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The SEC Expands Use of XBRL and Validates RDG’s Commitment to Excellence

Wednesday, January 21st, 2015

On December 30th, the SEC significantly expanded its use of the XBRL data provided by public companies with their 10-Q and 10-K filings. It launched a new program that is designed to “facilitate investor analysis and comparisons of public company financial statement data” by consolidating the “data that companies provide in structured formats” into data sets that will be “posted for bulk downloads on the SEC’s website.” The program will begin using only the information provided in the base financials, but it will soon include data from the footnotes as well. The purpose of this program is to promote and expedite the use of XBRL data by investors and academics.

We are very happy that the SEC has begun using XBRL in this way. This step begins to validate the commitment we have long made to creating top-quality code that exceeds the standard of SEC compliance and is entirely useable for analysts and investors.

We are gratified the SEC has taken these steps, because the XBRL code we submit on behalf of our clients is excellent, compliant, and useable.

In the data sets the SEC has released, there will be a lot of code that was built by providers who outsource the XBRL overseas, or who have otherwise made a lesser commitment to quality XBRL data. Additionally, there will be a fair amount of code built by the reporting teams at individual companies who have taken the responsibility of properly structuring XBRL in-house. When the XBRL is poorly built, or created by people who are not CPAs and experts, there is a risk that the information made available by the SEC in these data sets will be an inaccurate reflection of the companies’ financial information.

Investment decisions by analysts and enforcement decisions by the SEC will be driven by the code in the XBRL data, and for that reason RDG has–since its very inception–been committed to having the best people creating the highest quality code.

XBRL is the future of financial disclosure, and RDG can help public companies create excellent and usable data. Please contact us to learn more about our Full Service Tagging Services and our XBRL Quality Assurance Services.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in SEC Compliance, SEC News, Structured Data, XBRL Filings, XBRL News, XBRL Quality Assurance | Comments Off on The SEC Expands Use of XBRL and Validates RDG’s Commitment to Excellence

The SEC Massively Expands Its Use Of XBRL Data

Friday, January 9th, 2015

On December 30^th, the SEC massively expanded its use of the XBRL data provided by public companies with their 10-Q and 10-K filings. The SEC announced and launched a pilot program designed to “facilitate investor analysis and comparisons of public company financial statement data” by consolidating the “data that companies provide in structured formats” into data sets that will be “posted for bulk downloads on the SEC’s website.” The program will begin using only the information provided in the base financials, but it will soon include data from the footnotes as well. The purpose of this program is to promote and expedite the use of XBRL data by investors and academics.

This program is the most significant expansion of the availability public companies’ financial disclosures since the advent of the EDGAR system in the 1990’s. For the first time, every public company’s base financials will be available in one data set, which means that investors and academics will no longer have to manually cobble together usable data from the information available in the archaic and individual EDGAR filings.

This announcement made on the penultimate day of 2014 capped off what was a big year for XBRL. This announcement put an exclamation point on a year in which the SEC dramatically increased both its use of XBRL and the attention it pays to structured data. Earlier in the year, the SEC conducted a staff assessment of the use of custom tags. In 2014, the SEC also began sending ‘Dear CFO’ letters to companies regarding required calculations in their XBRL exhibits.

With this move, the SEC has positively affirmed that XBRL is the present and the future of financial reporting. They have also sent an unmistakable message that public companies should take the necessary steps to ensure their XBRL data is well structured and properly usable. These public data sets are based on the XBRL only and are not verified against the content of the EDGAR document, so poorly constructed XBRL data will not provide an accurate depiction of a company’s financial disclosures. It takes an expert to create quality, compliant, and truly usable XBRL data.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in SEC Compliance, SEC News, Structured Data, XBRL Filings, XBRL News, XBRL Quality Assurance | Comments Off on The SEC Massively Expands Its Use Of XBRL Data

The SEC Enhances its Commitment to XBRL Data

Monday, October 20th, 2014

In the Opening Remarks at the SEC’s Investor Advisory Committee on Oct. 9, 2014, SEC Chair Mary Jo White discussed recent developments in the “Commission’s rulemaking agenda.” Chair White touched on reforms to enhance the transparency of money market funds, she described “two quite significant Dodd-Frank Act rulemakings,” and she touted a “very successful year in terms of both the breadth and quality” of SEC enforcement. For more detail, you can read the full remarks here, but Chair White did something that really caught our attention. Chair White made explicit mention of XBRL and other structure data initiatives, and described a deeper commitment by the SEC to the XBRL requirement.

