The staff of the Securities and Exchange Commission is seeking public comment on dozens of questions as part of its Work Plan on the possible adoption of International Financial Reporting Standards for U.S. issuers.

The agency issued the requests for comment in two separate releases dated Aug. 12. Comments on both are due 60 days following publication in the Federal Register.

One release seeks comment on the impact adopting IFRS would have on issuers’ compliance with contractual arrangements that require the use of U.S. Generally Accepted Accounting Principles, compliance with corporate governance requirements, and the application of certain legal standards tied to amounts determined for financial reporting purposes.

The other asks about the impact on U.S. investors’ current knowledge of IFRS, their preparedness for incorporation of IFRS into the financial reporting system for U.S. issuers; the ways investors educate themselves on changes in accounting standards, as well as the extent of, logistics for, and estimated time needed to make changes to improve investor understanding of IFRS and the related education process to ensure investors have a sufficient understanding of IFRS prior to potential incorporation.

As part of a statement adopted by the Commission in February reaffirming its support of convergence and global accounting standards, the SEC directed the staff to develop and execute a work plan aimed at hashing out several major issues identified during the comment period on its 2008 proposed roadmap that will impact its decision on whether and how to allow U.S. companies IFRS.

The SEC is supposed to decide in 2011 whether or not to allow domestic companies to make the move to IFRS. If it does move forward, the agency said that adoption wouldn’t occur until at least 2015.

Details of whether and how that move would occur are yet to be decided. The SEC’s 2008 proposed roadmap would’ve mandated adoption on a phased-in schedule. That plan had also contemplated letting some companies early adopt. In its February statement, the SEC dropped the early use option, but said it may consider the issue later.

The SEC is supposed to begin issuing public progress reports on the work plan by October.

Among other things, the releases ask about the extent and ways in which incorporating IFRS into the financial reporting system for U.S. issuers would affect the application, interpretation, or enforcement of contractual commercial arrangements, such as financing agreements, trust indentures, merger agreements, executive employment agreements, stock incentive plans, leases, franchise agreements, royalty agreements, and preferred stock designations.

Other questions ask what other types of contractual commercial arrangements would likely be affected, and how; and whether, for existing arrangements, the incorporation of IFRS would be treated differently than a change in existing financial reporting standards under U.S. GAAP would be treated today, and if so, how.

Some of the questions seek comment on the extent to which a move to IFRS would have any potential adverse effects on issuers’ compliance with corporate governance and related disclosure requirements

The agency also asks how the set of accounting standards used by a company for financial reporting are significant to an investor’s decision to invest in that company; how the current differences between U.S. GAAP and IFRS would affect an investor’s use of the information reported in the financial statements; how completion of the convergence projects would affect investors’ use of those financial statements, and how investors think incorporation of IFRS would affect comparability among different issuers’ financial statements.

The SEC also seeks comment on whether providing for a transition or phase-in period for compliance would mitigate or avoid any of the potential effects of incorporating IFRS, and how long a transition or phase-in period would be necessary. The releases also invite comment on whether the manner in which IFRS incorporation is implemented would have any affect on the answers to any of the questions.

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.

The Securities and Exchange Commission voted unanimously today to publish a statement updating its position on the possible adoption by U.S. companies of International Financial Reporting Standards that keeps a 2011 deadline for making a final decision on whether or not to make the move, but would delay adoption until at least 2015.

Under the statement approved at a Feb. 24 open meeting, if ongoing convergence projects are successfully completed and a forthcoming SEC staff work plan is executed, the Commission would still make a decision in 2011 on whether to adopt IFRS for all U.S. companies.

However, based on views by commenters on its 2008 proposed roadmap for IFRS adoption that companies would need a four- to five-year timeframe to make the change in their financial reporting systems to incorporate IFRS, SEC officials said if they decide to move forward with IFRS adoption, U.S. companies wouldn’t report under IFRS any earlier than 2015.

