Information that should be of interest to anyone in an organization regulated in any way by the Securities and Exchange Commission: details from its chairman on how the agency plans to spend its resources in the coming fiscal year.

SEC Chairman Mary Schapiro took to the Hill this week to provide lawmakers with details on how the agency would use the President’s budget request of $1.258 billion for fiscal 2011.

If enacted, the 12 percent increase over the agency’s FY 2010 funding level would allow the SEC to hire an additional 374 professionals, bringing its total staff to just over 4,200, Schapiro said in March 17 testimony before a House Sub-committee. She noted that $24 million would be contingent upon the enactment of financial reform.

The budget request would allow the SEC to add 130 new professionals in the Enforcement Division, allowing it to open 75 additional inquiries, conduct 130 additional formal investigations, and file charges in 70 additional civil or administrative cases.

The Enforcement Division resources would be used to fully staff the new Office of Market Intelligence; hire enforcement staff with specialized expertise in financial products, additional trial attorneys, and administrative staff, and to provide staff training. Some of the funds would also be spent on information technology, including ongoing projects to improve the Division’s case management system and establish a centralized system for reviewing and analyzing tips and complaints. Future projects would include a state-of-the-art IT Forensics Lab, enhanced data and trading analytics, and improved document and knowledge management, Schapiro said.

The Commission would use the funds to add 70 staff in its examinations unit, which would allow its Office of Compliance and Examinations to conduct an additional 50 investment adviser exams and 25 mutual fund exams, and to staff the oversight function for credit rating agencies, half of which would be examined in FY 2011. Schapiro also noted that if the financial regulatory reform legislation requires hedge fund advisers to register, the SEC will begin to build an inspection program in that area. Even with the additional resources, she said the SEC anticipates examining only 9 percent of registered investment advisers and 17 percent of investment company complexes in FY2011.

The funds would also enable the Commission to add 20 new professionals in its Division of Risk, Strategy, and Financial Innovation, almost 50 positions to the Divisions of Investment Management and Trading and Markets, and 25 professionals to the Division of Corporation Finance, Schapiro said.

Finally, Schapiro said the budget request proposes to spend an additional $12 million on information technology investments, with the third phase of the new system for analyzing tips, complaints, and referrals as the top priority. That effort will add risk analytics tools to help identify high-value tips and search for trends and patterns.

The SEC completed part of that effort—centralizing its existing tips and complaints into a single, searchable database, and this week released a set of agency-wide policies and procedures to govern how employees should handle the tips they receive, Schapiro noted.

Other efforts would include building a suite of surveillance and risk analysis tools, completing improvements to the case and exam management tools, modernizing the agency’s financial systems, implementing a new system to handle an increase in the volume and complexity of evidentiary material obtained in investigations, and tools to improve the efficiency of loading, storing, and archiving the data obtained in investigations.

Schapiro noted that the proposed increase in spending would be offset by the fees collected on transactions and registrations. In FY 2011, the SEC estimates it will collect $1.7 billion, an increase of $220 million over FY 2010.

Welcome news for some companies seeking to suspend their reporting obligation under Exchange Act Section 15(d)—they won’t have to seek no action relief to do so if they meet the criteria detailed in a new Securities and Exchange Commission Staff Legal Bulletin.

Amid a flurry of no-action requests on the topic, the Division of Corporation Finance issued a March 15 bulletin detailing certain situations in which issuers can rely on Rule 12h-3 to suspend their reporting obligations under Section 15(d) without seeking no-action relief.

“This is codifying the staff’s practice in the past in issuing no-action letters related to this area,” says Edward Smith, a partner with Chadbourne & Parke.

The bulletin benefits issuers that meet the specified criteria, since they won’t have to seek no-action relief, and the SEC staff, which won’t have to review and respond to those requests.

On a going-forward basis, the staff said an issuer that fits within either of the two situations and also satisfies the conditions in the legal bulletin doesn’t need a no-action response before filing a Form 15 to suspend its Section 15(d) reporting obligation in reliance on Rule 12h-3.

