The Committee on Corporate Reporting (CCR) of Financial Executives International (FEI) has sent a letter to the SEC stating that "..the process of detailed note tagging may be more difficult than it needs to be and, as a result, may cause delays in the release of SEC filings to investors." The letter raises concerns about high costs, inadequacy of XBRL tools, and slight interest from the investment community for XBRL exhibits.

The letter states several findings from an FEI member survey that followed quarter-end June 30, 2010, XBRL filings. Noting that the survey's results apply only for 10-Q's (quarterlies) and detailed tagging for (annual) 10-K's may result in "more issues," the CCR described several problem areas that can be summarized as follows:

·Third-party XBRL providers told members that a 48-hour window was necessary to finalize a change to a filing. Almost half of members indicated they would have filed earlier had it not been for the delays caused by the new requirements.

·The resources necessary to prepare XBRL filings varied widely, from a low of 12 hours to 2,000 hours per quarter to detail tag the most sophisticated financial statements. External implementation costs per quarter also varied significantly, from several thousand dollars at smaller companies to $500,000 at the largest filers.

·Overall, members found the tools available to review the XBRL files to be inadequate to identify errors in the filing.

·Of those companies that monitor information usage on their websites, none reported more than a slight interest in this XBRL information from the investor community. The number of hits ranged between 3 and 20 hits per quarter and some of those may have been either employees of the company or the service provider.

Based on these results and subsequent reports from members, the CCR makes three recommendations, which can be summarized as follows:

·Allow up to 1 week between the filing of 10-Qs/10-Ks and the submission of the XBRL files, without requiring the submission of the XBRL filing to be an amended filing and subsequent event evaluation/update from the original filing.

·Allow block tagging only for non-standard/company specific notes (e.g., footnotes for litigation, acquisitions, divestitures, etc.) where the numerical information contained in the disclosure will almost always be unique to a particular filer and therefore not fit for XBRL’s intended purpose.

·Allow wholly-owned subsidiaries that qualify for the abbreviated disclosure rules to be exempt from the detailed tagging requirements.

FEI is a leading international organization of 15,000 members, including Chief Financial Officers, Controllers, Treasurers, Tax Executives and other senior financial executives; CCR is a technical committee of FEI. The letter, which can be read online, represents the views of CCR and not necessarily the views of FEI or its members individually.