Out of the Clouds and Into Reality: XBRL for the Business User

Bowne Viewer Updated With Latest SEC XBRL Rendering Engine

In a previous post I provided an overview of the different XBRL viewers currently in place at the SEC.  The "original"/Voluntary Program XBRL Viewer has been relegated to "the cheap seats" now that a new XBRL rendering engine is driving the display of live-filed XBRL mandate submissions (click on the blue "Interactive Data" button on our latest filing here) as well as documents uploaded to the SEC's Previewer.

Given the visual enhancements made by the SEC in this new rendering engine, and given the SEC is kind enough to continue to make this code available in an open source format, we've now updated the Bowne Interactive XBRL Viewer to render all uploaded XBRL documents using this new rendering engine.  This enhancement once again puts the Bowne Viewer in synch with the renderings being provided by the SEC while providing additional review and approval capabilities not available on the SEC Previewer.

In addition, and unlike the current SEC Previewer, the Bowne Viewer also provides mandate-level technical validation feedback on any uploaded XBRL documents.  Documents currently uploaded to the SEC Previewer are not passed through the SEC's XBRL validators as part of the upload and preview process.  Whether the SEC changes this going forward, we'll have to see...but the Bowne Viewer is ready today to do both (validate and review/approve!).

We hope you enjoy the new functionality, and let us know what you think!

-Rob 

US GAAP 2009 Taxonomy Support Announced; Reminder for SEC Webcast

Today the SEC updated their official SEC EDGAR Standard Taxonomies page to announce forthcoming support for the US GAAP 2009 taxonomies.  On the site, the SEC states that July 22, 2009 is when the EDGAR system will officially support these new taxonomies.  This means that as of that day, XBRL test/live filings based on the  the 2009 taxonomies against the EDGAR system can be done.  Until then, test/live filings can only be done using the 2008 taxonomies.

In addition to this roadmap, the SEC "strongly encourages" companies to begin working with and using the 2009 taxonomies.  I agree completely!!...but what does a company do between now and July 22nd to make sure their 2009 taxonomy-based XBRL data is mandate-ready?  I'd recommend (shameless gratuitous plugs aside...=) the Bowne Interactive XBRL Viewer as it provides not only the visual review of XBRL data but also SEC mandate-level validation when uploading files.  Give it a try and let me know what you think!

Finally, a reminder of the SEC's webcast Wednesday, June 10, 2009 starting at 12 PM ET to discuss Interactive Data Reporting Requirements.  One of the key items of interest on the webcast was going to be listening for the SEC to provide an update on support for the 2009 taxonomies.  Now that that's no longer an issue...=)...there's still lots of interesting tidbits that should be discussed.  This includes clarification around points of conflict within the EDGAR Manual, tagging guidance around topics not covered directly by the EDGAR Manual, and specific discussion on the US GAAP 2009 taxonomies themselves.

Happy tagging!

-Rob

Here A (XBRL) Viewer, There A Viewer...And the Fox and the Chrome

Sounds like a complicated kid's story, doesn't it?  Well, it kind of is...but this story has to do with XBRL viewers at the SEC instead of a weird mix of farm and forest animals.  With the start of the interactive data mandate on April 13th, there seems to be some confusion as to which XBRL viewer the SEC is using, and where.  Add to the mix that one of the viewers doesn't play nice with at least two of the leading web browsers and things get a bit interesting.

The first XBRL viewer the SEC rolled out over two years ago, the Interactive Financial Reports Viewer (let's call it the Old Viewer) has been modified to now only display Voluntary Program filings and thus why looking at it's "Home" page makes it seem like there hasn't been any XBRL filings made to the SEC since April 10th (when in fact, there has been).  Since most (actually all) of the SEC XBRL filings coming in at this time are under the mandate program (roughly 95+% of all operating companies are covered by the mandate), this Viewer won't see much action going forward.

The second XBRL viewer is "new" (in fact, let's just call it that...the New Viewer) and is currently available in two forms, one known as the SEC IDEA Previewer, and the other as simply "the-viewer-that-displays-XBRL-data-when-I-click-on-the-round-Interactive-Data-button-next-to-any-live-filed-XBRL-document-made-since-April-13th" (say that 10 times fast...=).  The New Viewer contains a number of enhancements rendering-wise over the Old Viewer as well as supports the new Section 6 Interactive Data requirements of the EDGAR Manual.

