Order Granting Limited and Conditional Exemption Under Section 36(a) of the Securities Exchange Act of 1934 From Compliance With Interactive Data File Exhibit Requirement in Forms 6-K, 8-K, 10-Q, 10-K, 20-F and 40-F To Facilitate Inline Filing of Tagged Financial Data, 39741-39743 [2016-14306]
Download as PDF
sradovich on DSK3TPTVN1PROD with NOTICES
Federal Register / Vol. 81, No. 117 / Friday, June 17, 2016 / Notices
Section 12(g) because it is delinquent in
its periodic filings with the
Commission, having not filed any
periodic reports since it filed a Form
10–Q for the period ended September
30, 2014. On December 2, 2015,
Corporation Finance sent a delinquency
letter to ANOS requesting compliance
with its periodic filing requirements but
ANOS did not receive the delinquency
letter due to its failure to maintain a
valid address on file with the
Commission as required by Commission
Issuer Address Rules. As of June 8,
2016, the common stock of ANOS was
quoted on OTC Link, had five market
makers, and was eligible for the
‘‘piggyback’’ exception of Exchange Act
Rule 15c2–11(f)(3).
It appears to the Commission that
there is a lack of current and accurate
information concerning the securities of
Emperial Americas, Inc. (‘‘TEXX’’) (CIK
No. 1424718), a dissolved Florida
corporation located in Sarasota, Florida
with a class of securities registered with
the Commission pursuant to Exchange
Act Section 12(g) because it is
delinquent in its periodic filings with
the Commission, having not filed any
periodic reports since it filed a Form
10–Q for the period ended June 30,
2012. On January 28, 2016, Corporation
Finance sent a delinquency letter to
TEXX requesting compliance with its
periodic filing requirements but TEXX
did not receive the delinquency letter
due to its failure to maintain a valid
address on file with the Commission as
required by Commission Issuer Address
Rules. As of June 8, 2016, the common
stock of TEXX was quoted on OTC Link,
had six market makers, and was eligible
for the ‘‘piggyback’’ exception of
Exchange Act Rule 15c2–11(f)(3).
It appears to the Commission that
there is a lack of current and accurate
information concerning the securities of
Nord Resources Corporation (‘‘NRDSQ’’)
(CIK No. 72316), a void Delaware
corporation located in Tucson, Arizona
with a class of securities registered with
the Commission pursuant to Exchange
Act Section 12(g) because it is
delinquent in its periodic filings with
the Commission, having not filed any
periodic reports since it filed a Form
10–Q for the period ended September
30, 2013. On September 30, 2015,
Corporation Finance sent a delinquency
letter to NRDSQ requesting compliance
with its periodic filing requirements
which was delivered. As of June 8,
2016, the common stock of NRDSQ was
quoted on OTC Link, had six market
makers, and was eligible for the
‘‘piggyback’’ exception of Exchange Act
Rule 15c2–11(f)(3).
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16:48 Jun 16, 2016
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It appears to the Commission that
there is a lack of current and accurate
information concerning the securities of
UNR Holdings, Inc. (‘‘UNRH’’) (CIK No.
1093800), a delinquent Colorado
corporation located in New York, New
York with a class of securities registered
with the Commission pursuant to
Exchange Act Section 12(g) because it is
delinquent in its periodic filings with
the Commission, having not filed any
periodic reports since it filed a Form
10–Q for the period ended September
30, 2012. On March 25, 2015,
Corporation Finance sent a delinquency
letter to UNRH requesting compliance
with its periodic filing requirements
which was delivered. As of June 8,
2016, the common stock of UNRH was
quoted on OTC Link, had four market
makers, and was eligible for the
‘‘piggyback’’ exception of Exchange Act
Rule 15c2–11(f)(3).
The Commission is of the opinion that
the public interest and the protection of
investors require a suspension of trading
in the securities of the above-listed
companies. Therefore, it is ordered,
pursuant to Section 12(k) of the
Securities Exchange Act of 1934, that
trading in the securities of the abovelisted companies is suspended for the
period from 9:30 a.m. EDT on June 15,
2016, through 11:59 p.m. EDT on June
28, 2016.
