XBRL US submitted a comment letter to the SEC responding to their proposal, Administration of the EDGAR System. The proposal sought feedback on SEC actions that may be taken to promote the reliability and integrity of EDGAR submissions. They named triggering events that could result in SEC actions such as redacting information from a filing, removal or prevention of submission or dissemination of a filing, suspension of EDGAR access codes or reassignment of the filing date for a delayed submission.
In our letter, we strongly encouraged the Commission to notify the filer and relevant persons in advance before taking action, and to always include the issuer’s vendor as a “relevant person”.
We made the following additional recommendations beyond the questions raised in the proposal:
- Allow vendor access to a testing environment prior to EFM updates. Access to a “sandbox environment”, to allow for robust testing for at least a week before an EFM update goes into effect, can help to identify potential issues that can be corrected before the system goes live.
- Improve communication channels with vendors and issuers. Scheduled or unscheduled maintenance, or periodic bottlenecks are inevitable but can be better handled by taking the following steps:
- Avoid peak filing times when scheduling maintenance, or EFM or EDGAR System upgrades.
- Provide sufficient advance notice about planned downtime.
- Maintain a permanent outage log and alert system.
- Notify filers and vendors about system bottlenecks.
- Help SEC staff respond to filers and issuers.
- Improve the usefulness of tools currently providers to vendors and issuers like the SEC Interactive Data Test Suite.