Issued: June 29, 2012
Impact: All US GAAP

Issue

A large proportion of filer time is spent removing and adding elements between 10-Q and 10-K filings. A number of advisors are recommending that unused elements and disclosure groups be removed when not in use in a filing. In subsequent filings, such as the 10-K, these removed elements should be added back.

A number of commenters have pointed out that this effort may be unnecessary as it provides limited value to consumers of the data.

Recommendation

The Securities and Exchange Commission does not require the company to create different company extensions for 10-K and 10-Q filings if the reason for the change is to accommodate filing a different document type. Elements do not need to be removed from the presentation if no fact values are reported in the filing for the specific filing period. However, this is at the discretion of the filer and they can remove and add items to their extension taxonomies between filings.

However, a company should remove elements, relationships and extended link roles that it no longer expects to use in future disclosures. In addition, if extension items are replaced by US GAAP taxonomy items, old extension items and relationships should be removed from schema and linkbases.

In addition, the company should comply with the requirements of EFM 6.13.3 in relation to the actual facts reported, i.e., if the facts are reported in a different order and/or indentation in the 10-K and 10-Q, then the taxonomy extension should be amended between filings.

In the case where the companies have a disclosure in the 10-K that does not exist in the 10-Q, then relationships can remain but no facts should be disclosed.