Management's Materiality Criteria of Internal Control Weaknesses and Corporate Fraud: Evidence from China

This paper investigates the determinants and consequence of Chinese listed companies' first-time decisions on materiality criteria for internal control weaknesses, which have been observable beginning from the 2011 annual report. Although pretax income is most commonly used as the benchmark for materiality, revenue is also used as a popular alternative. Revenue is more susceptible to manipulation, as it has a much larger financial amount than pretax income. We argue that unethical managers prefer not to disclose material weaknesses by manipulating the materiality criteria to justify non-disclosure of a potentially material weakness. Consistent with this opportunistic incentive, we find that when companies committed fraud in the previous year that remains undetected, their management is more likely to use revenue (rather than pretax income) as the first-time benchmark and to set a higher revenue-based materiality threshold as well. Moreover, once the materiality metrics are set, the first-time revenue-based materiality threshold is significantly and positively associated with subsequent incidence of corporate fraud, which suggests that setting deviant and loose materiality metrics leaves room for the management to engage in future misconduct.