By the Commission.
Jill M. Peterson,
Secretary.
[FR Doc. 2016–14475 Filed 6–15–16; 4:15 pm]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–78041]
Order Granting Limited and
Conditional Exemption Under Section
36(a) of the Securities Exchange Act of
1934 From Compliance With Interactive
Data File Exhibit Requirement in Forms
6–K, 8–K, 10–Q, 10–K, 20–F and 40–F
To Facilitate Inline Filing of Tagged
Financial Data
June 13, 2016.
I. Introduction
Operating companies are required to
provide their financial statements
accompanying their periodic and
current reports in machine-readable
format using eXtensible Business
Reporting Language (XBRL). Companies
currently provide this XBRL data as an
exhibit to their filings. Since these
requirements were first adopted,
technology has evolved and now would
PO 00000
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Fmt 4703
Sfmt 4703
39741
allow filers to embed XBRL data directly
into a HyperText Markup Language
(HTML) document through a format
known as Inline XBRL. The technology
is freely licensed and made available by
XBRL International,1 and it is currently
used by companies in other
jurisdictions for a variety of regulatory
purposes.2
We believe that filing financial
statements with Inline XBRL has the
potential to provide a number of
benefits to filers and users of the
information. For example, Inline XBRL
could decrease filing preparation costs,
improve the quality of structured data,
and by improving data quality, increase
the use of XBRL data by investors and
other market participants.
Consequently, as a means of further
assessing the usefulness of Inline XBRL,
we are exercising our authority under
Section 36(a) of the Securities Exchange
Act of 1934 (Exchange Act) to permit,
but not require, operating companies to
use Inline XBRL in their periodic and
current reports under the Exchange Act
through March 2020. Additionally,
permitting companies to use Inline
XBRL on a voluntary, time-limited basis
could facilitate the development of
Inline XBRL preparation and analysis
tools, provide investors and companies
with the opportunity to evaluate its
usefulness, and help inform any future
Commission rulemaking in this area.
II. Discussion
Information is ‘‘structured’’ when it is
made machine-readable by labeling (or
‘‘tagging’’) the information using a
markup language, such as XBRL, that
can be processed by software for
analysis. Structured information can be
stored, shared, and presented in
different systems or platforms.
Companies currently use information
systems that accommodate and rely
upon structured information.
Standardized markup languages, such
as XBRL, use sets of tags, referred to as
taxonomies. Taxonomies provide
common definitions that represent
1 See https://specifications.xbrl.org/spec-groupindex-inline-xbrl.html.
2 For example, in the United Kingdom, the
‘‘accounts and computations’’ part of a ‘‘Company
Tax Return’’ must be submitted to HM Revenue and
Customs using Inline XBRL. See https://
www.hmrc.gov.uk/ct/ct-online/taxonomy.htm.
Other examples include Australia (https://
asic.gov.au/about-asic/media-centre/find-a-mediarelease/2015-releases/15-104mr-asic-introducesformat-for-improved-communication-of-financialinformation/); Japan (https://www.xbrl.org/thestandard/why/who-else-uses-xbrl/); Denmark
(https://www.xbrl.org/the-standard/why/who-elseuses-xbrl/); and Ireland (https://www.revenue.ie/en/
online/ros/ixbrl/). We note that the
specific disclosure regimes in these countries differ
from that in the U.S.
E:\FR\FM\17JNN1.SGM
17JNN1
sradovich on DSK3TPTVN1PROD with NOTICES
39742
Federal Register / Vol. 81, No. 117 / Friday, June 17, 2016 / Notices
agreed-upon information about
reporting standards, such as U.S. GAAP
for accounting-based disclosures. The
resulting standardization of financial
reporting allows for aggregation,
comparison, and large-scale statistical
analysis of reported financial
information through significantly more
automated means than is possible with
other formats, such as HTML.
