XBRL US submitted a comment letter to the Securities and Exchange Commission (SEC) in response to the rule proposal on Electronic Submission of Certain Material Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report.
The letter expressed XBRL US’ support for the Commission’s proposal to require documents to be filed electronically and to be submitted in machine-readable format. We agree with the Commission’s assessment that electronic filing and preparation will modernize the filing process, removing the burden of preparing paper forms by those filing, and the burden on the Commission of receiving and maintaining paper forms. The letter addressed specific form types including Form 1, Form CA-1, Form 19b-4(3), Form X-17A-5 PART III and 17-H, Rule 15fi-c(c) SBS Notices, Rule fk1(c)(2)(ii) CCO Report, and the FOCUS Report and Signature Requirements in Rule 17a-5, 17a-12 and 18a-7 filings.
Points raised included:
- Preference for the XBRL standard versus custom XML schemas as XBRL can more readily handle financial data, is more cost-effective for preparers and data users, and can provide a smaller size (when comparing custom XML to XBRL-CSV).
- Some forms are proposed to be prepared with some section in Inline XBRL and some in a custom XML schema, which would increase the preparation data data extraction cost.
- The Commission proposes leaving some documents that are provided as attachments in PDF format; we concur in some cases, and propose that the SEC require preparers to create an index document that contains tagged links to the individual documents to streamline access.
Read the letter: XBRL US Comment Electronic Submissions – File No. S7-08-23