The strength of a firm’s internal control is, at least in part, an endogenous choice. While the benefits of strong internal controls are numerous (i.e., promoting efficiency, reducing the risk of asset loss, and helping to ensure the reliability of financial statements and compliance with laws and regulations), there are costs involved. The explicit costs associated with SOX Section 404 have been estimated to be close to $8 million per firm (Charles Rivers Associates 2005). Perhaps more importantly, as internal control improves, the ability of management to manage earnings declines. A weak internal control environment has the potential to allow both intentional and unintentional errors in accrual estimation (Doyle et al. 2007b). Management considers the explicit costs of strengthening internal controls, but also considers its private benefits, which include the ability to manage or smooth earnings to maximize their compensation and the value of their equity holdings. Prior research (e.g., Healy 1985; Watts and Zimmerman 1986) has shown that managers make accounting choices to maximize the value of their compensation and that incentives provided by equity holdings lead to earnings management (e.g., Cheng and Warfield 2005; Bergstresser and Philippon 2006; and Efendi et al. 2007).