Posted on Friday, April 2, 2021

The Securities and Exchange Commission (SEC) announced the adoption of interim final amendments to Forms 20-F, 40-F, 10-K, and N-CSR to implement disclosure and submission requirements of the Holding Foreign Companies Accountable Act (HCFA) Act. The interim final amendments apply to:

…registrants that the Securities and Exchange Commission identifies as having filed an annual report with an audit report issued by a registered public accounting firm that is located in a foreign jurisdiction and that the Public Company Accounting Oversight Board is unable to inspect or investigate completely because of a position taken by an authority in that jurisdiction.” 

Registrants that fall into this category are required to submit certain documentation to the Commission. The interim final rule requests comments by May 2, 2021. Among other questions posed, the Commission asks if the required disclosures should be tagged in Inline XBRL format or in another structured format. XBRL US will likely submit a comment letter. Anyone interested in participating in the letter preparation, please email me directly as we arrange a member call to discuss.