客户年报问询函监管具有供应链传导效应吗——基于审计收费视角的研究

Does Customer’s Annual Report Inquiry Letter Have a Supply Chain Conduction Effect?Evidence from Audit Fees

年报问询函在供应链上可能既发挥信号传递效应,也存在监管溢出效应。本文利用我国供应商企业前五名上市客户及其年报问询函的相关数据,实证检验了客户收到年报问询函对供应商审计收费的影响。结果发现,客户被问询这一负面冲击在供应链中主要表现出了监管溢出效应,即客户被问询会使供应商也面临更大的监管压力并提高信息披露质量,从而降低了外部审计师所感知的审计风险水平,最终导致供应商的审计收费显著下降。同时,年报问询函具体内容和回函特征也会对其监管溢出效应产生差异性影响。进一步研究发现,上述监管溢出效应在供应商为头部企业或国企(尤其是央企)、供应商所处外部治理环境越完善、供应商和客户之间的关系越紧密、客户重要性越高时更加明显。本文从供应链角度拓展了年报问询函监管溢出效果的研究,同时丰富了供应链关系对企业行为影响的研究。

In the transformation of capital market regulation,the Shanghai and Shenzhen Stock Exchanges actively responded to the requirements of the 19th National Congress for“innovative regulatory methods”and began implementing the annual report inquiry letter system to strengthen post supervision of listed companies.Unlike traditional penalty supervision,which has a certain degree of time lag,the annual report inquiry letter system allows the Shanghai and Shenzhen Stock Exchanges to send letters of warning to potential but not yet deteriorating information disclosure issues of listed companies,and timely require listed companies to improve or correct their original information.Previous studies have revealed the governance effect of annual report inquiry letters on receiving companies from various aspects such as the quality of information disclosure and the degree of tax avoidance.However,due to the limited regulatory resources,the purpose of regulation is not only to punish violators,but more importantly,to make an example of others.Therefore,it is of great significance to explore whether the annual report inquiry letter will have further regulatory spillover effects.Some scholars have studied the spillover effects of annual report inquiry letters among enterprises in the same industry and region,but they have not delved into the supply chain network.The supply chain is an economic link that closely connects upstream and downstream enterprises,and the enterprises in the supply chain will have a significant impact on each other’s business management decisions.The negative event of a customer receiving an annual report inquiry letter will affect the external judgment of the supplier’s risk level in two completely opposite aspects.On the one hand,the customer receiving an annual report inquiry letter will release a signal to the outside world that the upstream supplier’s future business uncertainty is high and the business risk is high.This means the annual report inquiry letter may play a signaling effect in the supply chain.On the other hand,customers receiving annual report inquiry letters will expose their suppliers more to the attention of regulatory agencies and other capital market participants,forcing their suppliers to restrain their non compliant information disclosure behavior and reduce the potential risk level of suppliers.This means that annual report inquiry letters may have regulatory spillover effects in the supply chain.Owing to the fact that external auditors can more accurately identify the risk changes of the audited entity caused by customer inquiries,and use them as the decision-making basis for audit fees,this paper examines the conduction effect of annual report inquiry letters among supply chain enterprises from the perspective of audit fees.This paper uses the top five publicly disclosed customer related information of listed companies from 2015 to 2019 and matches it with the issuance of annual report inquiry letters by Shanghai and Shenzhen Stock Exchanges to empirically test the impact of customers receiving annual report inquiry letters on supplier audit fees.The main conclusions of this paper are as follows.(1)After customers receive the annual report inquiry letters,the audit fees of suppliers will significantly decrease.This result supports the regulatory spillover effect of annual report inquiry letters on the supply chain,rather than the signaling effect.At the same time,this conclusion remains valid after a series of robustness tests and endogeneity tests.(2)The specific content and response characteristics of the annual report inquiry letter will also have a differential impact on the regulatory spillover effect of the annual report inquiry letter.Specifically,when customers receive annual report inquiry letters involving upstream transactions,malicious violations,earnings information and performance changes,related party transactions,as well as delayed responses from customers,shorter response lengths,and lower readability of response letters,the regulatory spillover effect of annual report inquiry letters on the supply chain is more significant.(3)External auditors mainly reduce audit fees by reducing risk premium claims,rather than reducing audit devotion.(4)The regulatory spillover effect of the annual report inquiry letter is more significant when the supplier is a top enterprise or state-owned enterprise(especially a central enterprise),the external governance environment where the supplier is located is better,the supplier and customer relationship is closer,and the customer is more important.(5)The regulatory spillover effect of the annual report inquiry letter will also affect secondary suppliers,but the effect will be weakened.The main contributions of this paper are as follows Firstly,this article provides new empirical evidence from the supply chain perspective for the regulatory spillover effect of annual report inquiry letters.This paper reveals that annual report inquiry letters can play a governance role on entities that have not received the annual report inquiry letter in the supply chain network,providing strong support for the effectiveness of the annual report inquiry letter system.Secondly,this article expands the relevant research on the impact of customers being exposed with negative information on suppliers in cross enterprise situations.Previous studies have examined this issue from multiple perspectives,such as customers falling into financial difficulties,financial fraud,and business performance not meeting expectations.This paper explores whether and how suppliers respond to the adverse impact of customer inquiries from the perspective of the annual report inquiry letter,a non punitive regulatory measure,and provides an important supplement to this literature.Thirdly,this paper enriches the relevant literature on the factors influencing audit fees.Previous studies have found that customer concentration,nature of customer property rights,negative tone of customer annual reports,geographic distance of customers,and supplier/customer relationship based transactions all have a impact on audit fees.This paper find that after customers receive the annual report inquiry letters,the audit fees of suppliers will significantly decrease.This makes a certain incremental contribution to audit pricing theory.Fourthly,the research conclusion of this paper provides a theoretical basis for guiding Shanghai and Shenzhen Stock Exchanges to reasonably allocate regulatory resources and strengthen the effectiveness of frontline supervision.It is not only advantageous for“improving the financial regulatory system and maintaining the bottom line of avoiding systemic financial risks”proposed in the report of the 19th National Congress of the Communist Party of China,but also beneficial for“enhancing the independent and controllable ability of the industrial chain supply chain”proposed at the 2020 Central Economic Work Conference.