As companies continue their XBRL filings and move into the detail level of filing (tagging) and as the SEC’s modified liability provisions on XBRL (Extensible Business Reporting Language) data begin to expire, public companies are looking for accuracy, efficiencies and value in the process.
On December 13th, the SEC recently published their fourth summary of staff observations for XBRL filings. The SEC noted that they “continue to see the same issues around the topics of formatting of the financial statements, negative values, use of unnecessary extensions, and the completeness of the tagging (i.e., parentheticals and string values).”
As continued compliance is necessary and the enhancement of supporting processes is needed, we recommend some key actions as reminders:
- Re-evaluate the priority of XBRL with the changes in the modified liability provisions.
- Walkthrough the process with a fresh perspective, especially as a move to the new taxonomy (2011 vs. 2009) is planned, to identify inefficiencies and additional points for critical review prior to filing.
- Re-evaluate the use of a third party and the potential cost / benefit of providing analysis in-house, with a focus on final filing accuracy as well as efficiencies earlier in the process.
- Enhance training related to the EDGAR filing manual.
- Re-assess your filing group (this may alter the detail tagging requirement).
- Remain current on XBRL through:
As a reminder, the SEC final rules include modified liability provision guidance in section 232.406T which states: "(d) Temporary section. Section 232.406T is a temporary section that applies to an Interactive Data File submitted to the Commission less than 24 months after the electronic filer first was required to submit an Interactive Data File to the Commission pursuant to § 232.405, not taking into account any grace period, but no later than October 31, 2014.“ Also, footnote 231 of the final rule provides additional guidance: "For example, a large accelerated filer first required to submit interactive data for financial statements in a Form 10-Q for the fiscal period ended June 30, 2009, would be required to submit the interactive data by 30 days after the Form 10-Q's August 10, 2009 due date but its 24-month period would end August 10, 2011”.
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