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沙賓法

404

條及審計準則第

5

號是否會減少內部控制揭露錯誤?

260

of their professional judgments regarding risk of material misstatements have led to the

promise made by the PCAOB and SEC to scrutinize the effect of AS5 (Olson, 2007; Cox,

2007). Our study reveals the effect of SOX 404 and AS5 on public ICFR disclosures and

points out that the enactment of SOX 404 can enhance ICFR-disclosure quality by

reducing the incidence of Type II errors. However, we also find that AS5 lowers ICFR-

disclosure quality by showing the increased likelihood of Type II errors. The evidence

provided in this study might help policymakers and standard setters to formulate future

ICFR-audit-related rulings.

The remainder of this paper is organized as follows. The next section presents the

related literature and our hypotheses. Section 3 describes our research design and sample

selection. Our results are presented in Section 4. Section 5 reports the sensitivity and

additional tests. Finally, Section 6 concludes our research.

2. Related Literature and Hypothesis Development

2.1 SOX 404 Regulation and Auditing Standards Regarding ICFR

Before the passage of SOX, public companies were required to disclose information

about internal controls only when a Form 8-K was filed after an auditor change. Sections

302 and 404 of SOX are the first statutory legislation that requires public companies to

disclose the effectiveness of internal controls. Section 302, effective for the fiscal years

ending on or after August 29, 2002, requires managers of public companies to evaluate

and conclude on the effectiveness of their internal control systems in periodic reports.

Section 404, which became effective for the fiscal years ending on or after November 15,

2004, contains two subsections. Under Section 404(a), managers are mandated to prepare

ICFR assessments in annual reports. Under Section 404(b), public accounting firms that

audit the issuers’ financial reports shall also attest to the management internal control

assessments. Moreover, AS2:

An Audit of Internal Control over Financial Reporting

Performed in Conjunction With an Audit of Financial Statements

, effective since

November 15, 2004, has established requirements and has provided auditors guidance in

performing ICFR audits (PCAOB, 2004).

While the implementation of SOX 404 increases the productivity of audit firms

(Chang, Choy, Cooper, and Lin, 2015), internal control audits under the directions

prescribed in AS2 have resulted in strong complaints from public companies to the SEC

and PCAOB about substantial increases in audit fees (Johnson, 2005). To mitigate the

burdensome compliance costs of internal control audits, the PCAOB replaced AS2 with