Regulation Risk and Auditors’ Reporting Conservatism: Evidence from Chinese Comment Letters

Abstract

We study how auditors respond to regulatory risk that arises when their clients receive comment letters from Chinese stock exchanges. Our results show that auditors are more likely to issue modified or conservative—but not excessively conservative—audit opinions to the recipients of comment letters. This reporting conservatism is especially pronounced when the regulatory risk perceived by auditors rises, such as when comment letters contain more questions, when more comment letters are issued, when the auditors must give opinions on specific issues, or when comment letters involve more auditor issues. Comment letters have been issued in China since 2013, but did not have to be disclosed until 2015. We find no significant difference in the impact of comment letters on auditor conservatism between pre- and post-disclosure periods. Further, the size of auditor firms has no significant effect on the impact of comment letters in post-disclosure periods. We interpret our results as supporting the regulation risk hypothesis.

Keywords: Regulation Risk; Comment Letters; Auditors’ Reporting Conservatism; Spillover Effect.

JEL Classification: G28, M42