Proprietary Costs and Disclosure Substitution: Theory and Empirical Evidence

Abstract

This study develops and tests a simple model of voluntary disclosure where managers can choose to withhold (i.e., redact) information from mandatory disclosure. We consider a setting where mandatory disclosure is a disaggregated disclosure (e.g., a financial statement), voluntary disclosure is an aggregate disclosure (e.g., an earnings forecast), and the costs of each type of disclosure are distinct. In this setting, we show that concerns about the proprietary cost of mandatory disclosure motivate managers to withhold information from mandatory disclosure and substitute voluntary disclosure. We test our predictions using a comprehensive sample of mandatory disclosures where the SEC allows the firm to redact information that would otherwise jeopardize its competitive position. Consistent with our predictions, we find strong evidence that redacted mandatory disclosure is associated with greater voluntary disclosure.