The FEI Committee on Corporate Reporting (CCR) sent a comment letter to the SEC November 4, 2011 in which the concluded:
CCR believes thatthe changes in requirements proposed above would substantially lower the burden of preparing XBRL filings and bring the costs of preparation more in line with benefits. We note that application of existing protocols for detailed XBRL tagging will be effective for approximately 10,000 SEC registrants, including subsidiaries that follow limited disclosure, in July of 2012. All of the issues that large filers have experienced with detailed tagging could potentially be magnified when smaller, less-sophisticated companies attempt to comply. We therefore believe that action by the Commission is urgently needed.
FEI also published a survey SEC Reporting and the Impact of XBRL: 2011 Survey with these key findings of that survey:
- The most significant challenges mentioned in complying with the XBRL mandate are getting educated on XBRL and addressing the review process.
- XBRL had a limited impact on respondents’ SEC filing dates:
- 72% of large accelerated filers (Tier 1 and Tier 2) reported one day or less delay due to XBRL; and
- Over 90% of Tier 3 filers reported one day or less delay due to XBRL.
- The majority of respondents found that XBRL was either somewhat or significantly easier the second time around.
- Tier 1 and Tier 2 XBRL filers predicted a higher likelihood than Tier 3 XBRL filers of changing their XBRL process, with the vast majority of companies anticipating a change opting for an in-house software solution.
- In-house and built in solutions continue to increase their significant market share.
- Registrants using built-in solutions (software solutions used by in-house reporting teams in which the creation of the EDGAR document and XBRL instant report are fully integrated) are significantly more satisfied than those using other approaches.
Is it just me, or does the survey seem to contradict the comment letter? What do you think?