The Federal Deposit Insurance Corporation Improvement Act (FDICIA) of 1991 was designed, among other things, to introduce risk-based deposit insurance, increase capital requirements, and improve banks' internal controls. Of particular interest in this study are the requirements for annual audit...

We examine the unintended consequences of the 2005 increase in the asset threshold for FDICIA internal control reporting requirements from $500 million to $1 billion. We focus on a test sample of banks that grew from between $100 million to $500 million in assets prior to the change in...