The 2008 proposed roadmap for IFRS adoption contemplated letting some U.S. companies use IFRS as soon as filings for fiscal years ending on or after Dec. 15, 2009, and would’ve mandated adoption on a phased-in schedule starting in 2014.

Under today’s statement, the SEC isn’t pursuing the early use option at this time, but said it may consider it later. It also left open the question as to how issuers would adopt IFRS—for instance whether it would be mandated or voluntary and phased-in or all at once.

The statement directs the SEC staff to gather information to help the Commission evaluate the impact that the use of IFRS by domestic companies would have on the U.S. securities market, with public progress reports beginning by October 2010 on a staff work plan and on the status of convergence efforts by U.S. and international standard setters.

The Financial Accounting Standards Board, which oversees U.S. Generally Accepted Accounting Principles, and the International Accounting Standards Board, which sets IFRS, set a 2011 target date for a completion of their current convergence projects. The Commission said it will continue to monitor the progress of those efforts.

According to an SEC fact sheet, the staff work plan will focus on concerns raised by commenters including:

• Determining whether IFRS is sufficiently developed and consistent in application for use as the single set of accounting standards in the U.S. reporting system.
• Ensuring that accounting standards are set by an independent standard-setter and for the benefit of investors.
• Investor understanding of and education about IFRS, and how it differs from U.S. GAAP.
  Understanding whether U.S. laws or regulations beyond the securities laws, such as tax laws and regulatory reporting, would be affected by a change in accounting standards.
• Understanding the impact on large and small companies, including changes to accounting systems, changes to contractual arrangements, corporate governance considerations, and litigation contingencies.
• Determining whether the people that prepare and audit financial statements are sufficiently prepared, through education and experience, to make the conversion to IFRS.

Roughly a third of the capital markets outside of the United States use IFRS, according to the SEC. Foreign private issuers have been permitted since 2008 to file financial statements with the SEC prepared in accordance with IFRS without reconciling to U.S. GAAP.

“Incorporating IFRS into our financial reporting system would involve a significant undertaking,” SEC Chairman Mary Schapiro said in remarks during the meeting. “We must carefully consider and deliberate whether such a change is in the best interest of U.S. investors and markets.”

At the same meeting, the SEC voted 3-2 to adopt an alternative uptick rule, which amends Rules 201 and 200(g) of Regulation SHO to impose short sale restrictions.

Under the rule, which was opposed by Republican Commissioners Kathleen Casey and Troy Paredes, a circuit breaker would be triggered for a stock any time its price drops 10 percent or more from the prior day’s closing price in one day, and short selling in that security would only be allowed if the price is above the current national best bid.

The alternative uptick rule would apply to short sale orders in that stock for the remainder of the day and the following day. The SEC said the rule generally would apply to equity securities listed on a national securities exchange, whether traded on an exchange or in the over-the-counter market.

The topic of International Financial Reporting Standards for domestic companies is back on the Securities and Exchange Commission’s agenda.

At an Open Meeting on Feb. 24, the Commission will consider “whether to publish a statement regarding its continued support for a single-set of high-quality globally accepted accounting standards and its ongoing consideration of incorporating International Financial Reporting Standards into the financial reporting system for U.S. issuers,” according to a Sunshine Act Meeting Notice posted Feb. 19.

At the same meeting, the SEC will also consider whether to adopt amendments to Rules 201 and 200(g) of Regulation SHO relating to short-sale restrictions.

The SEC published its proposed roadmap on the adoption of IFRS for U.S. companies for comment in November 2008, as the economic crisis was deepening. Under that proposal, a small group of public companies would be able to  start filing using IFRS voluntarily as early as 2010, and others would be required to adopt the standards on a phased-in scheduled, starting with fiscal years ending on or after Dec. 15, 2014, if certain milestones were met. A final decision on whether to move ahead with mandatory adoption would be made in 2011.

