Responses to these questions were developed through an informal discussion with staff from the U.S. Securities and Exchange Commission.

Question: What is the Commission’s position on data points in bar charts? We assume that would require hidden facts such as DEI information. Today the risk/return summary charts must be tagged in table format in the detail view – how would the individual facts in the bar chart be represented using inline XBRL?

Answer: Tags in charts should be put in the hidden section. Validation has or will be modified so it will not give you a warning. The data does not have to be tied to an image, but it certainly can be.

 

Question: Could the Commission create one or more sample Inline XBRL documents for funds as they did with operating companies? It would be helpful to see a sample registration statement amendment (485BPOS) and a sample (or samples) of a supplement (497).

Answer: In the most recently published test suite (https://www.sec.gov/structureddata/osdinteractivedatatestsuite), i23007gd (test case), there is a specimen filing, an anonymized N1A filing summary. This shows what must and what doesn’t have to be tagged.

 

Question: Are there plans for the SEC to release an update of the technical specification document for Risk Return based on inline XBRL?

Answer: It is not clear that this is needed. Much that is in the current EDGAR Filer Manual (https://www.sec.gov/info/edgar/edmanuals.htm) and Preparer’s Guide is still applicable, under EDGAR Filer manual section 6.13, Inline XBRL only relieves the filer of the need to approximate the original filing layout; nothing else changes.

 

Question: For the 485BPOS, funds sometimes pull content from multiple sources and in multiple formats, e.g., Quark, Excel, etc. which takes time to aggregate into a single format. Are there any suggestions on how best to handle this?

Answer: The goal is to move to HTML format that allows you to aggregate to a common file. How you aggregate HTML for EDGAR today will be essentially the same.

 

Question: Will there be any rendering options like the SEC previewer? How will a filer be able to view the XBRL prior to filing? If there is a rendering option, will the rendering agent create bar charts?

Answer: Every product has its own previewer, or vendors can also use the SEC EDGAR Renderer through the Arelle GUI. Bar charts are viewable in Arelle also.

 

Question: Will a new Risk/Return Taxonomy be released for the transition to Inline XBRL?

Answer: There’s no need to create a new taxonomy for the move to Inline XBRL. If items 2, 3, or 4 in N-1A change, the taxonomy will be modified.

 

Question: Does the Commission envision any changes in the applicability of the calculation linkbase for Risk/Return or will it continue to be a “null” linkbase for the majority of mutual fund filings?

Answer: The Commission sees no reason to change the way the calculation linkbase is used. But XBRL International now has a proposal out for Calc Linkbase 2 which is meant to address issues that arise in financial statements. The Calc linkbase associated with the risk/return has no such issues. You can import the standard one into your filing.

 

Question: Does the SEC anticipate that a test filing system for inline risk/return will be made available?

Answer: The EDGAR test filing system is the test filing system. This is already available. When EDGAR was updated on March 11, 2019, it allowed for Risk/Return Summary Inline filings in the test system.

 

Question: Will the Table TextBlock elements and associated Embedded Text used to render the summary section tables be eliminated? Will they be maintained for a period of time to accommodate XBRL rendering which may not be inline XBRL enabled?

Answer: This is up to the filer. If the filer wants to include these as hidden items, they can. However, with inline XBRL, the need for this goes away, but they are not necessary once you’re using inline XBRL.

 

Question: Are there any developments on the merge functionality process documented at the end of the preparers guide?

Answer: There are no developments on the merge functionality process. The merge process is based on only looking at the data, not the presentation.

 

Question: With respect to linkbases, will these be the same going forward?

Answer: The default presentation linkbase can be used.

 

Question: How does the SEC intend to support redlining (track changes) in the inline tagged html?  There is a conflict between the inline code and the redline coding that would potentially cause an error or issue in the filing. Does the SEC have thoughts on how this could be resolved?

Answer: The Commission is aware of this issue and there will be a method available in EDGAR prior to the compliance date for Mutual Funds.

 

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