Chair White described the use of structure data as an “important, ongoing priority,” and she said the SEC is continuing to find “ways to improve the quality and usefulness of structured data while reducing the burdens on companies as much as possible.”

Chair White also referenced a report by the Division of Economic and Risk Analysis (DERA) regarding its assessment “of the use of custom tags in XBRL exhibits.” As Chair White explained, DERA also “performed an analysis of calculation errors in companies’ XBRL,” which led to the Division of Corporation Finance issuing ‘Dear CFO’ letters to “several companies that failed to include all required calculation relationships in their XBRL data.”

These explicit mentions of XBRL by the Chair of the SEC were significant in their own right, especially in light of the continued and misguided efforts within the halls congress to gut the XBRL requirement. However, we were particularly happy to hear Chair White’s glowing introduction to Dr. Mark Flannery. Dr. Flannery recently joined the Commission staff as the new Chief Economist and Director of the Division of Economic and Risk Analysis (DERA). As Chair White explains it, DERA is one of the “primary Divisions that is leading the structured data initiatives.” Chair White said that while Dr. Flannery is new to the SEC, he is “long conversant with the use and value of structured data.” White also referred to Dr. Flannery’s inaugural speech as the Director for DERA and described the speech as being “dedicated entirely to the topic of structured data.”

Dr. Flannery’s speech to the Data Transparency Coalition’s Fall Policy Conference on Sept. 30, 2014 was indeed entirely about structured data. He explained the “important role that high-quality financial information plays in the efficient operation of capital markets and their oversight by regulators,” and he made clear that the SEC is “committed to improving the availability of financial information through the presentation and analysis of structured data.” He addressed the ongoing need to increase the quality of the available XBRL data, and he made clear that “making useable data available to the public is a key function of many of the Commission’s disclosure rules.”

Flannery’s speech enumerated many of the uses—and users—of structured data, stating that the SEC staff themselves are huge consumers of the data. The division that Flannery now oversees, the Division of Economic and Risk Analysis (DERA) uses structured data in their “economic analysis of rules, risk assessment and market supervision initiatives” as well as to “support enforcement actions and compliance programs.”

Dr. Flannery expanded on the SEC’s continuing and increasing commitment to the XBRL and other structured data initiatives in the face of those who would “advocate an exemption of the requirements for smaller companies.” He said that removing the XBRL requirement for smaller companies would, in fact, be a detriment to those companies because “their ability to disseminate machine-readable financial information critically enhances their ability to access capital in financial markets.” If XBRL becomes the standard for financial reporting only for large companies, smaller companies will be overlooked by financial analysts and institutional investors.

Although he dismissed the notion of removing the XBRL mandate, Flannery was sensitive to the fact that any new regulatory requirement does impose additional burden on companies of all sizes. Flannery said that the SEC is “taking the most prudent course, continuing its efforts to monitor filing quality and educate filers,” and he explained that as is the case with “all new compliance experiences, time is required for sufficient learning to overcome the inevitable start-up problems and costs that companies incur.”

After saying that the SEC is exercising gradualism and patience as the XBRL mandate enters maturity, Flannery did make clear that the “DERA staff will continue to address the quality of XBRL submissions by periodically analyzing their content for accuracy and completeness,” and that “where appropriate, DERA staff will work closely with the Division of Corporation Finance to provide guidance to filers.”

In concluding his inaugural speech as Director of DERA, Dr. Flannery said that “ensuring that market participants have access to useable, high-quality” structured data was the primary purpose of the initial SEC XBRL mandate in 2009, and he said that he and his staff at “DERA are committed to helping fulfill that original aim.”

