Rule ID: General feedback for US GAAP -
this public exposure version was available for comment until
September 14, 2015.
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I have created a set of 51 fundamental accounting concepts and 22 or so relations between those concepts and currently about 98.9% of all XBRL-based public company financial filings are consistent with those rules. About 1.1% are not consistent. I would encourage that these rules be included in the consistency checks you are creating. While these rule are basic, they are foundation and reveal important relationship characteristics. I would be happy to explain these fundamental accounting concepts and relations. These fundamental accounting concepts and relations takes into consider the different styles which which economic entities. A summary of this information can be found here:
http://www.xbrlsite.com/2015/fro/us-gaap/html/ReportFrames/
Charlie
This is a summary of rules that tend to be applicable to 100% of reporting entities:
Equity = Equity Attributable to Parent + Equity Attributable to Noncontrolling Interest
Assets = Liabilities and Equity
Assets = Current Assets + Noncurrent Assets (classified balance sheet)
Liabilities = Current Liabilities + Noncurrent Liabilities (classified balance sheet)
Liabilities and Equity = Liabilities + Commitments and Contingencies + Temporary Equity + Redeemable Noncontrolling Interest + Equity
Noncurrent Liabilities = Liabilities – Current Liabilities (classified balance sheet)
Gross Profit = Revenues – Cost Of Revenue
Operating Income (Loss) = Gross Profit – Operating Expenses + Other Operating Income (Expenses)
Income (Loss) from Continuing Operations Before Equity Method Investments = Operating Income (Loss) + Nonoperating Income (Loss) – Interest And Debt Expense
Income (Loss) from Continuing Operations Before Tax = Income (Loss) from Continuing Operations Before Equity Method Investments + Income (Loss) from Equity Method Investments
Income (Loss) from Continuing Operations after Tax = Income (Loss) from Continuing Operations Before Tax – Income Tax Expense (Benefit)
Net Income (Loss) = Income (Loss) from Continuing Operations After Tax + Income (Loss) from Discontinued Operations, Net of Tax + Extraordinary Items, Gain (Loss)
Net Income (Loss) = Net Income (Loss) Attributable to Parent + Net Income (Loss) Attributable to Noncontrolling Interest
Net Income (Loss) Available to Common Stockholders, Basic = Net Income (Loss) Attributable to Parent – Preferred Stock Dividends and Other Adjustments
Comprehensive Income (Loss) = Comprehensive Income (Loss) Attributable to Parent + Comprehensive Income (Loss) Attributable to Noncontrolling Interest
Comprehensive Income (Loss) = Net Income (Loss) + Other Comprehensive Income (Loss)
Net Cash Flow = Net Cash Flows, Operating + Net Cash Flows, Investing + Net Cash Flows, Financing + Exchange Gains (Losses)
Net Cash Flows, Continuing = Net Cash Flows, Operating, Continuing + Net Cash Flows, Investing, Continuing + Net Cash Flows, Financing, Continuing
Net Cash Flows, Discontinued = Net Cash Flows, Operating, Discontinued + Net Cash Flows, Investing, Discontinued + Net Cash Flows, Financing, Discontinued
Net Cash Flows, Operating = Net Cash Flows, Operating, Continuing + Net Cash Flows, Operating, Discontinued
Net Cash Flows, Investing = Net Cash Flows, Investing, Continuing + Net Cash Flows, Investing, Discontinued
Net Cash Flows, Financing = Net Cash Flows, Financing, Continuing + Net Cash Flows, Financing, Discontinued
While some rules are definitely global and global rules are provided for, there is also a need to be able to patrician rules into groups. For example, some of the fundamental accounting concept rules are different for different economic entities. A specific example is how an economic entity reports “Income (loss) from equity method investments”. Some economic entities report this line item before tax, others include the line item within the tax section, others include it after tax in the special reporting items section, and other reporting entities use other allowed alternatives. As such, some method is necessary to group which rules apply to which type of entities.
• Disclosure Quality – We are concerned that certain recommended guidance and validation rules may result in less accurate disclosures. For example, certain amounts in our consolidated financial statements and associated notes may not add due to rounding and we disclose this prominently. Percentages have been calculated using unrounded amounts. We believe this is the most accurate disclosure as we do not adjust (“plug”) accurate amounts (full precision) for rounded numbers (less than full precision) to foot and cross-foot. Some of the rules recommended by the Committee require rounded numbers to foot and cross-foot. This can only be accomplished in practice by adjusting (“plugging”) the rounded numbers; thus, deviating from a more accurate disclosure. We recommend that the Committee reconsider, where applicable, the proposed guidance and validation rules and make sure that the rules always allow for a most accurate disclosure on the consolidated financial statements and associated notes without any of the recommended validation rules generating a false exception.
• Preparer Representation on the Data Quality Committee – We recognize that the recommended rules affect us as a large accelerated SEC filer as well as other SEC filers. However, we conclude from your Members list and the August 26 Data Quality Meeting that representation of SEC filers is missing. Because of the importance of this initiative, we strongly suggest that the Data Quality Committee include members of the preparer community and, in fact, we would be interested in becoming a member of the Committee to make sure that the filers’ SEC filing expertise, opinion and practical experience is taken into consideration when drafting proposed guidance and validation rules for public exposure and review.
• XBRL Linkbases – We noticed that the Data Quality Committee does not refer to existing XBRL linkbases for implementing the proposed validation rules, such as the Calculation linkbase and the Formula linkbase. We believe that new rules should be implemented using the existing XBRL linkbases for which specifications are already available. We would oppose including validation rules in a different environment than the Calculation linkbase and the Formula linkbase especially since the capabilities of the Formula linkbase have not yet been exhausted within the US GAAP Taxonomy. We urge the Committee to comply with these existing specifications.
• XBRL Processing Engines – The Data Quality Committee refers to Arelle as an XBRL processor to create a deployment environment. Arelle is one of the XBRL processing engines available to filers. We request that the Committee lists the technical specifications for XBRL engines to process the recommended rules.
Attachment Pfizer-Public-Exposure-of-Guidance-and-Validation-Rules.pdf