Posted on Friday, July 1, 2016
Read the full letter

In response to the SEC’s Concept Release on disclosures in Reg S-K, the SEC Investor Advisory Committee submitted a comment letter where data standards are very positively referenced. Highlights from the letter:

Leveraging Technology. The Commission is in the process of developing a second generation for the Electronic Data Gathering, Analysis and Retrieval system (EDGAR). Proposed changes should be judged on the basis of whether they optimally leverage or enhance EDGAR’s usability to investors. Data tagging, improved search functions, document dissemination, use of hyperlinks as cross-references, and incorporation of material from issuer websites are all areas worthy of focus.

Manner of Information Delivery. In this age of enhanced technology, we believe that any consideration of disclosure effectiveness must include consideration of the method of delivery to the Commission and the ability of investors to retrieve the filed information. We believe that all information filed with the Commission should be provided in a machine readable interactive format.

More needs to be done both in the short and long term to ensure that information filed in periodic reports (and proxy statements) is delivered to the SEC in a structured format. We strongly urge the Division to accelerate the development and implementation of Inline XBRL so that filers may file only a single document with the required tagged data. In addition, however, as the IAC recommended in 2013, the Commission should create a “plan to convert information filed with the SEC into tagged data.” …

In addition, however, the Division, as part of disclosure effectiveness, should take steps to increase the quality of the data filed with the SEC. 


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