Erschienen in:

14.01.2020

# A simple structural estimator of disclosure costs

verfasst von: E. Cheynel, M. Liu-Watts

Erschienen in: Review of Accounting Studies | Ausgabe 1/2020

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## Abstract

This study recovers a simple firm-level measure of disclosure costs implied by the voluntary disclosure theory of Verrecchia (Journal of Accounting and Economics 12(4), 365–380, 1990). The measure does not require knowledge by the researcher of the distribution of private information and can be implemented with three simple observable inputs: the minimum, average, and frequency of disclosure. We document a positive association of disclosure costs with proxies for existing and potential competition, information asymmetry, and insider trading. Higher values of disclosure costs are associated with lower contemporaneous and future disclosures as well as lower propensity to disclose in holdout samples. Overall, we provide future researchers with an easy-to-implement procedure to structurally estimate unobserved firm-level disclosure costs.
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Fußnoten
1
Following Verrecchia (1990), we have left aside considerations of risk-aversion modeled in the original Verrecchia (1983) model; that is, we assume that the set of potential investors is large, and the disclosure is about a diversifiable component such that there is risk-neutral pricing of the disclosed value (Cheynel 2013). For a more comprehensive empirical analysis of settings with a small investor base, see Armstrong et al. (2011). Note that investor risk-aversion increases the willingness to disclose for a given cost, since markets discount more risky non-disclosure. Therefore risk-aversion would directionally predict higher disclosure costs than those under risk-neutrality.

2
In other words, if the market price is $$P(\mathcal {I})= \alpha \mathbb {E}(e|\mathcal {I})$$, estimated variables can be rescaled by α, which can be estimated empirically. We omit α since it plays no further role in the estimation.

3
Within product market theories, information may be proprietary, and thus c is positive because disclosure will benefit existing competitors (e.g., Verrecchia 1983; Dye 1986). At the same time, depending on the effect of disclosure on the aggressiveness of potential competitors, disclosure can entail some benefits (e.g., Darrough and Stoughton 1990). Disclosure may mitigate agency costs stemming from diverging interests between owners and managers and affect investment efficiency (e.g., Stocken and Verrecchia 2004; Liang and Wen 2007). Or disclosure may reduce the risk of a shareholder lawsuit (e.g., Skinner 1994; Skinner 1997) or reduce information asymmetry (e.g., Diamond and Verrecchia 1991). Other disclosure costs can take the form of processing, communicating and producing the information to outsiders as well as psychological costs and reputational concerns. The cost c is positive in aggregate.

4
The model is laid out as if the manager paid the cost directly, mainly to avoid having to redefine the price equation to include the costs and burdening the exposition.

5
Our cost estimation approach still works even if there are multiple equilibria as long as the same equilibrium is implemented during the sample period. More assumptions are typically needed to guarantee the existence of a unique equilibrium. For example, if x is logconcave with sub-exponential lower tail, there exists a unique interior equilibrium. The proof of uniqueness follows immediately from the definition of logconcavity. Without sub-exponential lower-tail, there may be equilibria featuring unravelling even if the cost is non-zero (e.g., Laplace distributions); we refer to Bertomeu and Cheynel (2018) for a proof of a unique interior equilibrium as long as the lower tail becomes small at a rate greater than exponential rate. As a special case, this is always true if the distribution is bounded from below. Note that, strictly speaking, we can lift the requirement of logconcavity and sub-exponential tail as long as we assume that the entire sample is generated from players coordinating on one interior equilibrium.

6
The validity of your approach is contingent upon the equilibrium being characterized by a threshold and some relations between the cost and x could undermine that equilibrium characterization.