The SEC is committed to XBRL, and they are committed to high quality, useable XBRL data.

RDG Filings can provide your company with a Full Service Tagging Solution or with XBRL Quality Assurance Services, both of which will vastly improve the quality and usability of the XBRL data you are submitting to the SEC and create significant cost efficiencies for your company.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in H.R. 4164, SEC Compliance, SEC News, Small Company Disclosure Simplification Act, Structured Data, XBRL News, XBRL Quality Assurance | Comments Off on The SEC Enhances its Commitment to XBRL Data

New Data and Analytical Tools Increase the SEC’s Enforcement Reach

Sunday, September 21st, 2014

We’ll give the moral to this story first: The SEC is using XBRL and other available data to increase its enforcement initiatives. You cannot control the SEC, but you can control if your XBRL data is catching unwanted SEC attention. RDG Filings can ensure that your XBRL filings are held to the highest standards available anywhere and will not raise flags at the SEC due to poorly structured data.

Recently the SEC conducted an unprecedented investigation into violations by individuals and companies of securities laws that require corporate officers, directors and major shareholders to disclose their transactions in company stock.*

As the law firm McGuire Woods described it, the scope of this investigation was beyond anything the SEC had conducted in the past. And the firm Morgan Lewis said that this “sweep signals a new level of scrutiny by the SEC of a filing requirement that, to date, has been largely immune from aggressive enforcement actions.”

The SEC said that it had used “quantitative data sources and ranking algorithms” to detect these violations that would like have gone unnoticed prior to the availability of these new sources of data and the technology to analyze that data. Morgan Lewis predicts that the “existence of these quantitative tools alone suggests that more of these types of actions may be forthcoming from the SEC.”

This aggressive investigation is evidence that since the establishment of its Center for Risk and Quantitative Analytics in July 2013, the SEC’s Enforcement Division has increased its use of data analytics to identify potential violations.

These types of increase enforcement mechanisms are not a surprise. In October of 2013, Mary Jo White explained that the SEC would be adopting the “Broken Windows” theory to crime fighting and prevention. While they will remain focused on the big crimes, they would use newly available data and technology to more strictly enforce the smaller violations.

Admitting that the SEC has limited resources, and cannot actually be everywhere at once, she said that the SEC would be leveraging “new data tools and other force multipliers” to enhance and expand its coverage. She wants the SEC to “strive to be that kind of cop – to be the agency that covers the entire neighborhood and pursues every level of violation,” and she said that they would be “harnessing the power of our enhanced technological capabilities… to spot fraud early on.”

Chairperson White concluded that it is the SEC’s aim “to create an environment where you think we are everywhere – using collaborative efforts, whistleblowers and computer technology to expand our reach… and ensuring that even the small violations face consequences.”

Chairperson White’s head enforcement chief, Andrew Ceresney, echoed and expanded on those sentiments in May of 2014. Ceresny said that the SEC had been “focused on using technology to improve our ability to detect and investigate fraud,” and that with “proliferation of big data, we need to better harness technology in order to keep up with wrongdoers.”

More specifically, Ceresny said that the Center for Quantitative and Risk Analytics is helping “develop technologies to analyze trading and other types of data available to us from a wide variety of venues.” He added that it is “critical that we continue to develop tools that mine these massive data sources for possible violations. This data is a rich source of information for us and we need to take advantage of it.”

To repeat the moral to this story: The SEC is using XBRL and other available data to increase its enforcement initiatives. RDG Filings XBRL Quality Assurance Services will ensure that your XBRL data will not raise unwarranted flags at the SEC. RDG will provide you with an independent, 3rd party review of your XBRL code, and our QA team of expert CPAs will ensure that your XBRL is not simply SEC Compliant, but that it satisfies the most up-to-date and strictest recommendations from the FASB, the AICPA, and the XBRL.US. Contact us for more information.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

*RDG Filings offers an excellent, cost effective, and user-friendly, web-based tool for the creation and submission of Section 16 Ownership Forms 3, 4, & 5. Please contact us for more information.

