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An Analysis of Database Challenges in Financial Misconduct Research

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1 An Analysis of Database Challenges in Financial Misconduct Research
Jon Karpoff University of Washington Allison Koester Georgetown University Scott Lee University of Nevada, Las Vegas Jerry Martin American University

2 Databases – misreporting studies
Restatement announcements GAO – Government Accountability Office AA – Audit Analytics Securities class action lawsuits SCAC – Stanford Securities Class Action Clearinghouse Administrative proceedings & Litigation releases that censure accountants AAER – Accounting and Auditing Enforcement Releases secondary designation assigned by the SEC

3 Databases are simply tools
Like any tool, databases can be well-suited for one purpose… …and poorly suited for other purposes.

4 5 Features of the Databases
Initial revelation of misconduct - Do databases identify the initial revelation Scope limitations - How many “other-type” events does each database omit? Omissions - How many “same-type” events does each database miss? 4. Multiple events per case - Event-level observations often are NOT independent Extraneous observations - Does the database capture financial misrepresentation? (Hennes et al. 2008) - Does the database capture fraud?

5 Documenting each database’s features
Create a comprehensive database with: All 1,099 cases (includes 10,415 events) for which the SEC brings an enforcement action for §13(b) violations Books & records and internal control violations (FCPA) 2. Assemble data related to these cases from: Wolters Kluwer Law & Business Securities electronic library PACER (court documents) Lexis-Nexis’ All News and Dow Jones’ Factiva (press releases and articles) 3. Merge in GAO, AA, SCAC, and AAER database events Which §13(b) violations are included/missed by each database? What ancillary information is included/missed by each database?

6 Brocade Communications
Consider a firm picked up by all 4 databases: Brocade Communications A total of 23 unique event days with specific incremental information about Brocade’s financial misrepresentation

7 How can so many dates be relevant?
Jan 6, 2005: Brocade press release (issued after trading hours) announces its financial statements will be restated due to improper accounting for stock options Mar 10, 2005: SEC begins an informal inquiry June 10, 2005: SEC begins a formal investigation Brocade Communications was chosen specifically because all 4 databases flag it. This is NOT common.

8 Brocade Communications
Brocade makes four restatement announcements…

9 Brocade Communications
… a class action lawsuit is filed, and settled 3 years later…

10 Brocade Communications
… and the SEC issues 15 different Administrative Proceedings and/or Litigation Releases spanning 5 years

11 GAO hits 4 of 23 events AA hits 2 of 23 events Audit Analytics
Identifies Restatement #1 & 3 misses # 2 & 4 Neither GAO & AA inform you that the information was released after the market closed on Thursday, Jan 6, 2005  Friday, Jan 7, market response

12 SCAC hits 2 of 23 events

13 AAER hit rate = 2 of 23 events
Both AAERs relate to the SEC’s censure of two former Brocade executives who are CPAs.

14 5 Database Features and Brocade
Initial revelation dates GAO and AA identify the initial misconduct date Brocade’s announcement occurred after the U.S. markets close First event in SCAC is 4 months after initial revelation AAERs are 4 YEARS later 2. Scope limitations Of 23 events, GAO captures 4, AA, SCAC, and AAER capture 2 each 3. Omissions Only AA misses “same-type” events (unusual by selection) 4. Multiple events per case All databases have this 5. Extraneous events Can’t illustrate with a case chosen because it includes a §13(b)

15 Focusing on one aspect of a complex event
Parable of the blind men and the elephant

16 Number of Events Integrated into Cases for each Database
Table 2, Panel A GAO AA SCAC AAER FSR Events Cases In each database 2,707 11,001 3,421 3,568 10,415 1,099 Associated with a §13(b) violation

17 Number of Cases after Integrating Related Events for each Database
Table 2, Panel A GAO AA SCAC AAER FSR Events Cases In each database 2,707 2,321 11,001 8,358 3,421 3,116 3,568 1,356 10,415 1,099 Associated with a §13(b) violation

18 Number of Events and Integrated Cases associated with a §13(b) violation
Table 2, Panel A GAO AA SCAC AAER FSR Events Cases In each database 2,707 2,321 11,001 8,358 3,421 3,116 3,568 1,356 10,415 1,099 Associated with a §13(b) violation 427 290 239 188 389 346 2,865 939

19 We are concerned with how these databases perform in describing §13(b) violations
Table 2, Panel A GAO AA SCAC AAER FSR Events Cases In each database 2,707 2,321 11,001 8,358 3,421 3,116 3,568 1,356 10,415 1,099 Associated with a §13(b) violation 427 290 239 188 389 346 2,865 939 Important: All comparisons refer ONLY to the subset of events and cases in each database associated with a §13(b) violation

20 Feature #5: Extraneous cases
Table 6, Panel A NOT suggesting that extraneous events/cases should be omitted from each database Documenting the culling process facing researchers who use these databases to study financial misrepresentation

21 Feature #3b: Omitted Cases
(during coverage period) Table 4, Panel B Omitted cases with at least one same-type event AND a 13(b) violation during the database time period GAO AA SCAC AAER Cases identified by the database 290 188 346 939 Cases missed by the database 127 220 36 160 Number of cases that should have been identified 417 408 382 1,099 % of cases missed 30.5% 53.9% 9.4% 14.6%

22 Feature #2: Scope Limitations
Table 3, Panel B NOT suggesting GAO should include all 4,336 events But, remember the hazard of considering only the “elephant’s tusk”

23 % market reaction is understated using
Economic Magnitude of Features #2 and #3 (Scope Limitation and Omissions) Table 7, Panel B: Mean market-adj. CAR over all event dates identified in each case GAO AA SCAC AAER FSR Using all event dates per case identified by the database -7.82% -4.64% -5.61% -7.49% -39.93% Using all event dates per case identified by the FSR database -50.36% -38.38% -51.41% -44.38% % market reaction is understated using non-FSR database 84% 88% 90% 83% 0%

24 Feature #1: Initial revelation dates
Figure 3: Initial Revelation Date, by Event Type

25 Feature #1: Initial revelation dates
Table 3, Panel A

26 Lessons Financial misconduct cases are complex
Scope limitations can affect economic significance inferences Researchers should look beyond individual databases High event/case omission rates  contaminated control samples Ad hoc culling tends to select extreme incidents which yields unrepresentative and biased inferences Financial misconduct is NOT necessarily fraud 25% of 13(b) violations do NOT involve fraud charges 50% for AAERs 90% for securities class action lawsuits and restatement announcements

27 Thank you


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