Excluding no-action requests under Exchange Act Rule 14a-8, the SEC says about a third of all interpretive, no-action and exemptive requests acted on by the Office of Chief Counsel in fiscal 2009 involved the application of Rule 12h-3, and roughly 60 percent of such requests to date for fiscal 2010 have involved Rule 12h-3.

In order to rely on the suspension under Rule 12h-3 companies must meet certain conditions. In addition to being current in its Exchange Act reporting obligations, the issuer must have (1) fewer than 300 recordholders of the class of securities offered under the Securities Act registration statement; or (2) fewer than 500 record holders and its assets must not have exceeded $10 million on the last day of each of its three most recent fiscal years. It also must not have had a Securities Act registration statement relating to that class of securities become effective in the fiscal year for which the issuer seeks to suspend reporting, or have had a registration statement that was required to be updated by Section 10(a)(3) of the Securities Act during the fiscal year for which the issuer seeks to suspend reporting, and, if the issuer is relying on the fewer than 500 record holder and $10 million in assets threshold, during the two preceding fiscal years. The SLB notes that that last requirement, contained in Rule 12h-3(c), is what’s prompted issuers to seek no-action relief.

The SLB cites two common situations where the staff has repeatedly issued favorable no-action responses under Rule 12h-3, even though a Securities Act registration statement relating to that class became effective or was required to be updated by Section 10(a)(3) during the time period specified in Rule 12h-3(c).

One is an abandoned Initial Public Offering, where an issuer with no Exchange Act reporting obligations has a Securities Act registration statement become effective, but doesn’t sell any securities pursuant to the registration statement. The issuer files an application to withdraw the registration statement, and the staff consents to the withdrawal. As an example, the bulletin cites a July 2008 no-action request by Liberty Lane Acquisition Corp.

The other is where an issuer has been acquired by another entity, resulting in the class or classes of securities for which the issuer has a Section 15(d) reporting obligation being either extinguished or held or assumed by only one recordholder, the acquiring entity. See for example, a Nov. 4, 2009 no action request by Wyeth.

Smith says the situation where an issuer is acquired is fairly common, since most issuers routinely have S-8 or S-3 registration statements on file that are required to be updated yearly that would otherwise require them to seek no-action to take advantage of the suspension. For instance, he notes that the staff posted a letter granting no-action relief this week to Marvel Entertainment.

The bulletin also lays out four conditions an issuer in either of those circumstances must satisfy:

1. The issuer must not have a class of securities registered under Section 12 of the Exchange Act (Any Forms 25 and 15 to terminate Section 12 registration for any class of securities registered under Section 12 must be properly filed).

2. The issuer must comply with the other requirements of Rule 12h-3—it can’t exceed the recordholder and asset thresholds in Rule 12h-3(b)(1), must file a Form 15, and be current in its Exchange Act reporting obligations as of the date of filing the Form 15.

3. The issuer must deregister any unsold securities from Securities Act registration statements and withdraw any registration statements if there were no sales.

4. The issuer must not otherwise file Exchange Act reports during the time period in which it seeks to avail itself of the suspension provided by Rule 12h-3.

The issuer must file a Form 15 for each class of securities for which there is a Section 15(d) reporting obligation in order to cease reporting.

As part of its broader look at “proxy plumbing” issues, the Securities and Exchange Commission should tighten oversight and increase disclosures by proxy advisory firms that influence the way many institutional investors vote their shares, some observers say.

A requirement for all proxy advisory firms to register as investment advisers is one of six recommendations detailed in a discussion paper published by the National Investor Relations Institute and the Society of Corporate Secretaries & Governance Professionals in advance of a forthcoming SEC Concept Release to look at proxy mechanics and voting issues. Currently, only three of seven proxy advisory firms are registered as investment advisers, the paper notes.

