Summary and Conclusion
The results that we discuss below are, of course, subject to limitations common with most experimental behavioral studies[14]. Notwithstanding these typical limitations, our results strongly show that internal auditors will be less likely to evaluate a pervasive control deficiency related to tone at the top as a material weakness than a process-specific control deficiency. Our pervasive control deficiency – reflective of tone by top management – can have significant implications on ICFR throughout the company. Not evaluating this deficiency as a material weakness may result in providing inaccurate internal information about internal control quality. In reviewing the results related to the pervasive internal control deficiency, it is important to recall that we selected one specific pervasive internal control deficiency – management tone at the top related to the importance of internal controls. The results may be driven by our choice of the pervasive internal control deficiency. Potentially, internal auditors may perceive internal controls related to tone at top as less important than other pervasive controls (e.g. management override controls, an effective whistleblower program, hiring practices related to hiring competent financial reporting employees). Thus, if we had selected an alternative pervasive control, our results may have differed. We recognize that this is an empirical question and therefore suggest future research related to this issue.
Our results, coupled with archival analysis, cause us to question whether pervasive material weaknesses related to tone at the top are being under-reported. Analyses provided by Audit Analytics (2016a, 2016b) note that it is rare for pervasive tone at the top deficiencies to be reported as material weaknesses. Is this finding due to the fact that such material weaknesses are rare or that there is a bias against reporting such material weaknesses? Do standard setters and regulators not expect an inappropriate tone about the importance of controls to be classified as a material weakness?