On October 6, 2009, the SEC issued “Staff Observations From Review of Interactive Data Financial Statements,” identifying improvements to the quality of XBRL submissions. The Staff commented on rendering, element selection, context references, negative values and negated labels, decimals and other observations.Below, please find the items from the SEC Staff’s observations that we believe you should be aware of.

Rendering

The SEC continues to emphasize the following:

n        Filers should not deviate from the EDGAR Filer Manual rules and jeopardize the quality of their XBRL files in order to correct rendering issues.

n        There is no requirement that the rendered files appear identical to the HTML/ASCII filing.

n        Filers should expect differences between the HTML/ASCII filing and the rendered XBRL files. Some of the differences are: Formatting,  column headings such as “Unaudited” and subheadings such as “Current Assets,” totals and subtotals, and format of the shareholders’ equity statement including how certain columns and subtotals render. However, certain differences can be eliminated such as: Labels should match, abstracts for headers should be used and each footnote should be presented separately.

Element Selection

The SEC Staff has identified 12 examples of common issues and as a result, encourages filers to:

n        Carefully search through the entire taxonomy to find an element with the narrowest definition that captures all material information.

n        Be aware of elements that are industry specific.

n        Do not create an extension when a) an appropriate standard element exists, and b) representing identical concepts reported on multiple financial statements within the same submission.

n        Create extensions when a) the standard element does not adequately capture all material information, b) combining the concepts of two or more standard elements, and c) splitting two concepts in a standard element.

n        Tag all amounts appearing in parenthesis and present them separately from the face of the financial statements.

Context References

Context references allow tagged information to be understood in relation to other information presented. The SEC staff notes:

n        Filers should use the same elements for common line items but create unique contexts (dimensions) to distinguish financial information for subsidiaries, businesses and segments.

n        When reporting roll-forwards, such as the statement of shareholders’ equity, filers should use the same context reference for the beginning balance and the ending balance of the previous period.

Negative Values and Negated Labels

The standard taxonomy is designed so that the monetary amounts for most elements should be entered as positive values. Filers should properly distinguish negative values and negated labels. For example, negative values should be used to represent a loss for an element that has both a gain or loss concept. Negated labels should be used to render a balance in brackets.

Decimals

Tagged amounts should accurately reflect the rounded values reported on the financial statements.

Other Observations

Filers should provide debit/credit balance types for balance sheet and income statement monetary extensions. In instances when an extension can take a positive or negative value in different periods (most commonly on the cash flow statement), filers should either assign an appropriate balance type or provide a definition.

Filers who are not amending their XBRL filings should set the Amendment Flag to “false” and should leave the Amendment Description blank.

Filers should post their Interactive Data exhibits on their corporate website by the end of calendar day on the day of submission. Furthermore, the SEC discourages compressing the Interactive Data files in a .zip file as it may make it more difficult for the end users to access.