Posted on Tuesday, September 29, 2020

XBRL US submitted a comment letter to the SEC responding to their proposal, Reporting Threshold for Investment Managers. The proposal seeks to revise the disclosure requirement thresholds for investment managers filing Form 13F data to increase the reporting threshold from $100 million where it is today, to $3.5 billion.

Today, 13F data is submitted to the Commission in structured format, using a custom XML schema. The proposal also asks if there should be any other amendments that should be considered to reduce the burden on investment managers, including permitting managers to provide other identifiers in lieu of a CUSIP for each security.

Recommendations made in the XBRL US letter:

“While we support the Commission goal of reducing the burden on reporting entities, we do not believe that eliminating disclosures made by smaller reporting entities is an appropriate approach. Numerous stakeholders, as the Commission points out in the proposal, rely on this data including regulators, investors, the media, public companies, and other types of researchers. The value of this data has only grown over time and 13F data has become an expected resource. The Commission has received an overwhelming number of responses to this proposal, the majority of which do not support the move to raise the threshold.

 There are, however, alternate approaches to reduce the burden on reporting entities. First, we recommend that the Commission require the use of an open, nonproprietary securities identifier, such as the Financial Instrument Global Identifier (FIGI) instead of the CUSIP, to reduce the financial burden on investment managers imposed by the requirement to use proprietary, costly identifiers. Second, we ask that the Commission consider adopting XBRL-CSV as a replacement to the current custom XML schema reporting requirements.”

Read the comment: XBRL US Comment – Reporting Threshold for 13F Filers – File Number S7-08-20