Why's the New Viewer discussion so important?  Two reasons.  First, If you've created XBRL data for the SEC prior to the mandate starting but have yet to see it in the New Viewer, you're in for quite the...ummmm...let's just say "eye-opener".  With the new requirements found in the EDGAR Manual (my favorite: 6.13.3), and given some of the previous hard-coded business logic that was in the Old Viewer that has now been removed, I think it safe to say your XBRL will look quite differently than you've seen it before.

Second, don't be alarmed if the New Viewer evolves over time.  Although the core of the New Viewer is solid, there are still a few issues with it that may or may not be addressed going forward.  For example, the New Viewer currently has a little bit of problem displaying block-tagged Notes if you're running it in Google Chrome or Firefox.  Okay, I'm being nice...it has a LOT of problems viewing block-tagged Notes in Chrome or Firefox.  So, make sure to stay more mainline and use Microsoft Internet Explorer when viewing any mandated filings using the New Viewer.  And don't think about including the single-quote " ' " in the XML Name of your Statement of Stockholder's Equity report, or it causes bad things to happen to your XBRL in the New Viewer...a scary story we'll leave for another time.

-Rob

New US GAAP 2009 XBRL Taxonomies Now Available

[First paragraph updated as my original post was done while XBRL US was still getting their web site set up.]

Today XBRL US rolled out the long-awaited new US GAAP 2009 XBRL taxonomies.  The new taxonomies can be found here and are available for reviewing using their online taxonomy viewer.  From an initial glance, the same 5 industry entry points found in the 2008 taxonomies are still supported (Commercial and Industrial, Real Estate, Insurance, Banking and Savings, Brokers and Dealers) as well as the Document and Company Information (DCI) taxonomy have been updated.  New in the bunch is the updated Schedule of Investments for mutual fund companies.

The only "grain of salt" as of now would be that although the taxonomies are out and available for use, officially the SEC has yet to recognize these new taxonomies as being supported by the EDGAR System.  The Kevin Bacon-esque flowthrough on this is that the Final Rule refers to the EDGAR Manual to find the list of supported XBRL taxonomies, and the recently approved updated EDGAR Manual (just updated today, in fact) refers to this web site for the official listing of recognzied EDGAR Standard Taxonomies.  Unfortunately the new 2009 taxonomies are not yet listed while the 2008 taxonomies remain on the list (and honestly have to remain on the list, as the SEC simply can't shut these down over night).

I'm sure this is only a timing issue and now that the taxonomies are actually out, the SEC will move quickly to update the list of Standard EDGAR Taxonomies to include the new 2009 taxonomies.  Until this occurs, the official SEC party line is that filings based on taxonomies not on the list are not supported by EDGAR and thus test or live submissions cannot be done using them (although work-arounds do exist...=).  

Net net is this is great news as it represents the final outstanding piece to the start of the mandate puzzle.  I would recommend anyone currently tagging data, or soon to start, move aggressively to begin reviewing and ultimately tagging with these new taxonomies, especially those companies impacted by FAS160 or FAS141R.  Having said this, I do find it interesting that the taxonomies have a February date and yet they just released today.  A bit peculiar, isn't it?...=)

-Rob 

SEC Publishes Lists of Detailed XBRL IDEA Errors and Warnings

The SEC has published a list of XBRL "error" and "warning" messages that accompany the checking they'll be doing on test and live-filed XBRL documents that are filed under the mandated program:

SEC XBRL IDEA Errors and Warnings List

This list can be thought of as as the implementation side of the new EDGAR Manual Section 6 "Interactive Data" rules.   "Errors" are issues with XBRL documents that will cause an XBRL filing to be rejected while "warnings" will not.  The list counts 829 errors and 19 warnings and are mostly technical in nature.  

