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Auditor independence and non-audit services - ICAEW

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characteristics of clients who seek NAS, or it may be <strong>audit</strong>ors seeking to extract feepremia beyond the additional effort required. While the former is unlikely tocompromise <strong>independence</strong>, the latter is.Using data from 336 bids, it is found that the firm plans more effort for clientspurchasing additional <strong>services</strong>. There is no evidence that NAS clients have additionalproblems (i.e., are systematically riskier) that might lead the firm to plan more effortor seek a higher fee. There is, however, evidence of greater use of industry experts,which may imply the assignment of engagement personnel who can better integratethe multiple <strong>services</strong> provided. The firm proposes a small but significant fee premiumafter controlling for the incremental effort, however an analysis of accepted versusrejected bids shows that this fee premium is bid away in the market.Johnstone <strong>and</strong> Bedard’s explanation for these results is that the firm sees thepossibility of increased quality through synergy across <strong>services</strong> <strong>and</strong> sets bid pricesaccordingly. They conclude that the incremental effort applied, use of more industryspecialists <strong>and</strong> attempts to charge a fee premium (<strong>and</strong> not a discount) are inconsistentwith the SEC’s concerns regarding the impact of joint NAS provision on <strong>audit</strong> quality.8.6 LowballingMany studies consider the impact of an <strong>audit</strong>or change on <strong>audit</strong> fees. The reductionthat is normally observed 24 is considered potentially undesirable insofar as it maysignal that the fee charged is below cost. This is felt to undermine <strong>audit</strong> quality in thelong-run. Various terms have been used in relation to fee reductions associated with<strong>audit</strong>or changes: ‘lowballing’, ‘predatory pricing’, <strong>and</strong> ‘fee discounting’. In thepresence of joint service provision, the concern is that there is cross-subsidisation,with <strong>audit</strong> being a loss-leader.Regression studies of <strong>audit</strong> pricing in initial engagements do not all consider theimpact of NAS provision by the <strong>audit</strong>or. Of the studies included in footnote 24, onlyTurpen (1990) includes NAS fees as a control variable in estimating a model of <strong>audit</strong>fees for initial engagements, finding a positive relationship. In other words, initial<strong>audit</strong> fees are higher in the presence of NAS provision by the <strong>audit</strong>or.In the UK, McMeeking (2001) considers the association between <strong>audit</strong> <strong>and</strong> <strong>non</strong>-<strong>audit</strong>fees following a change of <strong>audit</strong>or. The model simultaneously tests for evidence of feecutting, cross-subsidisation, loss leader pricing <strong>and</strong> knowledge spillovers. Using datafrom 1992-1995 for the top 350 listed companies, he finds that changes in <strong>audit</strong> feesare negatively associated with the change in <strong>non</strong>-<strong>audit</strong> fees conditional on a change of<strong>audit</strong>or dummy variable. Although the coefficients on these variables are notstatistically different from zero, McMeeking interprets this finding as indicative thatboth <strong>audit</strong> <strong>and</strong> <strong>non</strong>-<strong>audit</strong> fees are cut following a switch.23 Archival research is research based on publicly available data.24 See, for example, Simon <strong>and</strong> Francis (1988), who observe an average price cut of 24%; Turpen(1990) who observes an average price cut of 19%; Ettredge <strong>and</strong> Greenberg (1990), who observe anaverage price cut of 25%; Gregory <strong>and</strong> Collier (1996) (a UK study), who observe an average price cutof 22%; <strong>and</strong> Craswell <strong>and</strong> Francis (1999), who observe an average price cut of 30% from <strong>non</strong>-Big 8 toBig 8 <strong>audit</strong>ors.51

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