XBRL US submitted a comment letter in response to the Securities and Exchange Commission Proposed Collection; Comment Request; Extension: Interactive Data. Points raised in the letter include:
- Requiring corporate disclosures to be prepared in XBRL format produces structured data that is more useful, accessible, granular, and more consistent than data in unstructured format for regulators, investors, researchers, and other data consumers.
- The Commission's burden estimate of 53.1111 burden hours is high, based on an issuer survey conducted among 26 respondents. The survey found that most issuers prepare their XBRL data themselves: 37% outsource to a vendor, 44% prepare their data in-house with some assistance from a vendor and 18% said they prepare in-house with no vendor assistance.
- Of those who prepare their XBRL in-house, 13% spend between 0 and 5 hours on XBRL preparation; 31% spend between 6 and 20 hours; 31% between 21 and 40 hours; 19% between 41 to 60 hours; and 6% said they spend more than 60 hours.
- Of those who outsource their filing, 60% spend between 6 and 20 hours; 10% spend between 21 and 40 hours; and 30% between zero and 5 hours.
- Based on the average of each hourly range (with 70 hours for the “60 or more hours” range) multiplied by the percent of respondents in that range, we estimate the average time spent by issuers (not including hours spent by vendor staff supporting them) to be around 22 hours.
Read the letter: XBRL US Comment on SEC Extension Interactive Data