7
We can approximate $$\mathbb {E}(x|x\leq \tau )$$ by computing the average earnings surprise for firm quarters for which there is no disclosure in the data, but this estimation procedure entails many caveats. First, it assumes that the private information is formulated in terms of posterior expectations, such that $$\mathbb {E}(e|ND)=\mathbb {E}(x|ND)$$ by the law of iterated expectations. Second, empirically, because we do not know when the manager receives his information, we cannot measure accurately the consensus and need to make choices when to pick the consensus, which is likely to add noise in the estimation. The estimation procedure that we adopt is not sensitive to these choices. We express $$\mathbb {E}(x|ND)=-\frac {p}{1-p}\mathbb {E}(x|x>\tau )$$ such that both p and $$\mathbb {E}(x|x>\tau )$$ can be measured directly in the data.

8
In Appendix A, we derive the asymptotic variance of the BBT and NP estimators.

9
While our empirical analyses will focus on the NP estimator, we show in Appendix B that the model can serve as a starting point for richer settings; we also discuss how to modify (or sometimes reinterpret) the analysis in three plausible alternative settings. Specifically, our NP estimator derived under pure disclosure costs continues to hold after including other disclosure frictions. For example, it is robust to a probability that the manager does not receive private information or to a probability that the manager receives some information that she would like to disclose, but she cannot convey it credibly, as in Dye (1985). It can also incorporate an exogenous probability that forces the firm to disclose or a probability that the manager does not care about maximizing the price and never discloses.

10
Everything else held equal, a greater frequency $$\hat {p}$$ implies a higher proprietary cost. This last property is seemingly counterintuitive, that is, one might expect a firm that discloses more often to have low proprietary costs. To see why this occurs, consider the case when c is small; then $$\hat {p}/(1-\hat {p})$$ becomes large but, at the same time, the average forecast surprise $$\mathbb {E}(x|x>\tau )\rightarrow \mathbb {E}(x)=0$$. The two effects offset each other; a high forecast frequency, controlling for the forecast surprise, tends to indicate a higher cost. The frequency effect on the NP-cost estimator stands in contrast to the effect on the BBT estimator. This observation illustrates that a negative correlation between the NP-cost estimator and disclosure is not by construction but will hold under the assumptions of the theoretical model.

11
Einhorn (2007) develops a more general voluntary disclosure model, where the manager might either maximize or minimize the price at a cost if he decides to disclose. In equilibrium, low and high outcomes are disclosed, and intermediate earnings are never disclosed. However, this intermediate non-disclosure region does not appear to be consistent with the observed management forecasts.

12
The cost here is a personal cost, in line with the presentation used in the main analysis. The manager solely minimizes the perception of the price similarly to Einhorn (2007). However, we could also assume that the manager minimizes the total cash flows, i.e., subtracting the cost from price via a decrease in future earnings, and this alternative formulation would result in minor changes.

13
Note that this effect is not driven by small-sample deviations from asymptotic theory, as the asymptotic standard-error of the estimator increases when trying to estimate small costs as shown in Appendix A.

14
We select this period for two reasons. First, the implementation of Regulation Fair Disclosure (Reg. FD) in the United States closed private channels of communication to analysts and thus greatly increased the number of forecasting firms for reasons unrelated to disclosure costs. Second, in previous years, management forecasts were not systematically collected by the First Call Company Issued Guidance (CIG) database, but after 2003, the requirement by Sarbanes-Oxley to record transcripts of conference calls greatly improved forecast archives. Prior to 2003, many forecasts were made during unrecorded conference calls, thus leading to systematic omitted forecast data for smaller firms that are less likely to trigger follow-up press releases.

15
Because management forecasts of EPS are typically adjusted, we use the ratio of unadjusted to adjusted EPS to convert these forecasts to raw forecasts. Adjusted forecasts are problematic because, for firms that had stock splits, the variance of adjusted forecasts will decline over time. In cases of zero adjusted EPS (which can occur because earnings are zero or because of two-digit rounding given very large splits), we use the nearest available adjustment factor, thereby dropping observations that have no adjustment factor.

