Urging XBRL across the board in comments to SEC
It has been a busy week in responses to the Securities and Exchange Commission (SEC) for XBRL US. One comment letter welcomes the SEC’s proposed digital reporting rules on Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies. “We support the requirement in the proposal that cybersecurity incident data be reported in Inline XBRL format to increase the Commission’s ability to assess risk and monitor activities, and to identify trends in cybersecurity incidents, as well as systemic risks across the market,” says XBRL US.
“Capturing this information in machine-readable format will ensure that cybersecurity information is more readily available, accessible, and comparable for investors, other market participants, and the Commission.” And given the large amount of other data already reported in XBRL, generating cybersecurity information in XBRL too will help give users a complete picture of the investment landscape in a single data format.
XBRL US has also written to the SEC in response to its rule proposal on Modernization of Beneficial Ownership Reporting. It agrees with the Commission’s plan to require the reporting of beneficial ownership data in structured format, but urges the use of XBRL rather than a custom XML schema as is currently proposed.
A custom, single-use XML schema would require data users to build new code to access data, and reporting entities to find new custom-built applications for reporting, says XBRL US. The Commission would need to bear the costs of building this custom schema and of developing style sheets to render the data human-readable, and any future changes in reporting needs would result in significant costs across the reporting ecosystem. Furthermore, validation checks would be less easy and cost-effective to implement. On the other hand, XBRL is ready to go, flexible for future needs, and facilitates comparison and integrated analysis with other data.
