This document summarizes a presentation given by David Blaszkowsky, Director of the SEC's Office of Interactive Disclosure, to XBRL Switzerland on June 23, 2009. It discusses the importance of interactive data for financial disclosures, what will be required in terms of content and filers, and the phase-in schedule. It also covers learnings from early interactive data filers, common issues, and next steps for the SEC in implementing the new requirements. The overall goal is to provide more structured financial information to investors through interactive data tagging of SEC filings.

1. SEC Staff Briefing on
Interactive Data
David M. Blaszkowsky,
Director, Office of Interactive Disclosure
XBRL Switzerland
Zurich
23 June 2009
1

2. Disclaimer
As a matter of policy, the Securities and
Exchange Commission disclaims
responsibility for the private statements
of SEC employees. The views I am
expressing today are solely my own, and
do not reflect the views of the
Commission, the Commissioners, or of
any employees other than myself.
2

3. SEC Staff Briefing on
Interactive Data
David M. Blaszkowsky,
Director, Office of Interactive Disclosure
XBRL Switzerland
Zurich
23 June 2009
3

4. Why is Interactive Data Important for
Company Information?
Filers/Corporations Buy-side
y Process improvements and y “Faster, cheaper, better”
savings y As-reported, and complete
y Easier/Faster compliance
y No introduced errors
y Better business analysis
y More useful: Easier to ID, import,
y Better communication, transform, analyze, apply “hi-
visibility to investors tech” functionality
x Especially for mid/small- y Higher analysis productivity
caps, markets
y Improved comparability,
especially globally
Improved Market Efficiency
4

5. “Interactive Data” Add Structure and
Meaning to Financial Disclosures
P&L
Mapping
Tagging
B-S
US-GAAP: Standard Tag
List of Tags Label: Short Term Assets
Tag: ShortTermAssets
Metadata: - Currency
(Plus
- Year
Footnotes)
- Amount
Δ’s - Scenario
- Value
OR: an “Extension”
5

6. What is Different Because of Interactive
Data?
SEC Filings Uses
Interactive Data
Format Strategic
Interactive
“Instance Document” Analysis
Data
Organizing Principles
• Company
• Document (Type) Investment
Emerging • Reporting Measure Analysis
• Data Series
• Filer Demographic
• …
Trading
Corporate Models
Financial /
Business SEC Filings
Reporting HTML & Spreadsheets
System ASCII
Document Format
• Download
Traditional • Print
• Transcribe
= Tagged Data
6

7. What Will Be Required
y Content:
x Primary financial statements
x Notes
x Financial statement schedules.
x Certain company identifier information
y Forms
x Periodic Reports
x Transition Reports
x Reports on Forms 8-K and 6-K that contain updated or revised
versions of financial statements that appeared in a periodic report
x Securities Act registration statements
y Interactive data requirements would supplement, not replace,
disclosures using HTML or ASCII
y “Disclosure Neutrality”
y Must be posted to the Filer’s website, if it has one, at the same time it is
provided to the SEC
7

8. Phase-in Schedule
What?
Year 1 Year 2
•“Face Financial Statements” “Detail Tagged” Footnotes
Who? • “Block Tagged” Footnotes & Schedules: & Schedules:
Filer Group Financial Quarters Ending On/After 15 June
Domestic/Foreign Large
Accelerated Filers Using US GAAP
• Public Float >$5 billion
2009 2010
• All other Large/Accelerated Filers
2010 2011
All other Filers in US GAAP
(including smaller reporting
2011 2012
companies)
All Issuers using IFRS as published
by the IASB
2011 2012
30 day grace period, from the filing date of the related report,
for the initial submission of interactive data exhibit
8

9. Data reliability and non-compliance
y Data in the interactive data file submitted will be subject to a
limited liability
y Limited liability provision phase-out:
x Over a two-year period for each company.
x Provision would terminate completely on October 31, 2014.
y Interactive data files will be excluded from the officer
certification requirements under the Exchange Act rules
y No requirement of auditor assurance on their interactive data
exhibits
y Filers that do not provide or post required interactive data on
the date required will be deemed not current with their
Exchange Act reports
9

10. What Can Financial Reporting
Professionals Do?
y Use publicly available resources to get smart on interactive data
x E.g.: http://www.xbrl.us (list of tags, preparer’s guide)
y SEC details:
x Final Rule Text: http://sec.gov/info/edgar/edgarfm.2.10_d.htm
x EDGAR Filer Manual: http://sec.gov/info/edgar/edgarfm.2.10_d.htm
x SEC Interactive Data Previewer - https://ideapreview.sec.gov/previewer/
x New: SEC webcasts, FAQs
y Brief/Build the team: financial, legal, technical…
y Watch for emerging “best practices”… or design them
y Learn from products and services in the marketplace
y Be aware that analysts and investors may start asking
y Use it – try it out
10

11. Interactive Data:
“News From the Front”
Mandate started 15 June – How is it working?
y Early filings came in successfully
xMany reviews completed, and feedback provided
y Companies can tag successfully
x Modest cost, modest time
x Learning curve: widest problems are the most basic
x “Best practices” emerging
x Next–gen software, integrated tagging on the way
x Benefits of a large, comprehensive taxonomy
y “User-side” awakening
x Investor applications emerging
x Investor interest becoiming keen
y Lots of questions about “What’s Next”
11

12. Learnings From Early Filers
y Voluntary Filing Program is closed for most public filers
x Public Companies can only submit required filings
x VFP Only open for Article 6 and mutual funds
y Extensions
x Ensure the need for extensions
x Recheck the taxonomy to make sure that a tag doesn’t
already exist
x Tags versus labels…
y Labels: Make sure the labels match the traditional (HTML)
document exactly
x Labels can be extended without creating a new tag
x “Sales” vs. “Turnover”: Same tag, different label
x Use the pre-viewer to check!
12

13. Learnings From Early Filers (2)
y Management Review
x Senior management should have an opportunity to
review
x Even if outsourced, they are still your financials and
tags
y Rendering Aesthetics vs. Tagging Integrity
x XBRL is about the integrity of the tags
x Focus on the accuracy of the tags, not the aesthetics
of the rendering
y A few words on IFRS
13

14. Learnings From Early Filers (3)
Finally –
y Looking to make the Interactive Data roll-out interactive and
smooth
x Look for SEC staff comments and FAQs
x Public Interactive Data Seminar 10 June
x Communicating with companies: web, phone, podcasts,
“whatever”
x Best practices will emerge, inevitable hiccups will be
resolved
x Ask-OID@sec.gov
14

15. Common Standard Will Allow Users to
Analyze Across Many Domains
Market XBRL Risk Social
Taxonomies
Responsibility
SEC Structured Data*
Governance
Mutual Fund Companies/
Risk/Return GAAP
Forms 3/4/5 Proxies
Ratings
Corporate (XML)
Actions Form D
(XML) Asset-Backed
Securities
Executive
Compensation KPIs
15

16. Thank You
Contact Information for Questions
y Ask-OID@sec.gov
y blaszkowskyd@sec.gov
y 202-551-5359
16