANOVA with Likelihood Rating as the Dependent Variable Source SS df MS F P (2-sided) Earnings Management Incentives 27.35 1 27.35 4.41 .04 Harshness of Penalties 0.54 1 0.54 0.09 .77 Incentives x Penalty 0.44 1 0.44 0.00 .93 Within Cells (Error) 1055 170 6.20 The tables present results related to H1: Auditors are insensitive to earnings management attempts. The dependent variable is the likelihood rating which is on an 11 point scale (1 being very unlikely, 11 being very likely) and based on the question “How likely is it that Company A’s sale of its Company X shares was designed to manage earnings?” The two independent variables are earnings management incentives (EM incentives) (strong vs. weak) and Harshness of Penalty (mild vs. harsh). 28 Table 4: Re-classification Recommendation Likelihood (Test of H2) Panel A: Likelihood for Re-classification Rating (Mean) Mild Penalty Harsh Penalty Weak Incentives 8.61 (0.24) n=31 8.09 (0.25) n=49 Strong Incentives 8.98 (0.25) n=45 9.45 (0.24) n=49 Panel B: Two-Way ANOVA with Re-classification Recommendation Likelihood as the Dependent Variable Source Earnings Management Incentives SS df MS F P (2-sided) 30.96 1 30.96 10.93 .00 Harshness of Penalties 0.02 1 0.02 0.00 .93 Incentives x Penalty 10.22 1 10.22 3.61 .06 Within Cells (Error) 481.44 170 2.83 Panel C: Results of Simple Effects Mean Diff. Std. Sig. Mild Penalty Strong vs. Weak Incentive 0.37 0.35 0.29 Harsh Penalty Strong vs. Weak Incentive 1.35 0.39 0.00 The tables present results related to H2: Auditors are more likely to recommend corrective action under strong incentives than under weak incentives; the difference in 29 likelihood is greater under harsh penalties than under mild penalties. The dependent variable is the likelihood rating which is on an 11 point scale (1 being very unlikely, 11 being very likely) and based on the question “Before the financial statements are issued, how likely is it that you would recommend to management to include Company X investment in the 12/31/2011 financial statements as trading securities, rather than available for sale securities as initially declared by Management? ” The two independent variables are earnings management incentives (EM incentives) (weak vs. strong) and Harshness of Penalty (mild vs. harsh). 30 Table 5: Audit Risk (Test of H2) Panel A: Audit Rating (Mean) Mild Penalty Harsh Penalty Weak Incentive 8.57 (0.28) n=31 7.26 (0.35) n=49 Strong Incentive 9.00 (0.46) n=45 9.14 (0.28) n=49 Panel B: Two-Way ANOVA with Audit Risk Rating as the Dependent Variable Source Earnings Management Incentives SS df MS F P (2-sided) 56.16 1 56.16 14.88 .00 Harshness of Penalty 14.38 1 14.38 3.81 .05 Incentives x Penalty 22.25 1 22.25 5.89 .02 Within Cells (Error) 641.94 170 3.78 Panel C: Results of Simple Effects Mean Diff. 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