Structured financial statement
information is currently required to be
submitted in an ‘‘Interactive Data File’’
exhibit to certain forms.3 These forms
are prepared in either HTML or (less
commonly) American Standard Code for
Information Interchange (ASCII)
electronic formats. The form as prepared
in these formats is called the ‘‘Related
Official Filing.’’ The Interactive Data
File currently consists of an ‘‘instance
document’’ and other documents as
described in the EDGAR Filer Manual.
For the purposes of this order, we use
‘‘instance document’’ to describe that
part of the Interactive Data File that
contains the XBRL tags for the
information contained in the
corresponding data in the Related
Official Filing to satisfy the content and
format requirements in 17 CFR 232.405.
The other documents in the Interactive
Data File contain contextual information
about the XBRL tags.
Companies often create XBRL exhibits
by first preparing their financial
statements in a word processing
application and then converting it to
another format, such as HTML. Filers
then create an XBRL exhibit by copying
the financial statement information and
tagging it in XBRL. In this way,
preparers essentially tag a copy of the
data contained in their HTML filings in
a separate document, which requires
them to expend resources to create and
tag a copy of the data and verify the
consistency of tagged data across
documents.
Errors sometimes appear in financial
statement information submitted in
XBRL that affect the quality of the data
and its potential use by the public and
the Commission. For example,
Commission staff has identified several
recurring issues with XBRL
submissions, including errors related to
the characterization of a number as
negative when it is positive, incorrect
scaling of a number (e.g., in billions
rather than in millions), unnecessary
custom tags (such as to achieve a
particular presentation), incomplete
tagging (e.g., a failure to tag numbers in
parentheses), and missing calculations
that show relationships between data
3 See 17 CFR 232.405; see also 17 CFR
229.601(b)(101).
VerDate Sep<11>2014
16:48 Jun 16, 2016
Jkt 238001
(e.g., how adding cost of revenue to
gross profit equals revenue and
subtracting cost of revenue from
revenue equals gross profit).4 While
these data quality issues may have
multiple potential causes, we believe
that some of these errors may result
from the submission of XBRL tagged
information as an exhibit separate from
the Related Official Filing.
Embedding XBRL data in an HTML
document (which we refer to together as
the ‘‘Inline XBRL document’’) rather
than tagging data in a separate instance
document may increase the efficiency
and effectiveness of the filing
preparation and review process and, by
saving time and effort spent on the these
processes, may, over time, reduce the
cost of compliance with XBRL
requirements.5 In particular, Inline
XBRL makes it possible for preparers to
view XBRL meta data 6 within the
HTML document. By facilitating the
review of XBRL data, we believe that
Inline XBRL could decrease the overall
time required to comply with the XBRL
data filing requirement and may better
equip preparers to detect and correct
XBRL data errors.
Permitting filing in Inline XBRL is
intended to improve XBRL data quality.
In particular, the elimination of a
separate instance document should
reduce the incidence of re-keying errors.
Additionally, Inline XBRL might
eliminate unnecessary or inappropriate
custom tags intended to make XBRL
data look similar to an HTML document
when ‘‘rendered’’ by software into a
human-readable presentation. With
Inline XBRL, companies would have
less of an incentive to create custom tags
solely to mimic the appearance of an
HTML filing. To the extent that
permitting filing using Inline XBRL
might improve data quality, it may
contribute to wider use of XBRL data by
market participants and may enhance
4 See, e.g., Staff Observations of Custom Tag Rates
(July 7, 2014), available at https://www.sec.gov/dera/
reportspubs/assessment-custom-tag-rates-xbrl.html;
Staff Observations from the Review of Interactive
Data Financial Statements (December 13, 2011),
available at https://www.sec.gov/spotlight/xbrl/staffreview-observations-121311.shtml.