While the 200-plus comment letters were generally supportive of the pursuit of a single set of global accounting standards, they were sharply divided on how best to get there.

The proposed roadmap was put on the back burner last winter as the SEC dealt with the financial crisis, the Madoff fraud debacle, and a change in its leadership when the new administration took over last year.

After remaining mum on the issue for months, SEC officials in public remarks last fall said that converging U.S. Generally Accepted Accounting Principles and IFRS would be a high priority for the agency. The U.S. accounting standards setters, the Financial Accounting Standards Board and the International Accounting Standards Board, which sets IFRS, are working on several major joints projects to bring their standards closer.

As previously reported, at a conference in December, SEC Commissioner Elisse Walter said the SEC wouldn’t move forward with any plan until it was satisfied that concerns about IASB’s susceptibility to political pressure and independence were resolved.

Back in 2007, the SEC abolished a long-standing requirement that overseas companies listed on U.S. exchanges reconcile their financial statements to U.S. Generally Accepted Accounting Principles if they file using IFRS as promulgated by IASB.

Those awaiting a date certain for the adoption of International Financial Reporting Standards by U.S. companies will have to wait a little longer.

Securities and Exchange Commission officials speaking at a financial reporting conference this week promised that they’re developing a work plan, but didn’t give any clues about when the SEC might announce any sort of timeline.

Speculation about when the SEC might act and what it will do related to its proposed roadmap has been rampant since commission officials remarked in September that convergence and the roadmap would be a majority priority this fall—leading speakers at the event to quip that fall officially ends on Dec. 21.

SEC chief accountant James Kroeker, speaking at Financial Executives International’s current financial reporting issues conference in New York on Nov. 16 said that his office is developing a “work plan” to follow up on the issues identified during the comment period on the SEC’s proposed roadmap for IFRS adoption by U.S. companies.

“A host of issues were identified during the comment process,” Kroeker said. “The seven milestones we identified weren’t the only issues people viewed as important.”

He assured corporate reporting executives that if and when the SEC moves ahead with IFRS adoption for U.S. SEC registrants, to expect “ample time to prepare.”

“We understand … that people are going to need time if there is a mandate to do all of the systems work, to invest in the human capital, invest in the systems, and invest in an understanding of IFRS,” he said. He noted that part of that is tied to current convergence projects underway between U.S. and international accounting standard setters, since some of the new standards companies would have to adopt are still under development.

“Expect ample time,” he said. “We will consider the needs of preparers, auditors, and investors … as we talk about continued progress toward IFRS.”

He also urged financial statement preparers and others to monitor and comment on projects undertaken by the International Accounting Standards Board.

“Comment on those projects like you would on projects undertaken by FASB,” he said. “In a number of cases IASB is taking the first crack at some projects … and [for projects outside of their Memorandum of Understanding] IASB might be taking the lead where [the Financial Accounting Standards Board] has plans to put a wrap-around document around an IASB proposal.”

Regardless of the follow up on the concepts in the proposed roadmap, Kroeker said it’s important that FASB and IASB continue their efforts toward convergence.

Meanwhile, he said working with FASB on improvements to accounting standards for financial instruments under Statement 166 and 167 “will continue to be a high priority for our office.”

While they’re currently taking differing approaches in revising their standards on accounting for financial instruments with respect to the use of fair value, FASB and IASB have pledged to work more closely to align their views on the role of fair value.

Kroeker said his personal view is that “It’s time to move beyond the debate of whether fair value is relevant for financial assets or whether historical cost is relevant for certain classes of financial assets.”

“I think there is room for both,” he said. “The difficult challenge is how you appropriately convey both sets of information.”

Compliance Week will provide readers with detailed coverage from the FEI conference in this blog and in its Nov. 24 issue.

With convergence front-and-center once again, most finance professionals say they would support the Securities and Exchange Commission’s approval of its proposed roadmap for adopting International Financial Reporting Standards, but the majority think the SEC should push back the mandatory deadline by a year.

