This study provides evidence that, when ‘‘hard’’ freezing their defined benefit pension
plans, employers select downward biased accounting assumptions to exaggerate the
economic burden of their benefit plans. Downward biased expected rates of return and
discount rates allow managers to increase reported pension expenses and, for discount
rates, allow managers to increase reported pension liabilities. We find that prior to the
Sarbanes-Oxley Act, both rates are downward biased when firms freeze their plans,
whereas after SOX the bias is lower. This finding is consistent with managers
opportunistically biasing pension estimates to obtain labor concessions during periods
of reduced regulatory scrutiny.