One important clarification that I already see in the lists is Warning #8, which addresses XBRL calculation inconsistencies.  The importance of this is simply what list it's in, and that's the "Warning" list and not the "Error" list.  This means that XBRL calculation inconsistencies will not cause an XBRL filing to fail and therefore helps clarify EDGAR Manual Interactive Data rule 6.15.2.  The topic of XBRL calculation inconsistencies is worthy of a whole separate blog post...and in fact, will be.  For now let's leave this chalked up to these lists providing additional clarity around the EDGAR Manual, which is a very good thing.

Definitely keep this URL handy for mandated filings, and cross your fingers that the other main piece of the SEC XBRL mandate puzzle yet to see the light of day, the link to the new US GAAP 2009 taxonomies, is coming soon.  I mean come on...they have to be coming soon, right?  Three-to-four months before the first mandated filings hit, and less than 30 days before the first voluntary mandated filings hit, and STILL NO NEW TAXONOMIES?!

Note to XBRL US and the SEC:  If you'd like to talk to a few registrants to get their take on the impact these new taxonomies not yet being available is having on them, I'd be happy to facilitate the calls.  Open offer...take it or leave it...=).

-Rob

SEC EDGAR Manual XBRL Changes: More Than Meets The Eye

Yesterday I was tipped off by a big West Coast tech company that felt the tracked changes identified by the SEC in the latest draft version of the EDGAR Manual that came out yesterday (available here) weren't all they were tracked up to be...;o).  Curiosity was getting the best of me so I did a PDF compare of the December 2008 EDGAR Manual and the March 2009 EDGAR Manual draft versions, focused solely on the interactive data (XBRL) section, and the results are contained here:

Download Bowne_SECEDGARManualsXBRLComparison 

As you can see, there are way more changes than what's initially apparent by solely looking at the March version.  To better understand the tracked changes contained within the document, the following legend applies:

RED changes:  SEC identified changes

GREEN underlines:  New content not identified by the SEC

YELLOW triangles:  Deleted content not identified by the SEC

(Did that just come off like a Sesame Street episode??)

For those looking to jump in and simply get the latest/most current validation scoop, then this comp document probably isn't a big deal.  For those looking to see what truly changed from the December to March draft, enjoy!

-Rob

Latest Draft of EDGAR Manual and XBRL Validation Rules Released

The SEC has released an updated draft version of the EDGAR Manual (now officially referred to as Version 11) that contains detailed validation rules for mandated XBRL filings.  The link to the PDF is here (be ready...it's 18 MB) and although still a draft, the SEC is expected to vote on this and, if approved, is scheduled to take effect on Monday, March 16, 2009 (which should not be confused with the start of the mandated filing program, which is April 13, 2009).

My initial reaction from doing a review of the tracked changes is that much has stayed the same from the original draft released back in December while a number of the specific rules have had their examples modified or firmed up.  Although a small change in the midst of the 125+ rules contained within, it is good to see that the list of special characters not allowed in XBRL labels has been modified to now allow the following:

":", ";", "&",  and "%"

Although purely cosmetic in nature, this change will allow XBRL labels such as "In-process research & development" and "Gain on repurchase of 1% Convertible Subordinated Notes" to match their HTML brethren...which is a good thing.

Unfortunately a number of the specific rules I was hoping would have their examples made stronger/more direct to the tagging process did not.  Specifically, search Secton 6 and you will not find reference to "Audited" or "Unaudited" data although item 6.6.11 says:

"An instance containing multiple reports about the same entity for the same periods under different reporting assumptions must distinguish the facts in different reports using xbrli:context elements whose xbrldi:explicitMember elements have a dimension attribute of us-gaap:StatementScenarioAxis"

...and then refers to "actual" data in the example when instead it could/should provide an example of how to tag "Audited" and "Unaudited".  Call me crazy that it'd be a good idea somewhere within the XBRL rules to address this since most companies at some point identify portions of their data as such.

And then there's still a few inconsistencies such as:

5.2.4.1 The XBRL portion of a submission is comprised of two major components:

                1. One or more instance documents

6.1  One or more instance documents (instances) that contain actual data and facts

6.3.8.  A submission must contain exactly one EX-100.INS [voluntary program instance document] or EX-101.INS [mandated program instance document]

Regardless, it's still very good to have this out in a more final draft so we can all finalize preparations for XBRL filings on and after April 13, 2009 (the start of the mandate).  Now, if we can only get the SEC via XBRL US to approve and release the US GAAP 2009 taxonomies, all the core pieces of the mandated filing puzzle will be in place.  Putting the pieces together...well, that's for a different blog post...=).

