XBRL and SEC Enforcement

So if XBRL radically increases the SEC's enforcement capabilities, and we believe it does, one of the goals is to submit high quality data. This seems obvious (so does filing a Form 4 on time) but what exactly does high quality data look like? So far the SEC has been relatively quiet but we have two important sources which give us plenty to work on.

The first is a speech given by Corey Booth in mid 2006. In it he outlines 4 types of errors the SEC identified in data submitted to the voluntary program (which we've previously detailed on Securities Connect):

• Uncertainty about plus and minus signs
• Calculation inconsistencies
• Inconsistent tag choice
• Inconsistent tag creation

In  addition, page 58 of the rule proposal outlines 6 accuracy checks that they plan to perform on the data:

• Check if required conventions (such as the use of angle brackets to separate data) are applied properly for standard and, in particular, non-standard special labels and tags
• Identify, count, and provide the staff with easy access to non-standard special labels and tags
• Identify the use of practices, including some the XBRL U.S. Preparers Guide contains, that enhance usability
• Facilitate comparison of interactive data with disclosure in the corresponding traditional format filing
• Check for mathematical errors
• Analyze the way that companies explain how particular financial facts relate to one another

We've already covered signage and we'll go through the rest of these validation-related topics over the next couple weeks so that, as many of you prepare and/or review your first data filings to get ready for the mandate, you'll have some sense of what to look for.

-- Ed Hodder