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On The Horizon: SEC staff releases Small Entity Compliance Guides

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Contents FASB staff proposes improvements for the 2019 taxonomies SEC staff releases Small Entity Compliance Guides Comment letters issued

FASB staff proposes improvements for the 2019 taxonomies The FASB staff issued the following proposed technical and other conforming improvements:


Comments on the proposals are due Oct. 13, 2018.



SEC staff releases Small Entity Compliance Guides Small Entity Compliance Guides summarize and explain rules adopted by the SEC, but they are not a substitute for SEC rules. Only an SEC rule provides complete and definitive information regarding its requirements.

The staff of the SEC’s Division of Corporation Finance recently issued two Small Entity Compliance Guides to summarize key provisions of the Final Rule, Inline XBRL Filing of Tagged Data, which requires operating companies to submit financial statement information, and mutual funds to submit risk/return summaries, using the Inline XBRL format. Inline XBRL allows filers to embed XBRL data directly into an HTML document. The Final Rule also eliminates both the requirement for filers to post Interactive Data Files to their websites as well as the 15 business-day XBRL filing period for mutual fund risk/return summaries, effective Sept. 17, 2018.

The Small Entity Compliance Guides issued are:

  • Operating Company Inline XBRL Filing of Tagged Data,” which includes examples for the phased-in compliance dates. It states that companies will be permitted to file using Inline XBRL prior to the compliance date once the EDGAR system is modified to accept such submissions, which is anticipated for March 2019

    The guide also clarifies that until such modifications are made to the EDGAR system, filers should continue to file the Interactive Data File entirely as an exhibit, unless they comply with the conditions of the Commission’s exemptive order issued on June 13, 2016, which permits operating companies that comply with certain conditions specified in the order to file Interactive Data Files using Inline XBRL through March 2020.

  • Open-End Management Investment Company Inline XBRL Filing of Tagged Data,” which also states that mutual funds will be permitted to file using Inline XBRL prior to the compliance date once the EDGAR system is modified to accept such submissions. The guide clarifies that until such modifications are made, mutual funds must continue to file Interactive Data Files as exhibits to registration statements and forms of prospectus filings.

For more information on the Final Rule, including the phased-in compliance dates, refer to the July 12 On the Horizon.



Comment letters issued On Sept. 10, the firm issued a comment letter in response to the PCAOB’s Draft Strategic Plan 2018-2022.

The firm also issued a comment letter on Sept. 14 in response to the FASB’s proposed ASU on narrow-scope improvements for lessors.



© 2018 Grant Thornton LLP, U.S. member firm of Grant Thornton International Ltd. All rights reserved. This Grant Thornton LLP On the Horizon provides information and comments on current accounting and SEC reporting issues and developments. It is not a comprehensive analysis of the subject matter covered and is not intended to provide accounting or other advice or guidance with respect to the matters addressed in this publication. All relevant facts and circumstances, including the pertinent authoritative literature, need to be considered to arrive at conclusions that comply with matters addressed in this publication. For additional information on topics covered in this publication, contact a Grant Thornton client-service partner.