By John Truzzolino, Chair, XBRL US Regulatory Modernization Working Group, and Director, Donnelley Financial Services (DFIN); with members of the Working Group
Many XBRL US members are providers of EDGAR filing preparation and submission applications. We have been helping public companies and investment management firms submit filings to the Securities and Exchange Commission’s (SEC) Electronic Data Gathering and Retrieval (EDGAR) System for years. For some of us, even decades!
The EDGAR System collects all different kinds of data from thousands of entities of all types: from public companies, investment management companies, private companies, and others. Compliance-related disclosures are the oil in the capital market machine, ensuring that the SEC can meet its mission to “.. protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation.” Efficient, accurate, timely delivery of that data is critical.
That’s why we applaud the recent efforts of the Commission to take concrete steps to improve the efficiencies of the EDGAR system, and to work in partnership with vendors and issuers to improve communication, and provide the market with tools that can reduce friction in the processing of time-sensitive, market-moving filings.
On February 3, the Commission announced a limited access pilot test environment, EDGAR BETA, to give filers and vendors early access to changes scheduled for an upcoming EDGAR Release. EDGAR BETA gives EDGAR submission software providers the ability to run tests in a safe, non-public environment, so that we can identify needed adjustments to custom software, automation routines, and business processes, to make sure they are compatible with planned EDGAR software changes.
The new BETA environment is expected to be available for testing for four weeks prior to making the final software changes. The SEC email announcing EDGAR BETA noted that the Commission will “...consider expanding the use of the EDGAR BETA test environment in connection with future EDGAR releases.”
We wholeheartedly support the Commission’s plans and hope that EDGAR BETA will be available for every new EDGAR Release, and in particular for new XBRL or other structured data rule implementations. New programs, particularly those involving new reporting entities submitting in structured format for the first time, or requiring the structuring of new kinds of data, can often raise questions during implementation and may result in unforeseen consequences. A test environment would help vendors, and the issuers we support, to head off problems before they happen.
We appreciate the work of the Commission in making this test environment available and in working with the marketplace to enhance the EDGAR submission process.
The XBRL US Regulatory Modernization Working Group, has a mission to “ Establish an ongoing dialogue between regulators and the vendor and filer community. Identify issues and propose recommendations to regulators that will facilitate the smooth implementation of new regulatory rules related to XBRL and other structured data filing requirements.”
Other organizational members include Advanced Computer Innovations; Broadridge Financial Solutions; Certent; Computer Science Resources; DataTracks; Exxon Mobil; KPMG; Mark V; Novaworks, LLC; P3 Data Systems; RDG Filings; Toppan Merrill; and Workiva.