Current developments: The SEC has mandated the use of XBRL, which is now effective for all filers. Filers in the first and second phase-in group are required to detail tag their financial information. .

The final phase-in group that reports under U.S. GAAP, including smaller reporting companies and Foreign Private Issuers (FPIs) that prepare their financial statements in accordance with IFRS (as issued by the IASB), are required to block tag submissions of XBRL-formatted financial information. However, the SEC has not yet adopted an IFRS Taxonomy which could be used by the FPIs. As such, in a response to a letter from the Center for Audit Quality ("CAQ") dated March 29, 2011 concerning the requirement for certain FPI's the SEC staff expressed a view that FPIs are not required to submit to the SEC and post on their corporate websites, if any, interactive data files until the SEC specifies on its website a taxonomy for use by such FPIs in preparing their interactive data files.

Further, the SEC had also issued XBRL rules for mutual funds. The rules require the mutual funds to provide the risk / return summary section of their prospectuses to the Commission and on their web site in XBRL format. Compliance with this rule was effective January 1, 2011. In connection with the issuance of this rule, the SEC issued a Preparers Guide that is intended to assist preparers to use the XBRL Mutual Fund risk/return summary taxonomy for submission of the risk/return section of the mutual fund prospectuses in interactive data format and the Rendering Guide that depicts staff guidance on the layout rules applied by the Commission Viewer's "rendering engine".

Impact on the business community: Companies that are required to submit XBRL exhibits with their SEC reports should consider the following matters as appropriate to their implementation status:

• The phase-in group to which a company belongs is based on the public float as at the end of the second quarter of the most recently completed fiscal year. As such a company can move between phase-in groups thus accelerating or decelerating XBRL requirements.
• The volume and complexity of XBRL detailed tagging increases exponentially the time, effort and cost of preparing XBRL submissions. Bolting on the tagging process to the existing financial statement close process, either internally or through an outsourced provider, may not be sustainable. Consideration should be given to building the tagging process into the financial statement close process.
• The SEC has made available, on its XBRL website, observations from the initial interactive data submissions of the second phase-in group of filers and the initial detailed-tagged interactive data submissions of the first phase-in group of filers. A review of these observations along with the frequently asked questions related to interactive data disclosures and the compliance and disclosure interpretations will allow filers in later phase-in groups to take advantage of the lessons learned by filers in earlier phase-in groups.
• The SEC has made available, on its XBRL website, a Summary of XBRL Information for Phase 3 Filers. The Summary provides an overview for companies that are now required to submit XBRL data effective in calendar year ending 2011 and summarizes some of the main process issues, lessons learned to date and resources for further information.
• The SEC has made available, on its XBRL website, observations from filings submitted for the second quarter of calendar 2011, which include the first submissions made by the third phase-in group as well as the first detailed tagged submissions of the second phase-in group. A review of these observations along with the frequently asked questions related to interactive data disclosures and the compliance and disclosure interpretations will allow filers to address the issues identified in their next series of interactive data filings.
• The final rules and the related EDGAR Filer Manual (EFM) provisions are regularly updated to expand the validation tests performed on XBRL submissions (i.e., the EDGAR system may reject future XBRL submissions that are prepared in the same manner as those that were previously accepted). Filers should · ensure that they are following the most updated guidance and should consider building test submissions into their financial statement close process.
• The modified liability provisions that allow XBRL submissions to be furnished rather than filed are being phased-out over a 24 month period and will not apply to any XBRL submissions after October 31, 2014. These modified liability provisions expired for calendar year end filers who began furnishing XBRL data submissions in the first phase-in group.
• The 2011 US GAAP taxonomy was adopted by the SEC at the end of February. The taxonomy includes updates to the 2009 taxonomy including changes in accounting standards, expanded disclosures for current practices, correction of errors and rationalization of duplicated concepts and new linkage to the Accounting Standards Codification and maintained pre-Codification references to assist in the transition period. The SEC staff strongly encourages companies to use the most recent version of the US GAAP taxonomy. However, due to the timing of the release of the US GAAP 2011 taxonomy in conjunction with the phase-in of the Rule, companies will be permitted to continue to use the US GAAP 2009 taxonomy. There is currently no mandated date by when all issuers will be required to use the 2011 taxonomy.
• Although no auditor involvement is required, a public accountant can provide assistance in a variety of ways, such as, informal knowledge sharing, implementation advice, assessing processes for preparing XBRL submissions and the related internal controls and/or performing attestation services.
• The XBRL Assurance Task Force of the AICPA Assurance Services Executive Committee (ASEC) has developed a set of principles and criteria to evaluate information formatted in the eXtensible Business Reporting Language (XBRL). The exposing comment period ended on July 15, 2011 and is being evaluated by the task force.