The SEC published a rule proposal seeking to modernize the nature, timing, scope and applicability of disclosure requirements in Industry Guide 3 for bank holding companies. We strongly support the use of structured data in these modernization efforts. Expanding the use of standards for the reporting of financial disclosures that are not yet required in structured, standardized format will vastly improve the usability and value of this information.
The letter also points out that bank holding companies would benefit from a collaboration between the SEC and the FDIC to share taxonomy elements that are used for both FDIC and SEC reporting. A single taxonomy could be created to contain these data fields and referenced (and the data elements used) by bank holding companies. This would facilitate XBRL tagging by bank holding companies as they could easily identify needed elements. A single referenceable taxonomy for these jointly used elements would ensure that updates to reporting requirements are coordinated between both agencies.
An alignment of FDIC and SEC reporting requirements for bank holding companies is an initial step towards much greater efficiency and streamlining for U.S. regulators and the reporting entities they oversee: an agency-wide, collaborative implementation of data standards to reduce costs and enable automation. Streamlining regulatory reporting in this fashion would reduce the burden on all reporting entities and would allow government agencies to significantly cut the costs of data collection. XBRL US published a position paper explaining this proposal: Reduce Company Burden, Cut Government Spending – Standardize Financial Data Reporting Requirements