16
Since CIG reports adjusted EPS forecasts, we recover unadjusted forecasts using the adjustment factor, i.e., the ratio of unadjusted to adjusted EPS, to convert these forecasts to raw forecasts.

17
We can make no theoretical predictions about the correct variable to measure and scale surprises. For example, in the context of management earnings forecasts, one might use any variable capturing market change in expectations, such as short-window market response (Kasznik and Lev 1995), earnings per share (Cheong and Thomas 2011), or earnings surprise scaled by lagged assets or prices.

18
Li (2010) classifies MKTS into two categories as a measure of existing competition as well as potential rivals. Firms generating high sales may operate in environments where the number of existing rivals is larger, and they may avoid disclosing information that competitors might use to their advantage.

19
We define high litigation industries as those with SIC code 2833-2836, 8731-8734 (biotech), 3570-3577 (computer hardware), 3600-3674 (electronics), 7371-7379 (computer software), 5200-5961 (retail), 4812-4813, 4833, 4841, 4899 (communications), or 4911, 4922-4924, 4931, 4941 (utilities), as defined by Ajinkya et al. (2005).

20
While we conduct our analysis using both logit and OLS regressions, we tabulate the OLS regressions, because these are less sensitive to the inclusion of fixed effects compared to logit and with marginal effects that are simpler to interpret (Angrist and Pischke 2008).

21
Our results are qualitatively similar if the holdout period consists only of the firm-quarters in 2016.

22
The four-digit Standard Industrial Classification (SIC) codes used by government agencies to classify industry areas remain quite popular, but this is being supplemented by the six-digit North American Industry Classification System (NAICS) codes. The Global Industry Classifications Standard (GICS) system that has been jointly developed by Standard & Poor’s and Morgan Stanley Capital International (MSCI) is popular among financial practitioners, whereas the 48 Fama and French classification tends to be more popular in academic research.

23
Not all of the 48 industries are tabulated because some of them did not contain the minimum requirement of five firms.

24
In untabulated results, we examine the correlations between $$\hat {c}_{NPALT}$$ and the competition variables. This measure $$\hat {c}_{NPALT}$$ correlates with proxies capturing competition from potential rivals, with the exception of R&D. The evidence is more mixed with measures of existing competition. The alternative measure correlates positively with the HHI variable, whereas the correlation with NUM is insignificant. Lastly, the correlation is negative with CAPX, consistent with the existence of barriers to entry.

25
Federal laws govern insider trading in the United States, and several pieces of legislation concerning insider trading include the following: the Securities Act of 1933, the Securities and Exchange Act of 1934, and the Sarbanes-Oxley Act of 2002. On August 10, 2000, the Securities and Exchange Commission (SEC) adopted Rules 10b5-1 and 10b5-2 that clarify certain principles of insider trading while simultaneously announcing the adoption of Regulation FD (Fair Disclosure), which prohibits public companies from selectively disclosing information.

26
In untabulated tests, we also include lagged insider trading to control for unobservable factors that affect insider trading. The results are qualitatively similar.

27
In fact, this equation is exactly the same as in Jung and Kwon (1988), subtracting the cost from the disclosing firm price, i.e., changing τ into τc.