5 Embedding XBRL data in the HTML filing could
create some confusion about the operation of
current accuracy requirements, such as in Rule
405(c)(1). That rule requires ‘‘[e]ach data element
. . . contained in the Interactive Data File [to
reflect] the same information in the corresponding
data in the Related Official Filing.’’ Although the
Inline XBRL document will contain XBRL data that
is currently presented in the Interactive Data File,
that data must still accurately reflect the
corresponding information in the HTML format
portion of the filing. See condition (c) below.
6 Such meta data include, for example,
definitions, reporting period information, data type,
and related references.
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Frm 00119
Fmt 4703
Sfmt 4703
the benefits that are associated with
XBRL more generally.
In light of the potential benefits from
using Inline XBRL, we are initiating a
voluntary, time-limited program to
assess the usefulness of this new filing
format. This voluntary program also
may facilitate the development of
technological tools to support the
potential further use of Inline XBRL in
the future.
We note that, with the acceptance of
Inline XBRL filings under this program,
XBRL data users, such as investors,
analysts, filers, and data aggregators,
may need to modify their software or
algorithms to be able to extract the
XBRL data. We believe, however, that
such adjustments will be minimal
because the voluntary Inline XBRL
program will not affect the taxonomy or
the scope of the information required to
be tagged. In addition, the Commission
has incorporated tools into the EDGAR
system that will enable users to view
information about the reported XBRL
data contained in embedded tags on the
Commission’s Web site, using any
recent standard Internet browser,
without the need to access a separate
document. With this feature, when a
user views a filing submitted with Inline
XBRL on EDGAR, the user will be able
to see tags and the related meta data
while viewing the HTML filing.
Software enabling this feature will also
be made freely available to the public in
an effort to facilitate the creation of cost
effective Inline XBRL viewers and
analytical products. We also plan to
make freely available software for Inline
XBRL extraction, which may further
mitigate potential effects on XBRL data
users. Additionally, the EDGAR system
will, for the duration of the voluntary
program, extract and make available the
XBRL tags from an Inline XBRL
document as a separate file, enabling
current software to continue automated
processing of XBRL data with minimal
changes to existing processes.
We also note that permitting filing
using Inline XBRL may result in
changes that affect those filers choosing
to use Inline XBRL. Currently, when
there is a major technical error with
XBRL data submitted in an exhibit, the
EDGAR validation system causes the
exhibit to be removed from the
submission, but the submission as a
whole is not suspended. With Inline
XBRL, the EDGAR validation system
will suspend an Inline XBRL filing that
contains a major technical error in
embedded XBRL data, which would
require the filing to be revised before it
could be accepted by EDGAR. Based on
staff observations, very few XBRL
exhibits are suspended, in part, because
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17JNN1
Federal Register / Vol. 81, No. 117 / Friday, June 17, 2016 / Notices
companies and preparers routinely use
tools the Commission makes available to
submit test filings to help identify and
correct technical errors prior to EDGAR
filing. Similar tools to submit test filings
will be available to those filers choosing
to file in Inline XBRL. Because we
expect that Inline XBRL filers would
utilize available tools to submit test
filings to identify and correct any
technical errors prior to EDGAR filing,
we believe that such suspensions
should be similarly rare for Inline XBRL
filers.
III. Conclusion
Based on the foregoing, we find it is
appropriate in the public interest and
consistent with the protection of
investors to grant companies that choose
to use Inline XBRL when filing financial
statements in their Exchange Act
periodic and current reports a timelimited and conditional exemption from
certain requirements of the Interactive
Data File exhibit.
