IPO Firms’ Voluntary Compliance with SOX 404 as Evidence on the Value Relevance of Internal Control Quality

Newly public firms are not required to comply with SOX 404 for their initial public offerings. This provides a unique setting in which to investigate the benefits of voluntary disclosure with SOX 404 and the value of information revealed as a consequence of compliance. We investigate whether voluntary compliance with SOX 404, either fully or partially, impacts the perceived risk of firms conducting IPOs on the first day of trading (reflected in underpricing) or following the IPO. Our results indicate that neither full compliance with SOX 404 at the time of the IPO, nor a managerial discussion of internal controls prior to the IPO, result in lower underpricing or higher post-IPO performance. This suggests that the costs incurred through the SOX 404 compliance process may be unnecessary. Indirectly, our results provide additional evidence that some of the requirements of SOX extract costs from shareholders without supporting better quality information.