Finally, because we study disclosures made during a reporting regime that predated
SOX 404 internal control audits, our study identifies factors that contribute to internal
control problems for a broad cross-section of publicly traded firms that includes both
Accelerated and non-accelerated filers. Thus, our ICD model facilitates the formation of
expectations about the determinants of ICDs that is more representative of the underlying
population of firms that face control problems because our sample cuts across firms of all
sizes in contrast to the sample in the Doyle et al. (2006a) study that contains a higher
proportion of accelerated filer (larger) firms. Later in our paper, we demonstrate how this
difference in sample composition influences the results.
The remainder of the paper proceeds as follows. Section 2 elaborates on the regulations
of SOX pertinent to reporting ICDs and introduces our conceptual framework for ICD
disclosures. Section 3 describes our sample and descriptive statistics. Section 4 presents the
multivariate analysis of the determinants of ICDs, as well as marginal effects, and
sensitivity analyses of alternative measures of explanatory variables. Section 5 presents our
summary and conclusions and identifies several avenues for future research. LE I