Accordingly, it is hereby ordered
pursuant to Section 36(a) of the
Exchange Act that any company that
complies with each of the conditions
below is exempt from the requirement
to submit an instance document as
described in this order as part of its
Interactive Data File exhibit with Forms
6–K, 8–K, 10–Q, 10–K, 20–F and 40–F
for reports due before March 30, 2020.
sradovich on DSK3TPTVN1PROD with NOTICES
Conditions
The company must
(a) file an Inline XBRL document as
prescribed in the EDGAR Filer Manual;
(b) file the Interactive Data File as
prescribed in the EDGAR Filer Manual
for Inline XBRL filers as an exhibit to
the Inline XBRL document;
(c) use XBRL tags within the Inline
XBRL document that reflect the same
information in the corresponding data
as the HTML format part of the official
filing;
(d) state in the exhibit index item
referencing the Interactive Data File that
the instance document does not appear
in the Interactive Data File because its
XBRL tags are embedded within the
Inline XBRL document;
(e) not file in plain text ASCII; and
(f) not rely on the hardship
exemptions in Rules 201 and 202 of
Regulation S–T.
By the Commission.
Brent J. Fields,
Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–78055; File No. SR–ICC–
2016–008]
Self-Regulatory Organizations; ICE
Clear Credit LLC; Notice of Filing and
Order Granting Accelerated Approval
of Proposed Rule Change To Revise
the ICC Clearing Rules
June 13, 2016.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on June 3,
2016, ICE Clear Credit LLC (‘‘ICC’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I, II and III below, which Items
have been prepared primarily by ICC.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons and to approve the proposed
rule change on an accelerated basis.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The purpose of proposed rule change
is to revise the ICC Clearing Rules (‘‘ICC
Rules’’) to add explicit references to
certain risk-related policies currently
contained in the ICC Risk Management
Framework and the ICC Risk
Management Model Description
document.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, ICC
included statements concerning the
purpose of and basis for the proposed
rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. ICC has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of these statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
ICC proposes changes to ICC Rules
403 and 801 to add explicit references
to certain risk-related policies currently
contained in the ICC Risk Management
Framework and the ICC Risk
Management Model Description
[FR Doc. 2016–14306 Filed 6–16–16; 8:45 am]
1 15
BILLING CODE 8011–01–P
2 17
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16:48 Jun 16, 2016
Jkt 238001
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00120
Fmt 4703
Sfmt 4703
39743
document related to the minimum time
horizon for liquidation, antiprocyclicality conditions, and the
maintenance of cover-2 default
resources. The proposed changes are
described in detail as follows.
As provided in the ICC Risk
Management Model Description
document, ICC’s initial margin
methodology applies a minimum of a 5day time horizon as the liquidation
period for all ICC cleared instruments.
ICC proposes amending ICC Rule 403 to
explicitly reference this risk policy by
stating that ICC’s initial margin
methodology shall incorporate a
minimum 5-day time horizon for the
liquidation period (for both house and
client-related positions).
Additionally, as provided in the ICC
Risk Management Framework, ICC
incorporates certain anti-procyclicality
measures into its risk methodology to
account for stable but prudent margin
requirements.3 ICC proposes amending
ICC Rule 403 to explicitly reference its
current anti-procyclicality measures and
to provide for additional antiprocyclicality measures. Specifically,
ICC proposes amending ICC Rule 403 to
state that ICC’s initial margin
methodology shall incorporate one or
more measures designed to limit
procyclicality, including by avoiding
when possible disruptive or big step
changes in margin requirements and by
establishing transparent and predictable
procedures for adjusting margin
requirements in response to changing
market conditions. Further, consistent
with current ICC risk policies, the
measures designed to limit
procyclicality will demonstrably meet
or exceed the requirements of measures
designed to limit procyclicality that
assign at least 25% weight to stressed
observations in a look-back period
beginning on April 1, 2007. In addition,
changes to ICC Rule 403 also allow ICC
to measure procyclicality limits by
reference to a ten year historical lookback period for computing initial
margin.4
Finally, as provided in the ICC Risk
Management Framework, ICC maintains
a minimum of cover-2 default resources,
in accordance with Commodity Futures
Trading Commission (‘‘CFTC’’)
Regulations 39.11 and 39.33. ICC
proposes amending ICC Rule 801(a)(i) to
explicitly reference this risk policy and
state that ICC shall establish the
aggregate amount of required
3 See Securities Exchange Act Release No. 34–
73877 (December 18, 2014) (SR–ICC–2014–18).
