Supporting Statement for Voluntary XBRL

SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection Submission for
Voluntary XBRL-Related Documents
A.

JUSTIFICATION
1.

Necessity for the Information Collection

The Commission has been evaluating the use of interactive data tagging as a tool to
improve the timeliness and accessibility of the information contained in electronic filings with
the Commission under the federal securities laws. 1 As part of our evaluation of the potential of
interactive data tagging technology, the Commission adopted rules in 2005 instituting a program
that permitted registered investment companies (“funds”) to submit on a voluntary basis
specified financial statement disclosure tagged in eXtensible Business Reporting Language
(“XBRL”) format as an exhibit to certain filings on the Commission’s Electronic Data Gathering,
Analysis and Retrieval System (“EDGAR”). This voluntary program permits any fund to
participate merely by submitting a tagged exhibit in the required manner. These exhibits are
publicly available but are considered furnished rather than filed. Under the voluntary program,
funds are permitted to submit financial statement and portfolio holdings information.

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The Commission has historically acted to modernize the manner in which information is filed
with the Commission and disclosed to the public in order to keep up with changes in the industry
and technology. See Investment Company Reporting Modernization, Investment Company Act
Release No. 31610 (May 20, 2015), available at http://www.sec.gov/rules/proposed/2015/339776.pdf, at section I.A. The Commission’s disclosure and reporting modernization efforts have
included the evaluation (and voluntary or required use by investment companies) of data tagging.
Data tagging uses standard definitions (or data tags) to translate text-based information into data
that is interactive, that is, data that can be retrieved, searched, and analyzed through automated
means. Tags are standardized through the development of taxonomies, which are essentially data
dictionaries that describe individual items of information and mathematical and definitional
relationships among the items.

2.

Purpose of the Information Collection

The purpose of the collection of information is to help evaluate the usefulness of data
tagging and XBRL to registrants, investors, the Commission, and the marketplace.
3.

Role of Improved Information Technology

The Commission’s EDGAR system automates the filing, processing, and dissemination
of full disclosure filings. The automation has increased the speed, accuracy, and availability of
information, generating benefits to investors and financial markets. Responses under the
collection of information are submitted to the Commission electronically on EDGAR in XBRL
format.
4.

Duplication

The Commission periodically evaluates rule- and form-based reporting and
recordkeeping requirements for duplication and reevaluates these requirements whenever it
proposes a rule or form, or a change in either. The collection of information permits funds to
submit, in interactive data format, financial information that is already required to be submitted
to the Commission in traditional format. When the information is in traditional format, it cannot
be used as effectively as when in an interactive data format that a variety of software applications
can recognize and process. The submission of data in an interactive data format helps make
financial information easier for investors to analyze, and also assists issuers in automating
regulatory filings and business information processing.
5.

Effect on Small Entities

The voluntary program may have an impact on small entities that choose to participate.
The voluntary program does not distinguish between small entities and other participants. Given
that the reporting program is voluntary, only entities with sufficient resources would be likely to

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elect to participate. The Commission reviews all rules periodically, as required by the
Regulatory Flexibility Act, to identify methods to minimize recordkeeping or reporting
requirements affecting small businesses.
6.

Consequences of not Conducting Collection

The program is voluntary.
7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

This collection is not inconsistent with 5 CFR 1320.5(d)(2).
8.

Consultation Outside the Agency

The Commission and the staff of the Division of Investment Management participate in
an ongoing dialogue with representatives of the fund industry and through public conferences,
meetings, and informal exchanges. These various forums provide the Commission and the staff
with a means of ascertaining and acting upon paperwork burdens confronting the industry. The
Commission requested public comment on the collection of information requirements in the
voluntary interactive data program before it submitted this request for extension and approval to
the Office of Management and Budget. The Commission received no comments in response to
its request.
9.

Payment or Gift

No payment or gift to respondents was provided.
10.

Confidentiality

No assurance of confidentiality was provided.
11.

Sensitive Questions

No questions of a sensitive nature are involved.

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12.

Burden of Information Collection

The following estimates of average burden hours and costs are made solely for purposes
of the Paperwork Reduction Act of 1995 2 and are not derived from a comprehensive or even
representative survey or study of the cost of Commission rules and forms. Participation in the
program is voluntary. Submissions under the program will not be kept confidential.
We estimate that no funds participate in the voluntary program each year. This
information collection, therefore, imposes no hour burden; however, we are requesting a burden
of one hour for administrative purposes.
13.

Cost to Respondents

Cost burden is the cost of services purchased to prepare and update disclosure under the
voluntary interactive data program, such as for the services of independent auditors, outside
counsel, and the costs associated with purchasing technology or other components used in
generating, maintaining, and disclosing or providing the information. We estimate that no funds
participate in the voluntary program each year. This information collection, therefore, imposes
no cost burden.
14.

Costs to the Federal Government

The annual cost of reviewing and processing registration statements, post-effective
amendments, proxy statements, shareholder reports, and other filings of investment companies
amounted to approximately $19.2 million in fiscal year 2014, based on the Commission’s
computation of the value of staff time devoted to this activity and related overhead. However, as
discussed above, we estimate that no funds participate in the voluntary program each year, so

2

44 U.S.C. 3501 et seq.

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none of the estimated costs to the federal government would be attributable to the voluntary
program.
15.

Changes in Burden

This information collection imposes no hour or cost burdens; however, we are requesting
a burden of one hour for administrative purposes. These hour and cost estimates have not
changed since the last approval.
16.

Information Collections Planned for Statistical Purposes

The results of any information collected will not be published.
17.

Approval to Omit OMB Expiration Date

The Commission is not seeking approval to not display the expiration date for OMB
approval.
18.

Exceptions to Certification Statement

The Commission is not seeking an exception to the certification statement.
B.

COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information will not employ statistical methods.

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