Our sample begins with 2261 AAER sissued by the SEC from May 17th,1982 through June 10th, 2005.Since 1982,the
SEC has issued AAER sagaist a company,an auditor,or an officer for alleged accounting and/or auditing misconduct.The
misstatements identified in the AAERs are typically egregious cases of materia lmisstatements tha tinvolve GAAP
violations. The AAERs provide varying degrees o fdetail on the nature of the misconduct,the individuals and entities
involved, and the effect on the financial statements.12 Table 1 reports the sample selection procedure.There are a total of
896 firms referenced in the AAERs.We firs tex clude219 firms that either were charged for conduc tother than accounting
manipulations (e.g.,bribery,disclosure issues,etc.)or could not be linked to specific manipulation periods.Among the
remaining firms,178 firms do not have valid CUSIP identifiers,resulting in a sample of 499 firms.These 499manipulation
firms are ou rbase sample and are used in our legal cost analysis for CFOs.13