Literatur
Ajinkya, B., Bhojraj, S., Sengupta, P. (2005). The association between outside directors, institutional investors and the properties of management earnings forecasts. Journal of Accounting Research, 43(3), 343–376.
Angrist, J.D., & Pischke, J.S. (2008). Mostly harmless econometrics: an empiricist’s companion. Princeton: Princeton University Press.
Anilowski, C., Feng, M., Skinner, D.J. (2007). Does earnings guidance affect market returns? the nature and information content of aggregate earnings guidance. Journal of Accounting and Economics, 44(1), 36–63.
Armstrong, C.S., Core, J.E., Taylor, D.J., Verrecchia, R.E. (2011). When does information asymmetry affect the cost of capital? Journal of Accounting Research, 49(1), 1–40.
Berger, P.G. (2011). Challenges and opportunities in disclosure research - A discussion of the financial reporting environment: Review of the recent literature. Journal of Accounting and Economics, 51(1), 204–218.
Bertomeu, J., & Cheynel, E. (2018). PhD Notes, available at https://​sites.​google.​com/​site/​jeremybertomeu/​ph-d-course.
Bertomeu, J., Beyer, A., Taylor, D.J. (2016). From casual to causal inference in accounting research: the need for theoretical foundations. Foundations and Trends in Accounting, 10(2-4), 262–313.
Bertomeu, J., Ma, P., Marinovic, I. (2015a). How often do managers withhold information?. Stanford GSB Working Paper.
Bertomeu, J., Marinovic, I., Terry, S.J., Varas, F. (2015b). The dynamics of concealment: CEO Myopia and information withholding, Stanford GSB Working Paper.
Beyer, A., Cohen, D.A., Lys, T.Z., Walther, B.R. (2010). The financial reporting environment: Review of the recent literature. Journal of Accounting and Economics, 50(2-3), 296–343.
Botosan, C.A. (1997). Disclosure level and the cost of equity capital. The Accounting Review, 72(3), 323–349.
Bresnahan, T.F. (1989). Empirical studies of industries with market power. Handbook of Industrial Organization, 2, 1011–1057.
Caskey, J., Hughes, J., Liu, J. (2015). Strategic informed trades, diversification, and cost of capital. Accounting Review, 90(5), 1811–37.
Cheong, F.S., & Thomas, J. (2011). Why do EPS forecast error and dispersion not vary with scale? Implications for analyst and managerial behavior. Journal of Accounting Research, 49(2), 359–401.
Cheynel, E. (2013). A theory of voluntary disclosure and cost of capital. Review of Accounting Studies, 18(4), 987–1020.
Chung, K.H., McInish, T.H., Wood, R.A., Wyhowski, D.J. (1995). Production of information, information asymmetry, and the bid-ask spread: Empirical evidence from analysts’ forecasts. Journal of Banking & Finance, 19(6), 1025–1046.
Cotter, J., Tuna, I., Wysocki, P.D. (2006). Expectations management and beatable targets: How do analysts react to explicit earnings guidance?. Contemporary Accounting Research, 23(3), 593–624.
Darrough, M. (1993). Disclosure policy and competition: Cournot vs. Bertrand. The Accounting Review, 68(3), 534–561.
Darrough, M., & Stoughton, N.M. (1990). Financial disclosure policy in an entry game. Journal of Accounting and Economics, 12(1-3), 219–243.
Demsetz, H. (1968). The cost of transacting. The Quarterly Journal of Economics, 82(1), 33–53.
Diamond, D.W., & Verrecchia, R.E. (1991). Disclosure, liquidity, and the cost of capital. The Journal of Finance, 46(4), 1325–1359.
Dye, R.A. (1985). Disclosure of nonproprietary information. Journal of Accounting Research, 23(1), 123–145.
Dye, R.A. (1986). Proprietary and nonproprietary disclosures. Journal of Business, 59(2), 331–366.
Dye, R.A. (2001). An evaluation of ’essays on disclosure’ and the disclosure literature in accounting. Journal of Accounting and Economics, 32(1–3), 181–235.
Einhorn, E. (2007). Voluntary disclosure under uncertainty about the reporting objective. Journal of Accounting and Economics, 43(2-3), 245–274.
Einhorn, E., & Ziv, A. (2008). Intertemporal dynamics of corporate voluntary disclosures. Journal of Accounting Research, 46(3), 567–589.