-Rob

XBRL Final Rule for Mutual Funds Now Available

Another proverbial shoe dropped in place today as the SEC released the XBRL Final Rule for Mutual Fund Risk Return Summary on their website. At first glance, the rule looks to follow many of the items originally included in the Proposed Rule (save for the start date), and with the operating companies XBRL final rule, as follows:

1. Effective January 1, 2011 for all open-end mutual funds
2. Focused on Form N-1A  
3. Must be submitted concurrently or within 15 days of traditional (HTML) filing
4. Must be posted on company website by end of submission calendar day 
5. Penalties for not submitting
6. Limited legal liability, with provisions ending October 31, 2014 

Although the voluntary program is quickly coming to an end for operating companies, mutual funds are able to continue to submit risk-return information voluntarily through December 31, 2010, and indefinitely for their financials.  In addition, mutual funds can submit just portfolio holdings in XBRL without having to submit other financial (statement) information.

Good news is the entire rule is only 114 pages (almost 100 pages less than the operating companies rule).  Happy reading and stay tuned for a Bowne Plain English overview of this rule coming soon.

-Rob

XBRL Final Rule hits Register; Voluntary Program End Date Established

More pieces of the final rule puzzle continue to fall in place, as today the XBRL mandate final rule hit the Federal Register.  This is important for two reasons:

1. Rule is now officially recorded/"on the books"
2. Provides start date of the rule:  April 13, 2009

The latter clarifies an open point that's been unaddressed since the vote to approve the mandate back in December, and that's when the current voluntary filing program comes to end.  Looks like we have our answer.  It's April 12, 2009...the last day for companies to be able to submit XBRL voluntarily, and under the rules of the voluntary program.  Come April 13, 2009, it's the dawn of a new filing day...and the start of the SEC enforcing the XBRL submission rules contained in the EDGAR manual.

The final version of the revised EDGAR manual is the next puzzle piece we await, and our hope is it's not too far from seeing the light of day given the complexities found in the draft version.

Is it Live, or is it Memorex?: SEC XBRL Validation Fake-out, Part I

SHORT VERSION:  You do not have to use the US GAAP "Document and Entity" tag EntityPublicFloat to file XBRL documents currently to the SEC even though this tag is part of the "Public Validation Criteria" that the SEC (supposedly) started validating submissions against as of December 15, 2008.

LONGER VERSION:  A few blog posts back I talked about the SEC's release of XBRL creation (validation) criteria via the Public Validation Criteria (PVC) and the revised EDGAR Manual (still a DRAFT version at this time).  A quick recap for those just joining us, the PVC can be thought of as a subset or precursor to the complete set of rules contained in the revised EDGAR Manual that will be the basis of validating all mandatory filings.  However, since the revised EDGAR Manual is not yet final, the SEC had to find a way to start enforcing some of these validation rules sooner rather than later, so they did so via the PVC...starting on December 15, 2008...or so we thought.

The PVC contains a list of 26 rules, one of which (number 2) details 13 "document and entity" tags that XBRL submissions must contain when filed to the SEC.  One of these 13 tags is EntityPublicFloat, data of which is typically found on a 10-K but not a 10-Q.  Today a client who was finalizing a Q-based XBRL filing asked:  "If the Entity Public Float tag is required tag by the SEC, and yet we don't include that information on our Q, what should we put as a value for the tag?"  Hmmm...good question.

My first thought was to tag using a blank (or "nil") value for the tag and include it in the client's filing, but due to a bug in the SEC Viewer, this wouldn't be picked up and displayed.  Next step was to check out a couple of recent live filings to make sure this tag really did have to be included in the submission.  Much to my surprise, I noticed Philip Morris' most recent filing did NOT include this tag.  Hmmm...strange...since again this tag is on the PVC list and the SEC (supposedly) started enforcing this list 12/15/2008.  Something wasn't computing since Philip Morris clearly was able to live file without this tag so...

