As noted by former SEC Chairman Arthur C. Levitt, while this kind of earnings management impairs financial reporting quality by misleading investors, it does not rise to the level of a material
misstatement (Levitt, 1998). Thus, within-GAAP manipulation is likely to represent the “qualitative aspects of management's
accounting choices” that reflect “potential bias in management's judgments” that auditing standards require auditors to
evaluate (PCAOB, 2010). In addition, while proxies such as DAC do not directly capture egregious misstatements, DAC is
associated with AAERs (Dechow et al., 1996), and thus captures the increased likelihood of more extreme misstatements. Yet
another advantage is that their continuous nature captures variations in audit quality even in studies that are restricted to
relatively small samples, and within the subset of clients who do not have egregiously poor audit quality. This contrasts with
restatements and GCs, whose infrequent occurrence requires large samples, and whose discrete nature masks any variation
in audit quality among clients without restatements and GCs.