That’s according to a survey of more than 150 finance professionals conducted by Deloitte, in which 51 percent of those polled said the SEC should approve the proposed roadmap, but consider pushing back the mandatory deadline a year. Almost 20 percent said the roadmap should be approved “as is.” Only 12 percent said the SEC should reject the proposed roadmap in its entirety.

The SEC approved the use of IFRS for financial reports filed by foreign issuers in 2007. Domestic companies have been awaiting the SEC’s next move on the proposed roadmap, which called for the SEC to decide in 2011 whether to mandate IFRS for U.S. companies beginning in 2014.

While the roadmap appeared to be on the fast track when it was published by the SEC late last year, enthusiam seemed to have waned by the time the comment period closed in April, as the SEC grappled with the financial crisis and criticism of high-profile enforcement failures, and its chairman, Mary Schapiro, raised concerns about the move.

However, recent public statements by SEC officials and global financial leaders at the recent Group of Twenty meeting focusing on the need to work toward a single set of global accounting standards have reignited the discussion about IFRS adoption by the U.S.

In particular, the G-20’s call for accounting standard setters to redouble their efforts to achieve a single set of global accounting standards by June 2011 is expected to increase pressure on the Financial Accounting Standards Board and the International Accounting Standards Board to converge several major standards next year.

According to the Deloitte survey, among those companies that said they put their IFRS assessment plans on hold, 45 percent said the reason was the delay in the SEC’s proposed IFRS roadmap, while 20 percent citing economic challenges or a lack of internal support and resources as the reason. Meanwhile, 26 percent say they didn’t delay their assessment and are currently on track with their IFRS planning efforts.

Meanwhile, only 34 percent of those surveyed say IFRS adoption would make the U.S. more competitive in the global marketplace, while 38 percent say it wouldn’t.

The Securities and Exchange Commission’s proposed roadmap for the U.S. adoption of International Financial Reporting Standards appears poised to emerge from the deep freeze.

A top SEC official hinted that the proposal will see some sort of action soon, although exactly what is unclear.

Speaking Sept. 17 at an SEC conference sponsored by the New York State Society of CPAs, the Commission’s Chief Accountant, James Kroeker, said the convergence of accounting standards is “going to be a priority of the staff over the coming weeks and months.”

The SEC has been mum on the proposed roadmap—which laid out milestones for the possible adoption by U.S. issuers of IFRS on a phased-in basis starting in 2014, but putting off the decision on whether or not to mandate the move until 2011—since the comment period ended in April. Moreover, comments by SEC Chairman Mary Schapiro earlier this year citing concerns about the move suggested that momentum for IFRS adoption had slowed.

The SEC published its proposed roadmap for the adoption of IFRS by domestic companies last November and later extended the comment period at some commenters’ requests, since the original deadline coincided with most companies finalizing their 10-Ks.

“Some looked at that as a signal that we’re no longer as committed to the idea of a single set of high-quality accounting standards or that convergence wasn’t important,” Kroeker said. “I wouldn’t read that into the deferral at all.”

“We will be turning our attention to the proposal we issued last fall and focusing on IFRS again as a priority in our office,” he added.

Compliance Week will have full details of Kroeker’s remarks in its Sept. 22 edition.

Smaller companies should prepare to become “more familiar” with the auditor attestation requirement under Section 404(b) of the Sarbanes-Oxley Act, an SEC commissioner told a group of compliance officers gathered in Washington D.C.

The SEC’s cost-benefit study on Section 404 is “close to final” and the anecdotal evidence is that “the hard learning that the large accelerated filers have done, the work by the PCAOB in re-doing Auditing Standard No. 5, and guidance given by groups such as COSO have all tended to help create a more scalable system,” SEC commissioner Luis Aguilar told attendees at Compliance Week’s annual conference.