...after running a few test filings internally, yep, it's true...XBRL submissons don't currently need the EntityPublicFloat tag...even though it's supposed to be required.  Live?  Memorex?  Man, my brain hurts trying to keep all this straight.  I'm sure the SEC will sort this out as they tighten up ship in preparation for the mandate but the moral of this story goes something like this:

If you're in to moving targets, stick around for a while...this is bound to get even more interesting as we approach the start of the mandate.  If you're trying to test or live file XBRL documents to the SEC over the next 60-90 days, don't place any weight on reviewing SEC filings made prior to 12/15/2008 and make sure you're working with someone that knows how to investigate and explain validation anomolies such as this.

-Rob

SEC Final Rule on XBRL for Operating Companies Now Available

So much for the mystery of whether the XBRL final rule would ever see the light of day...;o)

Today the SEC posted on their web site the final rule on XBRL for operating companies.  The link to the PDF is here and not that I'm telling anyone to skip pages, but the Summary of Adopted Amendments starts on page 20...=).  Hopefully you have a little free time on your hands as the document has grown from 143 pages (proposed rule) to 206 pages (final rule).

Happy reading...and stay tuned for more blog posts on specific aspects of the rule, as well as a Plain English overview of the final rule made available on our main XBRL landing page.

-Rob 

XBRL and the New Administration(s): Trouble Ahead?

How could one not feel at least a bit of (renewed?) pride in this country after watching President Obama's swearing in.  The people...the flags...the pomp...the circumstance...it was all there.  He took the oath, waved goodbye to GW and Mrs. B, and got down to business.  Oh alright, not right away, as he had a few galas to attend, but come Day Two...time to put away the tux and get down to business.

When it comes to XBRL and the new Adminstration (actually Administrations given the revolving door at the SEC), things were already a little up in the air with a new incoming Chair of the SEC (more on that later).  Not a big deal, right, as all the SEC had to do was move their rule making process forward and wrap the XBRL rules up before all this change started happening.  

What's that?  The XBRL rules didn't get finalized before yesterday?  Oh boy...I guess that means the government-wide memo from Obama's Chief of Staff Rahm Emanuel today effectively putting the breaks on all pending regulations comes into play with XBRL.  Although the SEC technically doesn't have to "follow"  a memo such as this (being an independent regulator), they almost always do...which means the final XBRL mandate rules are officially on hold since they had yet to hit the Federal Register.

On a quick digression, what's interesting to me about this is that Christopher Cox's time as Chair is over; he resigned yesterday.  As everyone knows, XBRL was Cox's baby.  He knew his time was short at the SEC and thus I would think have done everything possible to make the final rules official by getting them in the Federal Register BEFORE he left.  The reality is he didn't...or couldn't (Conspiracy Theorist Alert:  Was the holdup inter-agency vs. intra-?)...and now the rules have to wait in line for review by the Obama Administration. 

Adding to this air of XBRL uncertainty is new SEC Chairperson Mary Schapiro.  Although pro-investor and familiar with the turf, she takes over the SEC in a time of crisis with what I'll presume are a number of urgent matters in line ahead of XBRL.  Although it's expected her confirmation as Chairperson could come as soon as next week (Senate Banking Committee testimony coverage here, video here), I bet she'll want to get her new house in order before doing anything too drastic (good or bad) with XBRL.

So, where does this leave XBRL?  Although my crystal ball is a bit cloudy right now (nothing to do with the "I-really-wanted-to-be-at-an-Inaugural-Ball" beverages I had last night), I would tend to lean towards the sentiment expressed by Diane Mueller in her CIO post.  XBRL is a good fit at both the Administration and incoming SEC Chair level, does good for a number of key constituents in this information supply chain, and has even been embraced publicly by many companies (okay...fine...mostly larger ones, but any is better than none, right?).  

The next few weeks will obvioulsly hold the answer to the main question:  Can XBRL survive the storm of change hanging over DC?  I believe it can...and will...and thus my recommendation for all Group 1 companies to stay the course and continue preparing for a June 30th-based mandated XBRL filing.  Anything less would be...well, unpatriotic...=).

