On December 20, 2017, XBRL US submitted a comment letter in response to the Securities and Exchange Commission proposal FAST Act Modernization and Simplification of Regulation S-K. Key recommendations made in the letter include:
- Require the use of the LEI for those registrants that currently maintain an LEI. Require the LEI to be tagged using Inline XBRL to enable automation.
- Establish a roadmap to full adoption of the LEI for all public companies.
- Help issuers understand the value of the LEI for themselves and their stakeholders through educational programs.
- Consider other identifiers such as securities identifiers linked to the LEI; and an LEI that represents individuals.
- Require structured data standards for cover pages. Require Inline XBRL specification (or conventional XBRL if Inline XBRL has not yet been adopted by the Commission).
- Educate issuers on how tagged cover page data will be used by corporate stakeholders.
- Require tagging of cover pages for Form 6-K in addition to other filings.
- Consider requiring the tagging of other corporate disclosures such as entire Form 8-Ks that contain financial data, e.g., earnings announcements, as well as the MD&A, proxy statement and risk factor sections.