Consequences of Ethical and Audit Violations: Evidence from the PCAOB Settled Disciplinary Orders

We investigate the justifications provided by the Public Company Accounting Oversight Board (PCAOB) when sanctioning audit firms and individual auditors, as disclosed in the publicly released Settled Disciplinary Orders (SDOs). Employing responsive regulation theory, we seek to gain an understanding of violating behaviors by audit firms and individual auditors that attract regulatory responses ranging in nature from persuasive to punitive sanctions. Using 298 SDOs issued by the PCAOB from 2005 to 2020, we find that the frequency and severity of PCAOB sanctions at the firm level are positively associated with auditing standards violations, independence issues, and reckless behavior. At the individual auditor level, integrity violations and reckless behavior are positively associated with the frequency and severity of PCAOB sanctions. Our findings indicate that significantly higher financial penalties for individual auditors (audit firms) arise from manipulation of audit evidence (quality control criticisms). Further, the PCAOB financially penalizes Big 4-affiliated auditors and firms significantly more than their non-Big 4 counterparts. Other factors such as multiple individuals being implicated in an SDO and whether a firm and individual(s) are both implicated in the SDO are important considerations in sanction(s) imposed by the PCAOB. Overall, our findings suggest that the PCAOB adopts a responsive enforcement strategy when monitoring the auditors in their ethical and audit compliance efforts.