Posted on Tuesday, December 14, 2021

XBRL US submitted a comment letter to the Securities and Exchange Commission (SEC) regarding its proposed rule Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers. The rule proposes that fund reporting of proxy votes on Form N-PX be enhanced by adding additional disclosures, and by requiring the data to be reported using a custom XML schema.

The XBRL US letter encouraged the SEC to opt for XBRL-CSV rather than a custom XML schema for the following reasons:

  • XBRL-CSV would result in smaller file sizes than custom XML which would require issuers to repeat identifying tags over and over, rather than referencing a taxonomy
  • Issuers and data users would be able to leverage tools they already use for XBRL

The letter also encouraged the SEC to opt for the Financial Instrument Global Identifier (FIGI) as the sole allowed security identifier, rather than allowing issuers to choose to report either the ISIN or the CUSIP, as proposed. Unlike the CUSIP, the FIGI is an open, nonproprietary identifier with no associated licensing fees. And unlike the ISIN, the FIGI identifies not only at the global level but at the country and exchange level as well, lending it a greater level of specificity.

Read the letter: XBRL US Comment – SEC File Number S7-11-21

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