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iXBRL - Does visual presentation in SEC Viewer matter?

Comments

3 comments

  • Alex Pabellon

    Visual representation matters about the same as it did before. The short answer is that it never mattered because, at least for dimensionalized data, it was never produced or was intended to produce a rendering that matched the HTML document. It only matters to the extent that the rendering provides you with evidence of inappropriate or missing tagging. If you don't have missing or inappropriate tagging, the SEC viewer's rendering of your XBRL is irrelevant.


    From the SEC, June 2011: "Filers should concentrate on the quality of the tagging rather than trying to match the rendering of the XBRL exactly to the HTML filing. The rendered version of the XBRL financial statements need not exactly match the HTML statements." The rest is here (old, but gives you an idea of how they view our compliance efforts):

    https://www.sec.gov/structureddata/osd_staffobs_06-15-11.html

    So the questions should be:

    1. what's my compliance risk? After all, XBRL is mostly a compliance exercise. It is doubtful your organization would be doing it if it weren't required. Will you be issued a comment letter? Will you incur penalties? Is there reputational risk, etc? You assist the company in assessing that risk.

    2. what diagnostic value do YOU derive from looking at that rendering? Does it help you mitigate your risk?" Do you frequently identify bad or missing tagging using that tool? If so, then continue to use it. If most of your finding occur in the outline or blackline review, then consider alternatives.

    Given that the rendering doesn't even show concept ID (you're looking at the label, which you can edit to say anything) or concept definition, I find that review does little to ensure that everything is tagged properly, which is my primary compliance objective, or to improve my data quality, which is my secondary objective. But perhaps you derive more value from the control. It's up to you to decide.

    Given competing risk management priorities, you have to assess the likelihood and impact of loss against the resources and time required to perform the controls. Then you determine whether the combination of other review procedures and controls you have performed already address your risks properly. If it's remote risk and low impact and if other controls adequately address the risk, consider reducing the resources allocated to that activity. After all, ensuring efficient use of company resources is part of your risk management processes.

    I hope that all makes sense.

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  • Jeff Katz
    Thank you very much. This is super helpful.
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  • Alex Pabellon
    Good, I'm glad to hear it. You can drive yourself mad researching "bleed" on the Edgar rendering. We developed risk-based review procedures that are better at identifying bad tags and take 10% of the time. Best of luck!!
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