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iXBRL and the 10-Q exhibit list

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5 comments

  • Official comment
    Mike

    Hi all!

    Great convo. I've been meaning to chime in with an update. That pesky Exhibit 104 is a bit confusing. The SEC did provide some input on the matter, found here on the FAST Act FAQs: https://www.sec.gov/corpfin/interactive-data-cdi

    You'll want to take a gander specifically at Questions 101.01 and 101.04 for exhibit index updates. Holler if you have any questions in the meantime. Thanks, and have a super day!

  • Linda Pensa

    I've also been advised by outside counsel to add the word "Inline" before each XBRL exhibit and to remove the 101.INS row altogether. In addition, they've advised us to add exhibit 104 and say "Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibits 101.). I found this online regarding exhibit 104: https://www.natlawreview.com/article/complying-sec-s-new-requirements-inline-xbrl-tagging-cover-page-information

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  • Jonathan Gregory

    My Company and many others I've seen have only updated the description for Exhibit 101.INS and left the other 101 exhibits as is. Our counsel has not advised us to modify. And I can see that argument as the data files on the SEC website are all still separately listed except for the Instance Document (pre-iXBRL way vs. now):


    I suppose you could move towards showing your 101 Exhibits more like Coke or Starbucks (example below). Despite them combining all XBRL exhibits into 1 line, they still note "Instance Document" only is embedded within the inline XBRL document.

    Also, regarding your Exhibit 104 question, I found an article that just came out yesterday clarifying this issue. (https://www.natlawreview.com/article/complying-sec-s-new-requirements-inline-xbrl-tagging-cover-page-information). We may need to revisit for next quarter's reporting.

    Hope this helps!

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  • Gabe M
    Thank you both for your replies! We opted to just follow legal's advice and add "inline" before each.
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  • Lynn Kaminski

    Our SEC legal counsel advised us that by adding language in the exhibit index to 101.INS stating that “the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document” is sufficient to comply with this requirement, and we don't need to include "Inline" in each Exh 101 description.  Definitely diversity in practice!

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