The Securities and Exchange Commission (SEC) Division of Economic and Risk Analysis evaluated the tagging of Business Development Company (BDC) Schedules of Investments and identified certain common tagging issues:
- Inappropriate tagging of subtotals of investments by industry or by investment type with Investment, Identifier [Axis]. These subtotals should be tagged using dimensions Industry Sector [Axis] or Investment Type [Axis].
- Tagged data that did not include the issuer affiliation information at the investment level.
- When tagging open interest rate swap contracts, inappropriate use of the Derivative Instrument Risk [Axis] or Investment, Identifier [Axis]. Filers should use Open Swap Contract, Identifier [Axis] instead.
- When tagging the amount of “Liabilities in excess of other assets”, inappropriate creation of a custom element or tagging the data with Investment Owned, Fair Value along with dimension Investment, Identifier [Axis]. Filers should use the standard Noninvestment Assets Less Noninvestment Liabilities element instead.
The Commission noted that “The SOI contains valuable information about a BDC’s investment portfolio. It is essential that the data are tagged accurately and consistently across different BDCs. Staff Interpretations and FAQs Related to Interactive Data Disclosure Question F.7 (updated) provides general guidance on the tagging requirements of the SOI. Financial Accounting Standards Board’s Generally Accepted Accounting Principles Taxonomy Implementation Guide Series – Financial Services – Investment Companies (Including SEC S-X Schedules for Business Development Companies) provides examples of the modeling for reporting by investment companies, including the SOI. Filers are encouraged to review their tagging of the SOI and make necessary corrections.”
Read their announcement.