Posted in SEC Compliance, SEC News, Structured Data, XBRL Filings, XBRL News, XBRL Quality Assurance | Comments Off on New Data and Analytical Tools Increase the SEC’s Enforcement Reach

The SEC is Moving (slowly) in the Right Direction

Thursday, July 24th, 2014

In a recent article on the Compliance Week website, Tammy Whitehouse makes clear that while the SEC has recently issued new guidance for–and begun stricter enforcement of–XBRL quality, there remain legitimate concerns about the ultimate usefulness of the data. It is certainly true that the XBRL being filed by many providers that use automated software and by many companies creating their own XBRL using in-house software is flawed and riddled with simple errors. As a result, the lion’s share of the XBRL data currently available is of limited value to the investors and analysts for whom the data is primarily intended. Although the SEC has recently begun issuing comment letters in a first attempt to remedy the issues that diminish the value of XBRL data, Whitehouse says that some people “worry it won’t go far enough to fix the problems that prevent better use of open source financial statement data.”

RDG agrees. This was a good first step, but more needs to be done to enhance XBRL quality.

However, the primary takeaway from Whitehouse’s article is not that “XBRL has been a failure since the beginning.” Perhaps it has, but only if you insist on only looking backward. RDG agrees with Campbell Pryde, president and CEO of the XBRL U.S., which advances the goal of a high quality dataset of public companies’ financial information. In the article, Pryde acknowledges that there has “been very little communication from the SEC,” and as a result, there has been little “incentive for folks to get it correct.” However, he provides valuable perspective when he says: “It’s a cycle, and hopefully the SEC attention to this should start to break the cycle.”

Since the inception of the XBRL mandate, the SEC has been very deliberate (all too deliberate) in the gradual implementation of the requirement, and they continue to move slowly toward stricter enforcement of the necessary standards of XBRL quality. They are, however, moving in the right direction.

There will always be companies that wait for the SEC to take discernible enforcement actions before complying with certain regulations. But for those companies that want to remain in compliance and ahead of the SEC’s future enforcement—and that want to supply XBRL data that is useful to analysts and investors—there are some simple and cost effective solutions.

If you’re using an outsource provider for XBRL tagging that outsources the tagging or uses automated software to create quick-and-dirty XBRL, your code is sure to have a large number of errors and may not fly under the radar of the SEC’s XBRL RoboCop. RDG Filings is among the top five most active filing agents in the country, we are proud to have set the standards for both customer service and XBRL data quality, and we are thrilled to be able to offer this quality at significant savings over the other reputable providers. High quality XBRL data is not cost prohibitive. Contact us for a quote.

If you are using in-house software to create your own XBRL, and if you want a higher degree of confidence that your code is properly built, RDG’s XBRL Quality Assurance Department provides you with an independent, 3rd party review of your XBRL code, and our QA team of expert CPAs will ensure that your XBRL is not simply SEC Compliant, but that it satisfies the most up-to-date and strictest recommendations from the FASB, the AICPA, and the XBRL.US. Contact us for more information.

At this point, it is undeniable that the XBRL mandate is far from perfect. However, it is important to maintain perspective and to understand the SEC for what it is. It’s a large government bureaucracy that moves slowly but steadily. It may be plodding along, but the SEC is moving toward increased enforcement of XBRL quality. It is up to companies to be sure they are out in front of the SEC. RDG Filings can help.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in SEC Compliance, SEC News, XBRL Filings, XBRL News, XBRL Quality Assurance | Comments Off on The SEC is Moving (slowly) in the Right Direction

At Long Last: The SEC Increases Its Enforcement of XBRL Quality

Wednesday, July 9th, 2014

The SEC has recently sent an email to their entire XBRL distribution list announcing that they have begun sending comment letters regarding the quality of XBRL code (an example of the letter is viewable here). The letter pertains to missing Calculation Relationships in particular, but regardless of the specific topic, RDG Filings has just one response:

It’s About Time!!

