iXBRL and the 10-Q exhibit list
Con rispostaHas anyone figured out exactly how the 10-Q exhibit list should look after adopting iXBRL?
Previously, my company was advised to change the description of exhibit 101.INS to the below:
However, our outside counsel has now advised us that we should include the word "inline" before the "XBRL" in each of these exhibits. They are citing §229.601(b)(101):
"Instruction 1 to paragraphs (b)(101)(i) and (ii): When an Interactive Data File is submitted as provided by §232.405(a)(3)(i) of this chapter, the exhibit index must include the word "Inline" within the title description for any eXtensible Business Reporting Language (XBRL)-related exhibit."
Is anyone else interpreting it this way?
Also, has there been a clear instruction on when or if exhibit 104 is required for the cover tags?
-
Commento ufficiale
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-cdiYou'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!
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
0
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!0
Thank you both for your replies! We opted to just follow legal's advice and add "inline" before each. 0
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!
0Accedi per aggiungere un commento.
Commenti
5 commenti