4 Please note that as ICC uses a look-back period
beginning on April 1, 2007, this ten year historical
period anti-procyclicality measure will become
available to ICC in 2017.
E:\FR\FM\17JNN1.SGM
17JNN1
Agencies
[Federal Register Volume 81, Number 117 (Friday, June 17, 2016)]
[Notices]
[Pages 39741-39743]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-14306]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-78041]
Order Granting Limited and Conditional Exemption Under Section
36(a) of the Securities Exchange Act of 1934 From Compliance With
Interactive Data File Exhibit Requirement in Forms 6-K, 8-K, 10-Q, 10-
K, 20-F and 40-F To Facilitate Inline Filing of Tagged Financial Data
June 13, 2016.
I. Introduction
Operating companies are required to provide their financial
statements accompanying their periodic and current reports in machine-
readable format using eXtensible Business Reporting Language (XBRL).
Companies currently provide this XBRL data as an exhibit to their
filings. Since these requirements were first adopted, technology has
evolved and now would allow filers to embed XBRL data directly into a
HyperText Markup Language (HTML) document through a format known as
Inline XBRL. The technology is freely licensed and made available by
XBRL International,\1\ and it is currently used by companies in other
jurisdictions for a variety of regulatory purposes.\2\
---------------------------------------------------------------------------
\1\ See https://specifications.xbrl.org/spec-group-index-inline-xbrl.html.
\2\ For example, in the United Kingdom, the ``accounts and
computations'' part of a ``Company Tax Return'' must be submitted to
HM Revenue and Customs using Inline XBRL. See https://www.hmrc.gov.uk/ct/ct-online/taxonomy.htm. Other examples include
Australia (https://asic.gov.au/about-asic/media-centre/find-a-media-release/2015-releases/15-104mr-asic-introduces-format-for-improved-communication-of-financial-information/); Japan (https://www.xbrl.org/the-standard/why/who-else-uses-xbrl/); Denmark (https://www.xbrl.org/the-standard/why/who-else-uses-xbrl/); and Ireland
(https://www.revenue.ie/en/online/ros/ixbrl/). We note that
the specific disclosure regimes in these countries differ from that
in the U.S.
---------------------------------------------------------------------------
We believe that filing financial statements with Inline XBRL has
the potential to provide a number of benefits to filers and users of
the information. For example, Inline XBRL could decrease filing
preparation costs, improve the quality of structured data, and by
improving data quality, increase the use of XBRL data by investors and
other market participants. Consequently, as a means of further
assessing the usefulness of Inline XBRL, we are exercising our
authority under Section 36(a) of the Securities Exchange Act of 1934
(Exchange Act) to permit, but not require, operating companies to use
Inline XBRL in their periodic and current reports under the Exchange
Act through March 2020. Additionally, permitting companies to use
Inline XBRL on a voluntary, time-limited basis could facilitate the
development of Inline XBRL preparation and analysis tools, provide
investors and companies with the opportunity to evaluate its
usefulness, and help inform any future Commission rulemaking in this
area.
II. Discussion
Information is ``structured'' when it is made machine-readable by
labeling (or ``tagging'') the information using a markup language, such
as XBRL, that can be processed by software for analysis. Structured
information can be stored, shared, and presented in different systems
or platforms. Companies currently use information systems that
accommodate and rely upon structured information.
Standardized markup languages, such as XBRL, use sets of tags,
referred to as taxonomies. Taxonomies provide common definitions that
represent
[[Page 39742]]
agreed-upon information about reporting standards, such as U.S. GAAP
for accounting-based disclosures. The resulting standardization of
financial reporting allows for aggregation, comparison, and large-scale
statistical analysis of reported financial information through
significantly more automated means than is possible with other formats,
such as HTML.