The fact is that, to date, the SEC has not been enforcing a high standard for XBRL data quality (in fact, they’ve been very permissive of poorly built code). So we are gratified by the SEC’s (belated) shift toward a higher standard, because we believe that XBRL will be a worthwhile endeavor only after the data available is of a sufficient quality to be usable to analysts and investors. There is a “clear demand for timely, structured, machine-readable data” among investors, but only a minority of the data is currently good enough. We believe that as a result of pressure from Congress and the data community, this Comment Letter will be the first step as the SEC continues to increase their enforcement standards.

RDG Filings has been preparing for this “ratcheting up” of enforcement since the inception of the XBRL mandate, and we have always taken steps to ensure the quality of the XBRL code we create for our clients meets and exceeds the SEC’s current standards. RDG has always been committed to building the highest quality XBRL, and we have continuously developed and expanded our expertise and knowledge to remain proactive in this area.

Many companies who create their XBRL using in-house software (or who have it built by the software company) desire a higher degree of confidence that their XBRL code will not raise flags with the SEC and will be most usable to analysts and investors. For these companies, RDG Filings provides independent, 3rd party review of XBRL code. Our XBRL Quality Assurance Services are designed to ensure XBRL data is in line with the strictest standard for excellence available anywhere. For more information about our XBRL QA Services or about what additional changes we believe are coming from the SEC, please contact us.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in SEC Compliance, SEC News, XBRL Filings, XBRL News, XBRL Quality Assurance | Comments Off on At Long Last: The SEC Increases Its Enforcement of XBRL Quality

Without Warning – The SEC Introduces a New Validation Error

Wednesday, July 9th, 2014

The SEC has long been hinting at an increase in its validation requirements for XBRL filings, and it seems that they have finally begun the process with the recent release of the 2014 Taxonomy. With no advance notice, the SEC introduced a new validation error* that immediately caused XBRL exhibits to be stripped from some live filings.

These sorts of unannounced validation issues can cause unnecessary grief and unsightly Amended Filings. We can help. Since the beta-testing phase of the XBRL mandate, RDG Filings has been constantly increasing its knowledge and expertise, and there are two ways we can improve the quality of your XBRL code and avoid future validation errors.

If you are currently getting your XBRL done by an outsource provider, please contact RDG for information about our Full Service XBRL solution. With RDG, you will have access to a dedicated account manager, who is a CPA and will work directly with you throughout every filing deadline. The XBRL code we file for our clients is of the highest quality.

Alternatively, we can provide you with an independent, 3rd party review of your XBRL code. RDG’s Quality Assurance team of expert CPAs will ensure that your XBRL is not simply SEC Compliant, but that it satisfies the most up-to-date and strictest recommendations from the FASB, the AICPA, and the XBRL.US.

Many companies who create their XBRL using in-house software (or who have it built by the software company) desire a higher degree of confidence that their XBRL code will not raise flags with the SEC and will be most usable to analysts and investors. RDG Filings’ XBRL Quality Assurance Experts will ensure your taxonomy is accurately updated, and they will thoroughly review your XBRL code to bring it in line with the strictest standards available.

We would like the opportunity to present these services to you in the near future. Please contact us for more information and a quote, or to set up a time to discuss the options available to you from RDG Filings.

The Limited Liability period is long over, and the SEC has rolled out three new fraud detection initiatives all made possible by the RoboCop automated enforcement tool that will automatically trawl through XBRL filings immediately upon filing. RDG Filings has the knowledge, expertise, and experience to ensure that the AQM-RoboCop tool being deployed daily by the SEC is far less likely to flag your XBRL filings.

*FYI: The new validation is: Nonnnumeric Concept Must Be Duration. It means that an extended concept must have a Period Type of ‘duration’ because its base type is not numeric. In other words, when tagging a date as a fact or a time period, the SEC wants you to apply a start and end date to the date. It’s an odd validation that does not make a huge amount of sense, as there are cases when one may prefer to tag these types of concepts as ‘instants’. Regardless, now you cannot do so.

