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With the adoption of Rule 33-9006 last year, the SEC mandated that mutual funds (i.e., open-end management investment panies) provide their risk/return summaries in XBRL format. Gearing up for the pliance date of January 1, 2011, the SEC held a seminar for filers on June 4, which is now posted online along with the acpanying slides.
Here’s a roadmap to the 2-hours presentation which highlights key points and, I hope, helps readers find what they need.
(0:00 to 28:45) These introductory presentations by David Blaszkowsky, Director of the Office of Interactive Data (OID), as well as Andrew “Buddy” Donohue, Stephen Sadoski, and Brent Fields, all of the Division of Investment Management, will be of primary use to those new to XBRL.
(28:45 to 40:00, Slides 7 to 14) Mr. Fields’s discussion of which mutual fund filings require interactive data exhibits, requirements for posting XBRL data on pany webs, penalties for nonpliance, liability issues, and so forth will be mostly of interest to practitioners with specific responsibilities for mutual fund filings. Mr. Fields reiterates that on April 12 the SEC announced pletion of the updating of all the technology infrastructure necessary for filing risk/return data in XBRL; the risk/return taxonomy, Previewer, Viewer, and EDGAR validator have all been updated.
(40:00 to 1:02:00, Slides 15 to 24) Much of this general overview of XBRL and its use by the SEC by Mr. Sadoski is not specific to mutual funds, but it will be helpful for those relatively new to XBRL. At 49:00 – 50:30, he makes the useful distinction between mapping – the matching of line items within traditional statements to elements in a taxonomy that is typically done by acuntants – and tagging, the technical process of representing those elements in XBRL files which is typically performed by IT staff. At 58:00 – 59:15 (Slide 27), Mr. Sadoski’s discussion bees specific to mutual funds as he describes exactly what XBRL data needs to be posted to the fund’s web. At 1:00:00 to 1:01:00, he discusses important documentation for guidance in filing (Slide 28).
(1:03:00-1:13:00) Walter Hamscher of the OID begins his talk by discussing the key points (Slide 31) he wants to emphasize:
The 2010 risk/return (R/R) taxonomy:
Is like the US GAAP Taxonomy
"[The 2010 risk-return taxonomy] is intended to be…very nsistent with the architecture of the US GAAP and the rporate filings and the other XBRL activities that we are undertaking here at the SEC.” As with rporate XBRL filings, there is heavy use of text blocks and dimensional tables.
Is only 2% the size of the US GAAP Taxonomy
The taxonomy is not only nsiderably smaller but nsiderably simpler. He urges listeners to pay very close attention to the samples the SEC has provided.
Requires few custom elements for most filings
While extensions are mon for XBRL rporate filings, they will be relatively rare in risk/return filings. The only extension elements that will need to be created will be those based on series and class identifiers associated with the funds being reported. (Later on, he adds that where there are multiple prospectuses, sometimes there will need to be extensions for those too.)
The SEC Viewer/Previewer upgrades:
Support different layout and styles of tables
The Previewer and Viewer have been substantially upgraded and now offer more flexibility for layouts and table styles.
Renders distinct series in a filing nsecutively
Mr. Hamscher says that the rporate filing Previewer did a “rather poor job” of reporting on multiple entities. An enhancement allows mutual fund series to be handled much better.
Integrates closely with the risk/return 2010 taxonomy
The risk/return taxonomy is tightly integrated with the rendering engine enhancements, and the Viewer and taxonomy now work much better together. Mr. Hamscher urged filers to take advantage of this improvement.
(1:13:30, Slide 32) Mr. Hamscher describes three resources that technical staffs will find crucial for suessful pliance: Architecture, Rendering Guide, and Sample Instances. (The URL given on Slide 32 for the last item generated an error message for me; I believe I have provided the rrect URL here; but please let me know if that’s not the case.) He emphasizes that the Sample Instances will be very helpful for filers.
(1:15:00-1:48:00) Mr. Hamscher walks the audience through four filing samples with varying numbers of series, classes, and prospectuses (Slide 33). For each, he shows the original document; the rendering on the SEC web; a rendering of the details, i.e., a data view that will help filers check their work; the extension taxonomy; and finally the de in the instance document. He wraps up with a discussion of formatting enhancements.
(1:50:00 – 2:10:00) The Q&A session. One point Mr. Hamscher emphasizes is that filers should download the Previewer on their own machines (which the SEC has made it easy to do) and use it locally, rather than struggle with wait times on the SEC .
(2:10:00) – 2:14:00) Mr. Blaszkowsky makes his closing remarks.
As with other SEC seminars, this presentation was highly useful and informative. If your time is limited, I suggest you listen to Walter Hamscher’s talk for about the first half of the send hour to get the gist of the presentation. |