Posted on Monday, May 6, 2024

XBRL US submitted a comment letter to the Securities and Exchange Commission (SEC) to provide input to the Submission for OMB Review: Comment Request Extension: Rule 17g-3 Annual financial and other reports to be filed or furnished by nationally recognized statistical rating organizations. The XBRL US encouraged the SEC to require that these documents be prepared in Inline XBRL format to align with requirements of the Financial Data Transparency Act (FDTA), to leverage the experience that NRSROs already have with XBRL preparation of credit ratings actions, and most importantly, to generate the reported data in structured, machine-readable format. XBRL US also encouraged the SEC to require reporting entities to obtain and use the Legal Entity Identifier for NRSRO reporting.

In addition, XBRL US went on to recommend that the SEC make these changes:

  • Related to Rule 17g-7:
    • Change requirements for XBRL preparation of credit rating actions from XBRL-XML to XBRL-CSV, which is more appropriate to high volume data such as credit rating actions. This transition will make it easier for NRSROs to prepare, and easier for data users to extract the data reported.
    • Require credit rating action data to be submitted through the SEC EDGAR System rather than posted to the company website which is the current requirement. EDGAR submission will give data users a full history of submissions, ensure that the filer cannot modify the data, and will make it significantly easier for data users to find and extract the data.
    • Reduce the embargo period on credit rating submissions to 30 days.
  • Related to Rule 17g-1:
    • Require Form NRSRO to be prepared in XBRL-CSV format, in particular exhibits such as Exhibit 1 which contains high volume transition matrices.

Read the letter: XBRL US Comment RE Rule 17g-3

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