Feel free to contact me any time.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in SEC Compliance, SEC News, XBRL Filings, XBRL News, XBRL Quality Assurance | Comments Off on Without Warning – The SEC Introduces a New Validation Error

Congress Sends The DATA Act to the President’s Desk for his Signature

Wednesday, April 30th, 2014

After unanimously passing the Senate in a vote on April 10^th, the DATA Act (Digital Accountability & Transparency Act) was unanimously approved by the House of Representatives on April 28^th. The bill will next be sent to the President for signing into law.

RDG joins all proponents of government transparency nationwide in thanking the DATA Act’s lead sponsors Rep. Darrell Issa (R-CA), Sen. Mark Warner (D-VA), Rep. Elijah Cummings (D-MD), and Sen. Rob Portman (R-OH) for championing this important legislation. We are also grateful to the Data Transparency Coalition and other groups who have worked so hard to push this bill through.

The law will require the federal government to comply with new standards for financial disclosure that utilize Structured Data technology, and it ensures that more and better data is published online. The DATA Act will usher in a new era of transparency for the U.S. government’s spending of taxpayer dollars. Structured Data will allow government spending information to be properly searched and analyzed, and will facilitate the elimination of waste and fraud.

Structured Data is the future of financial reporting, and it is already in wide use by public companies worldwide in the form of eXtensible Business Reporting Language (XBRL).

The DATA Act will open the government’s spending information and set the stage for meaningful spending reform. By creating documents with standardized, searchable data, this law is a huge step forward in the honest tracking of government expenditure.

Posted in H.R. 4164, SEC News, Structured Data, The DATA Act | Comments Off on Congress Sends The DATA Act to the President’s Desk for his Signature

The DATA Act Will Vastly Improve the Transparency of Government Spending

Thursday, April 17th, 2014

On April 10^th, the United States Senate passed the DATA Act (Digital Accountability & Transparency Act) without objection. The legislation now returns to the House of Representatives, which approved its version of the bill last November with only one dissenting vote. The truly bipartisan DATA Act is expected to make it to the President’s desk for signing soon after the Congress returns from recess later this month.

The bill would require the federal government to comply with new standards for financial disclosure that utilize Structured Data technology, and it would ensure that more and better data is published online. The DATA Act has the potential to usher in a new era of transparency for the U.S. government’s spending of taxpayer dollars.

To date, government spending data has been locked away in archaic form types and inaccessible printed materials. These previously un-searchable documents were not widely or easily available to the public. Leveraging the potential of Structured Data will allow this information to be properly searched and analyzed, and with greatly improved transparency the public and private sectors will be able to work together to eliminate wasteful spending and identify fraud.

By creating financial disclosures with standardized, searchable data, the DATA Act is the first step in helping taxpayers and citizens to track where their dollars are actually going.

Research Data Group and RDG Filings applauds the DATA Act’s congressional sponsors and the Data Transparency Coalition for championing this important legislation.

For more information about the bill, please visit the congress.gov. See more from RDG here.

Stewart Walker – SVP, Director of Sales

415.643.6017

Posted in SEC News, Structured Data, Uncategorized, XBRL News | Comments Off on The DATA Act Will Vastly Improve the Transparency of Government Spending

H.R. 4164 — Dubious Benefits & Destructive Consequences

Wednesday, March 12th, 2014

H.R. 4164, the Small Company Disclosure Simplification Act, is deeply flawed. The incorrect facts used to justify this bill are relatively insignificant compared to the bill’s inevitable and destructive consequences.

If this poorly considered bill manages to gain passage—either on its own or as an amendment to a larger bill—the partial elimination of the XBRL filing requirement would be deeply damaging to the national standards of public disclosure and financial reporting. Additionally, the SEC’s ability to discover investor fraud would be unnecessarily and dramatically hamstrung by this bill. Lastly, and rather ironically even by congressional standards, this bill will be considerably detrimental to the same companies that it is meant to help.