--Rob

Did Someone Say Guidance? SEC Releases XBRL Creation Rules...Not Once, but Twice

With all the holiday egg nog finally starting to dissipate, I reflect back on the mandate craziness that happened during the last part of December.  Much of the attention of course was focused on the meeting on December 17th but equally as important were two events that harken back to the mid-80's and the onset of the two-phase commit in the database world.  Although not a direct parallel (came across my SQL Server 4.21 install floppy disks...what can I say..=), the SEC has made it clear that the relative chaos that comprises today's voluntary filings is soon coming to an end.

The first phase of this commit(ment) to validation criteria on XBRL documents was the Public Validation Criteria, comprised of 26 rules that were originally released back in September but never enforced.  Although a good start, more interesting about these rules is that the SEC started validating them ahead of the mandate meeting...and they never really told anyone they were doing this (file at your own risk!).  Quite the surprise as companies filing that week and since found their filings rejected because they were suddenly missing required data (Criteria 2. Document and Entity Information).

The second phase of the commit(ment) came later in the month when the SEC released a draft version of the EDGAR Filing Manual Volume II Version 10.  These validation rules are the hammer to the Public Validation Criteria's nail in both size and depth, comprising over 50 pages and 100+ rules (Section 6, pages 153-206).  Although still in draft form and thus not being used currently to validate XBRL submissions, this (and the Public Validation Criteria to a lesser extent) is a significant move by the SEC. During the Voluntary Program it's been all open arms and welcomes. This marks the first time the SEC has provided detailed guidance on the preparation, submission and validation of XBRL data.

Given its in-your-face blend of heavy technical geekspeak intermixed with business reporting concepts, the time is now for anyone involved with SEC XBRL filings to begin digesting the draft rules.  Companies considering whether to tag themselves or outsource the effort should evalutate the difficulty in absorbing, implementing and keeping current with the requirements (trust me...the SEC is certain to revise these criteria) as well as making sure any vendors they choose can do the work correctly.

I've often been asked if the SEC has ever provided any rules of the road. Well, here they are...read 'em and weep.  No resting on the laurels of previous XBRL filings...play time is offically over.

R*Ed

It's XBRL Mandate Time...Play by Play

Finishing off what they started May 14th, the SEC meeting to mandate XBRL for operating and mutual fund companies is about to begin.  Although this meeting is happening a bit later than many had hoped, at least it's happening so we can gain some clarity and closure based on what was originally included in the proposed rule.  I believe most eyes (and ears) will be focused on at least two main points of the proposal:  When do mandatory filings begin, and Year 2 detail Notes tagging.  It's the latter that has been keeping people up at night so I'm really hopeful they'll discuss this during the meeting.

First up on the agenda is the PCAOB 2009 budget.  So, while I do a little last minute "XBRL stretching" in preparation for The Big Game (agenda items two and three dealing with XBRL), get the popcorn and remote...it's mandate time...=).

Okay then...now that the PCAOB is on their way for 2009, it's XBRL time...here we go...

12:25pm:  Time for the vote...both rules pass 4 yeah's to 1 nay.  Recommendations are approved...and somewhere in the State of Washington, Charlie Hoffman is smiling, and deservedly so.  Thanks for calling me in 1999 and letting me in on your crazy idea...looks like it wasn't so crazy after all...=).

12:23pm:  John White responds to Commission Aguilar's liability concerns by confirming/summarize what's being recommended in the final rule.  The limited liability provisions are only in effect for first 2 years of interactive filings; after that, no more special liability provisions and all limited liability provisions will be sunset by 2014.

12:17pm:  Commission Paredes opens his comments in support of the final rules.

12:16pm:  Commission Aguilar states that IF existing liability were applied to XBRL, or XBRL were simply furnished, then he'd be supportive of XBRL...but as written in the final rule, he can't be.

12:10pm:  Commission Aguilar throws down and DOES NOT SUPPORT XBRL for both intiatives, pointing out that the rules weaken the liability provisions currently in place.  Very concerned about protecting investors and feels that the rules do not provide adequate protection; calls out various aspects of final rule 406 that carves out liability for certain events, even if harm has been done to investors.

12:09pm:  Commissioner Walter echos support for XBRL and has no additional questions.