Gaver, J.J., & Gaver, K.M. (1993). Additional evidence on the association between the investment opportunity set and corporate financing, dividend, and compensation policies. Journal of Accounting and Economics, 16(1), 125–160.
Hughes, J., Liu, J., Liu, J. (2009). On the relation between expected returns and implied cost of capital. Review of Accounting Studies, 14(2-3), 246–259.
Jensen, M.C. (1986). Agency costs of free cash flow, corporate finance, and takeovers. The American Economic Review, 76(2), 323–329.
Jensen, M.C., & Meckling, W.H. (1976). Theory of the firm: Managerial behavior, agency costs and ownership structure. Journal of Financial Economics, 3(4), 305–360.
Jung, W.-O., & Kwon, Y.K. (1988). Disclosure when the market is unsure of information endowment of managers. Journal of Accounting Research, 26(1), 146–153.
Kasznik, R., & Lev, B. (1995). To warn or not to warn: Management disclosures in the face of an earnings surprise. The Accounting Review, 70(1), 113–134.
Lang, M., & Lundholm, R. (1993). Cross-sectional determinants of analyst ratings of corporate disclosures. Journal of Accounting Research, 31(2), 246–271.
Lang, M., & Sul, E. (2014). Linking industry concentration to proprietary costs and disclosure: Challenges and opportunities. Journal of Accounting and Economics, 58(2), 265–274.
Lang, M.H., & Lundholm, R.J. (1996). Corporate disclosure policy and analyst behavior. The Accounting Review, 71(4), 467–492.
Li, F., Lundholm, R., Minnis, M. (2013). A measure of competition based on 10-K filings. Journal of Accounting Research, 51(2), 399–436.
Li, X. (2010). The impacts of product market competition on the quantity and quality of voluntary disclosures. Review of Accounting Studies, 15(3), 663–711.
Liang, P.J., & Wen, X. (2007). Accounting measurement basis, market mispricing, and firm investment efficiency. Journal of Accounting Research, 45(1), 155–197.
Milgrom, P.R. (1981). Good news and bad news: Representation theorems and applications. Bell Journal of Economics, 12(2), 380–391.
Rogers, J., & Van Buskirk, A. (2009). Bundled forecasts and selective disclosure of good news. Unpublished paper available at http://​papers.​ssrn.​com/​sol3/​papers.​cfm.
Shaked, A., & Sutton, J. (1987). Product differentiation and industrial structure. The Journal of Industrial Economics, 36(2), 131–146.
Skinner, D.J. (1994). Why firms voluntarily disclose bad news. Journal of Accounting Research, 32(1), 38–60.
Skinner, D.J. (1997). Earnings disclosures and stockholder lawsuits. Journal of Accounting and Economics, 23(3), 249–282.
Soffer, L.C., Thiagarajan, S.R., Walther, B.R. (2000). Earnings preannouncement strategies. Review of Accounting Studies, 5(1), 5–26.
Stocken, P.C., & Verrecchia, R.E. (2004). Financial reporting system choice and disclosure management. The Accounting Review, 79(4), 1181–1203.
Sutton, J. (1991). Sunk costs and market structure: price competition, advertising, and the evolution of concentration. Cambridge: MIT Press.
Verrecchia, R.E. (1983). Discretionary disclosure. Journal of Accounting and Economics, 5(1), 179–194.
Verrecchia, R.E. (1990). Information quality and discretionary disclosure. Journal of Accounting and Economics, 12(4), 365–380.
Verrecchia, R.E. (2001). Essays on disclosure. Journal of Accounting and Economics, 32(1-3), 97–180.
Yohn, T.L. (1998). Information asymmetry around earnings announcements. Review of Quantitative Finance and Accounting, 11(2), 165–182.
Zhou, F. (2016). Disclosure dynamics and investor learning. Working paper.
Titel
A simple structural estimator of disclosure costs
verfasst von
E. Cheynel
M. Liu-Watts
Publikationsdatum
14.01.2020
Verlag
Springer US
Erschienen in
Review of Accounting Studies / Ausgabe 1/2020
Print ISSN: 1380-6653
Elektronische ISSN: 1573-7136
DOI
https://doi.org/10.1007/s11142-019-09511-1

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