NIRI President and Chief Executive Jeff Morgan says a copy of the paper was sent to the SEC in hopes that the issues and recommendations “will be a part of the discussion” included in the concept release.

“From a company standpoint, the process is very opaque,” says Morgan. “Their processes need to be more out in the open.”

Despite their tremendous influence on institutional shareholder voting, proxy advisory firms “generally remain unregulated and unsupervised and often are not transparent with regard to their standards, procedures, methodologies, and conflicts of interest,” states the paper, “Recommendations for Improving the Regulatory Oversight and Transparency of the Proxy Advisory Industry.”

Institutional investors and their third-party investment managers often lack in-house staff to analyze and vote on proxy items, and thus outsource voting decisions to proxy advisory firms. In many cases, they generally adopt the voting policies developed by one or more of the advisory firms, which the NIRI/SCSGP paper says may result in a “one-size-fits-all” approach rather than encouraging voting decisions on a case-by-case basis.

The groups say investors “may not be protected adequately because of the current deficiencies in regulatory oversight and transparency that exist within the proxy advisory industry.”

“Our members are concerned about the impact of these firms on voting and the fact that they seem to control a lot of institutional investor votes, as well as potential conflicts of interest and the lack of transparency,” says Darla Stuckey, SCSGP senior vice president for policy and advocacy, who notes that the recommendations “speak for themselves.”

The paper says proxy advisory firms can “significantly influence” director elections and corporate actions since their mutual funds and pension plan clients often have huge stock holdings. NIRI and SCSGP say that influence will grow in light of the change to New York Stock Exchange Rule 452, which they say will reduce the influence of retail investors.

“Unfortunately, several proxy advisory firms are not subject to any regulatory oversight, required disclosures, or fiduciary obligations regarding their ability to control or influence the outcome of shareholder votes at public companies in the United States,” the paper states.

In addition to increasing regulatory oversight of proxy advisory firms through the Investment Advisers Act of 1940, the groups say those firms should have to disclose conflicts of interest, such as relationships with any client who is the proponent of a proxy proposal or “vote no” campaign whenever the firm is issuing a recommendation to other clients in favor of the same proposal or “vote no” campaign.

Morgan says the SEC’s regulation of credit rating agencies is a “logical starting point” for developing a regulatory framework for proxy advisory firms.

NIRI and SCSGP also say proxy advisory firms should be required to publicly disclose their internal standards and methodologies, and their assumptions for developing voting recommendations and decisions.

They also suggest that the SEC and the Labor Department consider establishing a more robust due diligence process for institutional investors requiring them to exercise greater oversight responsibility for any delegation of their voting rights to a proxy advisory firm.

In addition, they recommend all proxy advisory firms be required to maintain a public record of all voting recommendations and decisions, and all institutional investors using proxy advisory services publicly disclose the actual proxy votes cast by them or on their behalf.

They also say public companies should have a chance to review proxy advisory firm draft reports for accuracy and to respond to comments or recommendations with which they disagree, and those responses should be disclosed by advisory firms to their clients.

Finally, they say proxy advisory firms should publicly and promptly disclose any errors made in executing or processing voting instructions on a particular proxy vote.

The paper was approved by the NIRI board and by the Policy Advisory Committee of SCSGP’s Board.

As previously reported, the SEC has said issues to be addressed in the concept release include accuracy in vote tabulation, issues of “over-voting” and “empty voting,” low voting rates by retail investors, and possible changes to the beneficial owner distinction. Detailed Compliance Week coverage of possible OBO/NOBO reforms is available here (subscription required).

A little light weekend reading, courtesy of the Securities and Exchange Commission staff, which posted three new Compliance & Disclosure Interpretations related to Regulation S-K.

The March 12 C&DIs are the latest to update the staff’s views in light of the new Proxy Disclosure Enhancements rule that took effect Feb. 28.