11:53am:  Commissioner Casey express support for the final rules and reviews phased-in schedule and seems to clarify a point I missed originally on the phase-in schedule for operating companies and that is the first group start date is delayed until June 15, 2009  but the second and third group start dates remain December 15, 2009 and December 15, 2010 respectively. 

11:47am: Chairman Cox asks about applicability of XBRL for ABS and it's reinforced by Staff that it is important, but it was also reinforced that the final rule would not apply to ABS data.

11:42am:  Chairman Coxs asks for clarity on the detailed notes tagging; refers to it in the entirety as "optional".  I'll have to go back and read the minutes as I could have sworn there's still something "more"/different about the Year 2 Notes tagging versus Year 1 Notes tagging.

11:39am:  Mutual funds can still submit only portfolio holdings information in XBRL to meet the interactive data requirements.

11:38am:  BIG CHANGE:  MUTUAL FUND MANDATE START DATE:  Initial registration statements after January 1, 2011 instead of December 31, 2009 as detailed in the proposed rule; voluntary program extended from December 31, 2009 through the new effective date of the mandate.

11:36am:  Must submit risk/return information in XBRL within 15 days of HTML submission and within 15 days after the prospectus becomes effective

11:34am:  Funds must put XBRL on corporate web sites, and they can do so by the end of the CALENDAR day instead of BUSINESS day

11:33am:  Switchover from the operating companies rule to mutual funds rule

11:32:  Phase-out of limited legal liabilities after 2 years...and no change on the auditing requirements: A company is not required to have their XBRL audited during the phase-in, but they optionally can.

11:31am:  Looks like the SEC extended the XBRL love "North of the US Border" by picking up 40-F filers.  I was never clear on why 40-Fers were left out of the original proposal rule and yet 20-Fers were included...so I guess that takes care of that.

11:30am:  Existing voluntary program extends for 60 days after the final rule hits the register and then XBRL filings fall under the final rule requirements.  Lining up the calendar, the final rule should hit the register in January...60 days would take us to roughly to March...and the mandate starts June 15.

11:29am:  Grace period of 30-days for first filing and first filing of Year 2 Notes detail tagging still in place; must have missed if they added the ability to file these on an 8-K, or whether they must be amended filings.

11:28am:  BIG CHANGE #2:  OPERATING COMPANY MANDATE START DATE:  Mandate starts on filings for fiscal periods on or after June 15, 2009.

11:27am  BIG CHANGE #1: DETAIL NOTES TAGGING:  Appears the final rule will back off the detail tagging of the Notes...sounds like only tables in Notes have to be tagged in detail, but not the narratives...very interesting but not unexpected.  Have to see the detail...

11:26am:  Companies still have to maintain XBRL on corporate web site and XBRL supplied in addition to HTML over the course of the phase-in.

11:25am:  Domestic and foreign companies using US GAAP, and eventually IFRS-based filers...and sounds like same form types as detailed in the proposed rule in May

11:20am:  Interesting that they're really driving home today as the start of the new IDEA system as the eventual replacement for EDGAR; a sign of things to come in the final rule?  I'm guessing yes...anyone taking bets that the rule starts 12/15?  =)

11:10am:  "Brick and mortar"...the Chairman is really laying the framework for the importance of XBRL, not just for corporate financial statements but other data such as ABS, mutual fund holdings, etc.  Today's two rules are just the start of what appears to be the potential for more to come...only time will tell.

10:58am:  First news item although still a bit "raw"...new primary SEC web page for interactive dislcores.  Still curious to see how the IDEA name conflict with Caseware sorts out but I digress...good to see the SEC standing up new pages to help differentiate traditional submissions vs. interactive ones.

10:56am:  Visual aids are always good and the Chairman using an old ledger to drive home the point of the importance of interactive data (XBRL) helping move the global capital marketplace into a new age is a good one.  With a rich flow of XBRL information about to start, the analysts/investors finally have a chance to get enough XBRL data to matter.

EDGAR Prepares for XBRL Mandate

This morning on the EDGAR Filing website, the SEC announced some changes to EDGAR under the heading "XBRL Mandate". These include a new Exhibit 101 "to support the XBRL mandate" and the integration of additional XBRL validation rules as spelled out in the Public Validation Criteria document.