XBRL US submitted a comment letter in response to the Securities and Exchange Commission (SEC) extension of data collection of Rule 17g-7 regarding disclosure requirements for credit rating agencies (Nationally Recognized Statistical Rating Organizations (NRSRO)). Credit ratings agencies today are required to report ratings data in XBRL format. Our letter expressed support for the continuation of XBRL formatting of ratings data, but we made the following recommendations to increase reporting efficiency, reduce the burden on reporting entities; and to increase the value of the data they report:
Revise the Credit Rating Taxonomy to replace tuples for dimensions to describe the data they report, because the XBRL dimensions specification is more widely used.
Require NRSROs to use XBRL-CSV instead of XBRL-XML (as they do today), which would reduce the burden of data preparation and produce data that is easier to access and use.
Require NRSROs to submit XBRL-formatted ratings data directly to the SEC EDGAR System rather than posted to the NRSRO web site and linked to from Form NRSRO, to ease data consumption.
Update the taxonomy to include the Legal Entity Identifier (LEI) and the Financial Instrument Open Identifier (FIGI), to encourage the use of these open, nonproprietary identifiers rather than proprietary CUSIP identifiers. Nonproprietary identifiers would reduce the cost for issuers and data users.
Reduce the time delay on making XBRL-formatted ratings data available to the public to increase the value of the machine-readable data.
The national consortium for the business reporting standard
XBRL US is a not-for-profit organization supporting the implementation of digital business reporting standards through the development of taxonomies for use by U.S. public and private sectors, with a goal of interoperability between sectors, and by promoting XBRL adoption through marketplace collaboration.