Questions 119.25 and 119.26, relate to reporting Executive Compensation amounts in the Summary Compensation Table under Item 402(c). The third, Question 133.12, relates to the reporting of compensation consultant fees as required under Item 407.

Bonus payouts to some chief executives were down sharply and fewer CEOs received bonuses in fiscal year 2009, according to a look at bonus trends based on early proxy filings.

In a preliminary analysis of 180 companies, median total CEO bonus payouts, including performance-based bonuses and discretionary cash awards, fell 22 percent, according to data published this week by compensation research firm Equilar Inc. The median total payout dropped from $882,105 in 2008 to $689,000 in 2009.

The data also shows fewer CEOs received any bonus in 2009 than in 2008. The prevalence of those getting bonus payouts fell 8 percent to 74 percent in 2009.

Amid general scrutiny of executive pay, bonuses have been subject to especially sharp criticism, as investors press companies to better justify huge sums paid to executives, particularly in cases where performance has been less than stellar.

Among the 180 companies studied, performance-based bonus payouts, which comprised the bulk of CEO bonuses last year, plunged 28 percent, from a median of $682,500 in 2008 to $488,972 in 2009. Those bonuses, which include disbursements from annual and multiyear incentive plans, made up an average of 79 percent of all CEO bonus payouts received in 2009, according to Equilar.

Of course, CEOs in certain industries took harder hits than others. Median total bonus payouts for CEOs in the financial and technology industries fell 51 percent and 59 percent respectively, while payouts grew 21 percent for services companies and 15 percent for healthcare companies.

“For a lot of companies, the 2009 bonus numbers are capturing the full effect of what happened in late 2008,” says Equilar Research Manager Aaron Boyd. “A lot of companies adjusted their performance plans last year to reflect market conditions and make sure pay was commensurate with performance.”

While he expects 2009 CEO bonus levels overall to be down relative to recent years, Boyd says the size of the decline may shrink when the remainder of companies with calendar-year ends file their proxies.

“A lot of it may be due to the fact that these are early filers,” he says. “Companies with fiscal year ends in June and September saw larger declines than calendar-year companies.”

For instance, he notes that most technology companies, which saw the sharpest declines, are June 30 filers.

The median value of discretionary cash awards declined 12 percent to $616,250 in 2009, down from $700,000 the prior year.

The review includes companies with annual revenues of at least $1 billion and a CEO in place for at least three years reporting compensation data for fiscal years ending between June 30, 2009, and Dec. 31, 2009. The complete 2010 Bonus Plan Design report, due out March 18, will be available by request.

Even without a “date certain,” many companies aren’t delaying work underway to prepare for a move to International Financial Reporting Standards, according to the latest survey by Big 4 firm KPMG.

When asked how the Securities and Exchange Commission’s IFRS statement will affect their plans to convert, 26 percent of the more than 2,000 executives surveyed by KPMG said it wouldn’t change their plans, and 8 percent said it would accelerate their plans.

Among those polled, 18 percent said they would delay their plans, 26 percent were undecided about how it would affect them, and 19 percent said it wasn’t applicable, according to results of a Feb. 26 online KPMG IFRS Institute poll.

As reported, the Commission laid out its latest thinking on IFRS on Feb. 24, adopting a statement that sticks to a 2011 deadline to make a decision, but delays any possible transition until at least 2015. The decision hinges on the progress of ongoing convergence projects between U.S and international accounting rulemakers and on the completion of a detailed SEC staff work plan.

“Of course, it’s much easier to plan with a definite timeline and goal in sight, but the Webcast survey does show that many companies continue to move forward with plans for implementing IFRS,” says Janice Patrisso, partner and National IFRS Leader at KPMG. “I think the SEC was clear that it continues to support development of a globally accepted set of accounting standards. To that end, they are working to ensure the path to the incorporation of IFRS into the U.S. financial reporting system is smooth and well planned.”

