Financial Reporting Consequences of Exempting Low-Revenue Issuers from the Internal Control Audit Requirement
研究了2020年交易所法案规则修订豁免低收入发行人内部控制审计要求的影响，发现豁免发行人很少自愿进行审计，且报告质量未显著下降。
ABSTRACT We examine the consequences of the 2020 amendment to Exchange Act Rule 12b-2, which exempted low-revenue issuers from the ICFR audit requirement and reignited the debate among regulators, issuers, auditors, and academics about the costs and benefits of ICFR audits. We find that exempt issuers rarely obtain ICFR audits voluntarily, indicating they generally do not view such audits as cost beneficial. We also find that exempt issuers report fewer MWs than nonexempt issuers, although this effect is driven by a recent increase in MWs for nonexempt issuers rather than a decline in MW for exempt issuers. We find no evidence that exempt issuers misstate more frequently or that they have less informative control effectiveness disclosures. Overall, our findings suggest that the exemption was welcomed by affected issuers and did not materially impair reporting quality, informing the literature and ongoing policy discussions regarding the appropriate scope of ICFR audit requirements. Data Availability: Data are publicly available from the sources identified in the text. JEL Classifications: M42; M48.