Ashbaugh, Collins, and Kinney, henceforth ACK, and Doyle, Ge, and McVay, henceforth DGM,
provide the first evidence relating firm characteristics to internal control deficiencies (ICDs) reported
under new disclosure requirements. Both studies document that control risk factors associated with
organizational complexity and significant organizational change, as well as relative investment in
internal control systems, are related to disclosure of internal control. ACK also test whether factors
associated with incentives to discover and report ICDs affect disclosure of ICDs but this evidence is
less compelling. I present alternative explanations and provide some descriptive evidence that is
consistent with these alternative explanations.