Structured financial statement information is currently required to
be submitted in an ``Interactive Data File'' exhibit to certain
forms.\3\ These forms are prepared in either HTML or (less commonly)
American Standard Code for Information Interchange (ASCII) electronic
formats. The form as prepared in these formats is called the ``Related
Official Filing.'' The Interactive Data File currently consists of an
``instance document'' and other documents as described in the EDGAR
Filer Manual. For the purposes of this order, we use ``instance
document'' to describe that part of the Interactive Data File that
contains the XBRL tags for the information contained in the
corresponding data in the Related Official Filing to satisfy the
content and format requirements in 17 CFR 232.405. The other documents
in the Interactive Data File contain contextual information about the
XBRL tags.
---------------------------------------------------------------------------
\3\ See 17 CFR 232.405; see also 17 CFR 229.601(b)(101).
---------------------------------------------------------------------------
Companies often create XBRL exhibits by first preparing their
financial statements in a word processing application and then
converting it to another format, such as HTML. Filers then create an
XBRL exhibit by copying the financial statement information and tagging
it in XBRL. In this way, preparers essentially tag a copy of the data
contained in their HTML filings in a separate document, which requires
them to expend resources to create and tag a copy of the data and
verify the consistency of tagged data across documents.
Errors sometimes appear in financial statement information
submitted in XBRL that affect the quality of the data and its potential
use by the public and the Commission. For example, Commission staff has
identified several recurring issues with XBRL submissions, including
errors related to the characterization of a number as negative when it
is positive, incorrect scaling of a number (e.g., in billions rather
than in millions), unnecessary custom tags (such as to achieve a
particular presentation), incomplete tagging (e.g., a failure to tag
numbers in parentheses), and missing calculations that show
relationships between data (e.g., how adding cost of revenue to gross
profit equals revenue and subtracting cost of revenue from revenue
equals gross profit).\4\ While these data quality issues may have
multiple potential causes, we believe that some of these errors may
result from the submission of XBRL tagged information as an exhibit
separate from the Related Official Filing.
---------------------------------------------------------------------------
\4\ See, e.g., Staff Observations of Custom Tag Rates (July 7,
2014), available at https://www.sec.gov/dera/reportspubs/assessment-custom-tag-rates-xbrl.html; Staff Observations from the Review of
Interactive Data Financial Statements (December 13, 2011), available
at https://www.sec.gov/spotlight/xbrl/staff-review-observations-121311.shtml.
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Embedding XBRL data in an HTML document (which we refer to together
as the ``Inline XBRL document'') rather than tagging data in a separate
instance document may increase the efficiency and effectiveness of the
filing preparation and review process and, by saving time and effort
spent on the these processes, may, over time, reduce the cost of
compliance with XBRL requirements.\5\ In particular, Inline XBRL makes
it possible for preparers to view XBRL meta data \6\ within the HTML
document. By facilitating the review of XBRL data, we believe that
Inline XBRL could decrease the overall time required to comply with the
XBRL data filing requirement and may better equip preparers to detect
and correct XBRL data errors.
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\5\ Embedding XBRL data in the HTML filing could create some
confusion about the operation of current accuracy requirements, such
as in Rule 405(c)(1). That rule requires ``[e]ach data element . . .
contained in the Interactive Data File [to reflect] the same
information in the corresponding data in the Related Official
Filing.'' Although the Inline XBRL document will contain XBRL data
that is currently presented in the Interactive Data File, that data
must still accurately reflect the corresponding information in the
HTML format portion of the filing. See condition (c) below.
\6\ Such meta data include, for example, definitions, reporting
period information, data type, and related references.
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Permitting filing in Inline XBRL is intended to improve XBRL data
quality. In particular, the elimination of a separate instance document
should reduce the incidence of re-keying errors. Additionally, Inline
XBRL might eliminate unnecessary or inappropriate custom tags intended
to make XBRL data look similar to an HTML document when ``rendered'' by
software into a human-readable presentation. With Inline XBRL,
companies would have less of an incentive to create custom tags solely
to mimic the appearance of an HTML filing. To the extent that
permitting filing using Inline XBRL might improve data quality, it may
contribute to wider use of XBRL data by market participants and may
enhance the benefits that are associated with XBRL more generally.