Still, 29 percent of those polled said the SEC action didn’t provide enough clarity on how IFRS would be implemented for U.S. companies, while 53 percent were undecided about whether the statement helped clarify things. Only 16 percent believe the Commission provided enough clarity on where the United States is going on IFRS.

Meanwhile, most executives seem comfortable with the SEC’s tentative timetable, according to the findings. More than half of respondents (59 percent) indicated that potential IFRS implementation in 2015-16 would give their organizations enough time to prepare for the change. Only 15 percent said it wouldn’t be enough time, while a quarter were unsure of the impact.

Once the SEC decides whether to require or permit U.S. companies to use IFRS, nearly half of respondents (49 percent) say they’d like the option for “early adoption.”

The SEC backed off from a plan under its 2008 Proposed Roadmap for a small group of issuers to voluntarily adopt IFRS prior to a 2011 decision after companies said there was no incentive to undertake the cost and work required for conversion until they the Commission makes a final determination on adoption. However, SEC officials noted that early adoption could still be part of the transition plan after the 2011 decision is made.

“It’s possible for companies to early adopt IFRS, if given the option, if they have IFRS conversion plans underway when the SEC makes an affirmative decision,” Patrisso tells Compliance Week.

She says some companies may see it as an opportunity to reduce compliance costs, since many U.S. companies already use IFRS for some of their foreign subsidiaries’ statutory reporting.

“The opportunity to use one accounting framework for most or all of their financial reporting around the globe could be cost-beneficial,” she says.

Other companies who want to move fast are those whose peers are already on IFRS. “Some of them have been laying the groundwork for adoption of IFRS since the SEC began to consider a timeline for adoption in 2008,” she says.

At the same time, the findings show that executives are still somewhat split on whether the United States should adopt IFRS at all. Among those surveyed, 41 percent say the SEC should adopt IFRS, 22 percent say it shouldn’t, and the remaining 36 percent are undecided.

The SEC’s Feb. 24 statement left open the question of how issuers might adopt IFRS. The proposed roadmap envisioned mandatory adoption on a phased-in schedule after a 2011 vote.

While Patrisso says the SEC’s recent statement has focused executives on what the change would mean for their organizations, she says much work remains before a U.S. change to IFRS.

“As this activity progresses, companies should make sure they have a good handle on their IFRS needs in order to have a smooth transition that will affect every area of their organization,” she says.

Companies and their counsel should take note: The Securities and Exchange Commission had added some new Frequently Asked Questions and updated some staff interpretations that you’ll want to take a look at.

The staff of the Office of Interactive Disclosure recently published six new FAQs related to the SEC’s Interactive Data Disclosure rules.

The new FAQs added March 4 relate to company extensions and instances.

As a reminder, the Commission has slated a March 23 public seminar to help companies and preparers comply with the XBRL reporting rules. Compliance Week will provide readers with coverage of that event in an upcoming edition.

Meanwhile, the staff of the Division of Corporation Finance has been busy updating its interpretations to address changes triggered by the new Proxy Disclosure rule that took effect at the end of February.

With the latest round of C&DIs, the staff added one new interpretation, revised two others, and withdrew six prior interpretations related to Regulation S-K to address changes in the reporting of equity awards in the Summary Compensation Table and Grants of Plan-Based Awards table under the rule.

Questions 119.04, 119.05, 119.11, 119.12, 119.15, and 120.05 were withdrawn to clean up interpretations that no longer apply because of the switch to reporting Grant Date Fair Value in the Summary Compensation Table and Grants of Plan-Based Awards Table.

The staff added new Question 119.24, which relates to when and how to report an award when the compensation committee’s right to exercise negative discretion precludes a grant date during the year in which it communicated the award terms and performance targets to the executive and in which the service inception date begins.

In that case, the staff’s interpretation departs from strict adherence to the accounting treatment for the award to better reflect the compensation committee’s decisions, but Mary Alcock, counsel in the law firm Cleary Gottlieb Steen & Hamilton, notes that the interpretation “seems limited to a specific, and in some ways extreme, set of circumstances,” since negative discretion isn’t often used in the context of equity awards.

