SEC Final Ruling

A few known facts from the final ruling for the Interactive Data for Mutual Fund Risk/Return Summary that you might be interested to know:

pliance Date: The rule requires that all mutual funds must submit interactive data (XBRL) of risk/return summary information from the prospectus filed pursuant to rule 497(c) or (e). The first required submissions will be for initial registration statements that beme effective after January 1st, 2011. The interactive filing must be filed after effectiveness of the related filing, but no later than 15 business days after the effective date of the related filing.

Liability: New rule 406T of Regulation S-T addresses the liability of and interactive data file. The liability provision is less severe than that of the full filing but it is only applied until October 31, 2014, and, thereafter, an interactive data file will be subject to the same liability provisions as the related official filings.

Data Tags: Under the rule, mutual fund mpanies are required to submit their risk/return summary information using the most recent list of tags released by XBRL US as approved for use by the SEC. Interactive data is required for the entirety of the risk/return summary information, including information for all series and all classes. One of the useful aspects of interactive data is its extensibility (filers can create custom tags to acmmodate unique circumstances); however, the use of custom tags also rces the ability for the public to mpare similar information across funds. In order to promote mparability across funds, the SEC is adopting the rule provision that limits the use of extensions to circumstances where the appropriate element does not exist in the standard list of tags.

How to Prepare Interactive Data for Mutual Fund Risk/Return Summary

The process of preparing an interactive filing for mutual fund risk/return summary is not that different from preparing an interactive filing for a rporate financial report. However, mpared to the mplexity of the US GAAP taxonomies (which ntain over 15,000 elements), the risk/return summary taxonomy is much, much smaller (< 400 reporting elements, what a relief!) and therefore should be simpler to understand and navigate.

With the Crossfire Reporting Platform, all mpany taxonomies and tagging templates would be reusable across funds for a given mpany. The following diagram depicts a typical process for a mutual fund mpany that uses Crossfire for preparing their filings.

Figure 1 – Using Crossfire to Prepare Interactive Data Filings

The Crossfire Wizard enables the preparers to create funds and classes automatically and dynamically to:

(1) Rce the time to create the “dimension members” and prevent errors;

(2) Allow the preparer to just create a single extension taxonomy and dynamically attach proper funds and classes for interactive data filings.

Within Crossfire, the preparer can easily format the BAR CHARTS (for annual return data) and create TABLES to disclose the Shareholder Fees and Operating Expenses data.

Figure 3 – Crossfire – Create Tagging Template/Populate with Data – Using Excel to Customize Bar Chart

Figure 4 – Create Tagging Template/Populate with Data – Using Excel/Word to Format Tables/Footnotes

Can’t Start Soon Enough

It’s time for mutual fund mpanies to start evaluating options for preparing interactive data based on the risk/return summary taxonomy. Lessons learned from the mandate of filing XBRL for rporate financials should also be valuable for executives in mutual fund mpanies.

So what can finance executives do now to lessen the pain? “My remmendation is that people get involved as far in advance as practical,” says Fred Bleier (chief acunting officer at International Paper) whose mpany ran into last-minute software glitches despite months of preparation and a test filing last year. (Read the article in CFO Magazine)

Start early, and look for solutions that are designed based on a deep understanding of XBRL, mutual fund risk/return summary taxonomy and EDGAR filing rules and you will guarantee suess in 2011.

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