In light of the potential benefits from using Inline XBRL, we are
initiating a voluntary, time-limited program to assess the usefulness
of this new filing format. This voluntary program also may facilitate
the development of technological tools to support the potential further
use of Inline XBRL in the future.
We note that, with the acceptance of Inline XBRL filings under this
program, XBRL data users, such as investors, analysts, filers, and data
aggregators, may need to modify their software or algorithms to be able
to extract the XBRL data. We believe, however, that such adjustments
will be minimal because the voluntary Inline XBRL program will not
affect the taxonomy or the scope of the information required to be
tagged. In addition, the Commission has incorporated tools into the
EDGAR system that will enable users to view information about the
reported XBRL data contained in embedded tags on the Commission's Web
site, using any recent standard Internet browser, without the need to
access a separate document. With this feature, when a user views a
filing submitted with Inline XBRL on EDGAR, the user will be able to
see tags and the related meta data while viewing the HTML filing.
Software enabling this feature will also be made freely available to
the public in an effort to facilitate the creation of cost effective
Inline XBRL viewers and analytical products. We also plan to make
freely available software for Inline XBRL extraction, which may further
mitigate potential effects on XBRL data users. Additionally, the EDGAR
system will, for the duration of the voluntary program, extract and
make available the XBRL tags from an Inline XBRL document as a separate
file, enabling current software to continue automated processing of
XBRL data with minimal changes to existing processes.
We also note that permitting filing using Inline XBRL may result in
changes that affect those filers choosing to use Inline XBRL.
Currently, when there is a major technical error with XBRL data
submitted in an exhibit, the EDGAR validation system causes the exhibit
to be removed from the submission, but the submission as a whole is not
suspended. With Inline XBRL, the EDGAR validation system will suspend
an Inline XBRL filing that contains a major technical error in embedded
XBRL data, which would require the filing to be revised before it could
be accepted by EDGAR. Based on staff observations, very few XBRL
exhibits are suspended, in part, because
[[Page 39743]]
companies and preparers routinely use tools the Commission makes
available to submit test filings to help identify and correct technical
errors prior to EDGAR filing. Similar tools to submit test filings will
be available to those filers choosing to file in Inline XBRL. Because
we expect that Inline XBRL filers would utilize available tools to
submit test filings to identify and correct any technical errors prior
to EDGAR filing, we believe that such suspensions should be similarly
rare for Inline XBRL filers.
III. Conclusion
Based on the foregoing, we find it is appropriate in the public
interest and consistent with the protection of investors to grant
companies that choose to use Inline XBRL when filing financial
statements in their Exchange Act periodic and current reports a time-
limited and conditional exemption from certain requirements of the
Interactive Data File exhibit.
Accordingly, it is hereby ordered pursuant to Section 36(a) of the
Exchange Act that any company that complies with each of the conditions
below is exempt from the requirement to submit an instance document as
described in this order as part of its Interactive Data File exhibit
with Forms 6-K, 8-K, 10-Q, 10-K, 20-F and 40-F for reports due before
March 30, 2020.
Conditions
The company must
(a) file an Inline XBRL document as prescribed in the EDGAR Filer
Manual;
(b) file the Interactive Data File as prescribed in the EDGAR Filer
Manual for Inline XBRL filers as an exhibit to the Inline XBRL
document;
(c) use XBRL tags within the Inline XBRL document that reflect the
same information in the corresponding data as the HTML format part of
the official filing;
(d) state in the exhibit index item referencing the Interactive
Data File that the instance document does not appear in the Interactive
Data File because its XBRL tags are embedded within the Inline XBRL
document;
(e) not file in plain text ASCII; and
(f) not rely on the hardship exemptions in Rules 201 and 202 of
Regulation S-T.
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2016-14306 Filed 6-16-16; 8:45 am]
BILLING CODE 8011-01-P