The staff also revised Question 119.16 and Interpretation 220.01.

As previously noted, the interpretations follow other updates to reflect the new rule, as reported  here, here, and here.

The Organization for Economic Co-operation and Development has issued new guidance on internal controls, ethics, and compliance to help its member countries implement anti-bribery strategies.

The OECD Working Group on Bribery has issued “Good Practice Guidance on Internal Controls, Ethics, and Compliance,” which calls for companies in the 38 countries that are party to the OECD Anti-Bribery Convention to put in place strict internal controls and establish ethics and compliance programs as part of a strategy to combat bribery in international business deals.

The March 3 guidelines “put further meat on the bones” of the Working Group’s November recommendations, which contained, among a number of key guidelines, “an important international recognition by 38 signatory countries of the need for companies to adopt proactive compliance and ethics programs to combat bribery and corruption when operating abroad,” says Donna Boehme, a principal with Compliance Strategists.

Specifically, the Guidance calls on businesses to: “Adopt a clear and visible anti-bribery policy that is strongly supported by senior management; instill a sense of responsibility for compliance with the policy at all levels of the company, as well as independent compliance structures; keep up regular communication and training on foreign bribery for all employees, as well as with business partners; and encourage observance of anti-bribery compliance measures, and disciplinary procedures to address their violations.”

The Guidance, which forms Annex II to the Working Group’s Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions, also recommends that business organizations play a leading role in providing information, advice, and training to companies, especially small- and medium-sized enterprises, on how to protect themselves against the risk of foreign bribery.

Boehme says the Guidelines not only incorporate the key principles of the Federal Sentencing Guidelines—including strong senior management tone and action, clear standards, protocols and internal controls, communication and training, and effective, appropriate disciplinary procedures—but in some respects, she says the guidelines “reach even further to validate the concepts of independent oversight and empowerment for the chief compliance officer.”

While the guidelines don’t have formal legal impact, the OECD Working Group will monitor each member country’s progress in encouraging companies to implement the guidance.

“We already have seen how this can be an effective change agent in how member countries approach anti-bribery and anti-corruption measures—expect to see more of the same as the Good Practice Guidelines are rolled out,” says Boehme. “It may take time, but this is an enormous step in ‘internationalizing’ the proactive approach of the FSG. Chief compliance and ethics officers should be proactive in educating their senior management and boards about this development and its impact on how countries beyond the United States are looking at bribery and corruption.”

The Securities and Exchange Commission had an unusually busy first fiscal quarter, but collected monetary payments in fewer cases than normal.

That’s according to a NERA Economic Consulting report detailing Q1 SEC Settlements Trends, which shows that the commission settled with 205 defendants in its first quarter of fiscal year 2010, compared to 181 in the previous quarter and 123 in the first fiscal quarter of 2009. (The SEC’s fiscal year starts on Oct. 1.)

The uptick is notable because the first quarter is typically a slow time for SEC settlements.

“In general, the first quarter is typically the quarter with the fewest settlements, and the end of the fiscal year tends to be a very active period with a lot of settlements,” Elaine Buckberg, NERA senior vice president and one of the report’s authors, tells Compliance Week.

Since the passage of the Sarbanes Oxley Act in 2002, Buckberg notes that there’s only been one other fiscal year where settlements were higher in the first quarter than in the prior quarter—2007.

Buckberg offers two primary explanations for the jump. One is that the SEC is “cleaning house” and getting rid of old cases that weren’t that strong, which would explain why many didn’t involve financial payments. If that’s the case, Buckberg says, “Then we would expect a return to normal Q2 settlement levels and a return to a higher percentage of company settlements involving financial payments.” However, that could take more than one quarter.

