ABSTRACT We examine the consequences of the 2020 amendment to Exchange Act Rule 12b-2, which exempted low-revenue issuers from the ICFR audit requirement and reignited the debate among regulators, issuers, auditors, and academics about the costs and benefits of ICFR audits. We find that exempt issuers rarely obtain ICFR audits voluntarily, indicating they generally do not view such audits as cost beneficial. We also find that exempt issuers report fewer MWs than nonexempt issuers, although this effect is driven by a recent increase in MWs for nonexempt issuers rather than a decline in MW for exempt issuers. We find no evidence that exempt issuers misstate more frequently or that they have less informative control effectiveness disclosures. Overall, our findings suggest that the exemption was welcomed by affected issuers and did not materially impair reporting quality, informing the literature and ongoing policy discussions regarding the appropriate scope of ICFR audit requirements. Data Availability: Data are publicly available from the sources identified in the text. JEL Classifications: M42; M48.
McCallen et al. (Mon,) studied this question.