H.R. 4164 has been introduced by Rep. Robert Hurt of Virginia’s 5^th district and co-sponsored by Rep. Terri Sewell of Alabama’s 7^th district with the stated intent of reducing the compliance burden on smaller companies by eliminating their XBRL disclosure requirement. It is true that the bill would save some publically traded companies between eight and fifteen thousand dollars per year, but H.R. 4164 would have profound and pernicious impacts that far outweigh these dubious benefits.

Hurting Small Companies by Creating a Financial Reporting Caste System

The reduction in XBRL regulations proposed in H.R. 4164 would actually hurt the smaller companies it is designed to help. If this bill becomes law, and if XBRL becomes the standard for financial reporting only for large companies, smaller companies will be overlooked by financial analysts and institutional investors. Analysts and major investors will not have the tools necessary to discover opportunities among the smaller companies that are exempted from XBRL reporting. In the wake of H.R. 4164, future investment dollars will stream only to companies whose financial information can be clearly and transparently reviewed in the XBRL format. Exempting small companies from XBRL reporting will create a permanent underclass of less visible, and undiscoverable investment opportunities.

Putting Investors at Risk

The value of XBRL data goes beyond stock analysis. XBRL represents a significant improvement in the SEC’s ability to identify and eliminate investor and financial fraud by companies of all sizes. H.R. 4164 represents a massive regulatory loophole that a fraudulent company could drive an Enron-sized truck through.

Misrepresenting the Value of XBRL Data

Rep. Hurt’s press release of March 6, 2014 regarding this bill rehashes the specious claim that “evidence suggests that less than ten percent of investors actually use XBRL.” XBRL is not designed for the individual investor, but it is and will be of tremendous value to institutional investors and analysts and the companies they choose to invest in.

News Flash: The Stone Age is Over

XBRL is the future of financial reporting, and delaying its use will set the world of financial reporting and oversight back to a technology (HTML) that was developed in 1996. XBRL is a tremendous and necessary advancement, and instead of pushing a reversion to decades old standards, the government should be demanding higher quality, more transparent data.

Overstating the Regulatory Burden of XBRL

Rep. Hurt’s press release of March 6, 2014 includes the assertion that XBRL filing costs public companies “tens of thousands of dollars” annually. That may be true for those companies getting horrendously overcharged by their current provider, but not for those companies working with RDG Filings. RDG is among the leading XBRL service providers, and despite the fact that we provide the highest level of service and data quality available, our clients have annual costs significantly lower than the exaggerated costs put forward by Rep. Hurt.

An independent survey conducted by Financial Executives Research Foundation (FERF) indicated that the median cost for the most recent 10-K filing was $2,000 for smaller reporting companies. An XBRL exemption for smaller issuers would mean an annual savings of only $8,000. To be honest, the cost of XBRL reporting can vary depending on the complexity of the financials, but even at the highest end, the “burden” of XBRL reporting is not significant enough that the savings would outweigh the benefits of XBRL for both companies and shareholders.

Distorting of the Impacts of XBRL

Rep. Hurt’s press release of March 6, 2014 states that the XBRL requirement has “a negative effect on small companies, particularly innovative startups that need additional capital to expand their operations and grow.” The preponderance of recent data belies this claim. The IPO market is thriving again, even as XBRL is a known regulation these IPOs must accept. XBRL has had no evident impact on the currently robust IPO market.

The Obvious Conclusions

The long-in-short of the unintended consequences of this bill is simple: H.R. 4164 would kill hundreds of high-quality American jobs, create a divisive caste system of public companies, increase the risk of investor fraud, and hamstring smaller companies’ ability to earn future investment dollars. These sacrifices will be made in exchange for an annual savings of eight to fifteen thousand dollars for public companies.

H.R. 4164 is a bad bill, and it should not become a bad law.

Posted in H.R. 4164, SEC Compliance, SEC News, Small Company Disclosure Simplification Act, XBRL Filings, XBRL News | Comments Off on H.R. 4164 — Dubious Benefits & Destructive Consequences