Another possibility: As part of stricter enforcement efforts, the SEC is tackling and settling more cases, which Buckberg says may mean more cases with weaker merits that don’t result in penalties. “If we see continuing higher levels of settlements and continuing lower levels of company settlements involving payments, that would bear out the theory that they’re casting a wider net to tighten enforcement.”

Also notable is the number of zero-dollar company settlements in the first quarter of 2010. Just 41 percent of company settlements during the quarter involved some form of monetary payment—the third-lowest in any quarter since the passage of SOX and far less than the 56 percent rate for the period from the fourth quarter of 2002 through Q4 of 2009. For individuals, 58 percent of settlements in the quarter included a payment, which NERA notes is consistent with recent levels.

While the number of settlements during the quarter was large, the amount of those settlements was generally modest. Among companies with settlements that included a monetary payment, both the average and median settlement amount for the quarter were down from fiscal 2009 levels. The median company settlement of $400,000 was the fourth lowest of any quarter since the passage of SOX and well below the $1 million median for fiscal 2009, while the $4.7 million average company settlement was the fifth lowest over the same period, and far less than the $10.8 million average for fiscal 2009.

For individuals whose settlements included a monetary payment, the median settlement amount was approximately $120,000. That’s compared with a range in the annual median from $100,000 to $133,000 since fiscal 2003. The average individual settlement was $730,000 for the quarter, compared to a range of annual average of $1 million to $3.7 million since fiscal 2003.

Only four of the 10 largest settlements for the quarter exceeded $10 million. The largest was a $43.7 million settlement in November with Value Line Inc., which was accused of misappropriating assets from mutual funds that it advised. The smallest among the 10 was a $3 million December settlement with Investools, Inc. related to alleged misrepresentations to customers.

The data excludes settlements relating to failure to file periodic financial statements with the SEC, administrative proceedings barring accountants because of felony convictions, and administrative proceedings barring brokers, dealers, and accountants for practicing while unregistered.

For those with an interest in Extensible Business Reporting Language, or XBRL, two groups are currently seeking public input related to the standard.

XBRL International Inc., the global consortium responsible for development and promotion of the business reporting standard, is seeking public comment on the future business requirements and technical roadmap for XBRL.

The group is seeking feedback on a discussion document published by the XBRL Standards Board, which is responsible for managing the technical development of XBRL, to help determine the consortium’s technical goals over the next five to 10 years.

The 28-page document, “XBRL: Towards a Diverse Ecosystem“ through March 19, seeks feedback on proposals focusing on three areas: Ease of use for developers; enabling information comparability around the world, and simplifying the use of XBRL data for analysis systems.

The discussion document includes dozens of questions for developers and users seeking comment on a number of issues, such as comparability across taxonomies and current challenges facing XBRL. Commenters can also respond via an online survey.

“The Discussion Document is one of the ways in which we are engaging the marketplace on the future business and technology requirements of the XBRL technology,” says Anthony Fragnito, CEO of XBRL International, Inc. In order to reach a broad audience, Fragnito says XII is also conducting Webinars on the discussion document.

John Turner, outgoing Chair of the XBRL Standards Board, says XII is now seeking to facilitate XBRL’s further adoption “inside the enterprise, as well as within other areas of the private and public sectors that rely on business reporting of all kinds.”

Meanwhile, the Securities and Exchange Commission is also seeking input for an upcoming public seminar to help companies and preparers comply with its XBRL reporting rules.

The March 23 seminar will help answer frequently asked questions about the rules and technology requirements. According to the SEC announcement, the staff will provide an overview of the XBRL taxonomy—the list of tags associated with Generally Accepted Accounting Principles, discuss the role of the Financial Accounting Foundation in maintaining that taxonomy, and provide guidance on other tools and information available to help with compliance.

Suggestions on questions and topics to be discussed at the seminar can be submitted by e-mailing Ask-OID@sec.gov with the words “Public Education Seminar” in the subject line.

The event will take place at the SEC’s Washington D.C. headquarters and will be Webcast on the SEC Website.