In response to a question about whether non-accelerated filers would finally have to comply with the provision, Aguilar said, “The expectation and hope is that the costs are going to be more in line with smaller companies.”

Smaller companies currently comply with the management assessment required under 404(a). They’re slated to comply with Section 404(b) until fiscal years ending on or after Dec. 15, 2009. When the SEC granted those companies yet another extension on compliance with the auditor attestation provision last year, the Commission said it would use the time to study the costs and benefits of SOX 404 implementation and assess whether its efforts to ease that burden have helped, seemingly leaving the door open to another delay. However, the SEC’s new chairman, Mary Schapiro, has said she wants to “bring uniformity to the system,” suggesting that small companies may really finally have to bite the SOX 404(b) bullet.

“If I was a betting person … I think smaller issuers will be familiar with 404(b) more so than they are now,” Aguilar said during a Q&A session following his June 3 speech. Any further extension would have to be approved by the SEC’s five commissioners.

So far, the SEC has been mum on when it will publish the findings of the study. Speaking to reporters after the Q&A, Aguilar noted that if the study “indicated a vast disconnection between the costs and benefits, we would have to revisit it, but my working hypothesis is that it won’t be extended.”

During his remarks, Aguilar reiterated his support for an “Integrated Capital Markets Regulator” that would combine the functions of the SEC, the Commodity Futures Trading Commission, and the functions of the Department of Labor’s Employee Benefits Security Administration.

While Aguilar called the odds of a merger between the SEC and CFTC “low,” speaking to reporters after the event, Aguilar said, “If it’s ever likely to happen, this is the moment … but I fully appreciate the politics behind those decisions.” Turf wars between the congressional committees that oversee the two agencies have been blamed as hampering past merger efforts.

Though he said he has no objection to the CFTC maintaining oversight for agricultural commodity derivatives, Aguilar says derivatives that “are nothing more than an economic substitute for securities” should be regulated by the SEC.

Aguilar also addressed the topic of enforcement. Thanks to an increase in the agency’s resources and funding, he told attendees, “You’re going to see much more aggressive enforcement soon.”

Aguilar said the staff is looking at which cases will have the greatest impact as part of an effort to better marshal its resources. Following criticism that its enforcement efforts were shackled by previous policies, Schapiro moved to act earlier this year to end a controversial pilot penalty program and to expedite the process for getting formal orders of investigation.

Noting that there are “more initiatives in the works,” Aguilar said, “You can expect us to have people on the ground quicker when something comes to our attention.”

When asked about the Commission’s timeline for the U.S. adoption of International Financial Reporting Standards, Aguilar acknowledged that momentum for the effort seems to have slowed.

“The dialogue will continue, but … this will probably be driven much slower,” he told conference goers.

The SEC published a roadmap for IFRS adoption last fall. Comments on the proposal were due April 20. While her predecessor, Christopher Cox, championed the move to IFRS, Schapiro has sounded concerns about the plan and in particular, about the independence of the body that sets international standards. The economic climate is also vastly different.

While he said the current move to convergence should “be fostered and continue,” Aguilar said there should be a focus on “how investors fare under both systems.”

Aguilar expressed enthusiasm for the SEC proposal on shareholder access to the proxy for nominating director candidates.

“To me it’s corporate law 101,” he said. “Shareholders own the corporation. They have the ability to nominate shareholders … but the modern reality of public companies is that those decisions are made in the proxy statement.”

By the time the annual meeting rolls around, he said, “those decisions have already been made and … proxy cards are being tabulated.”

“What we’re doing is providing a disclosure mechanism by which shareholders can exercise the power they already have” under state law, he said.

The Securities and Exchange Commission has extended the comment period on its proposed roadmap for the potential use of International Financial Reporting Standards by U.S. issuers.

The original comment period was scheduled to end on Feb. 19. In response to commenters, the SEC is extending the comment period for 60 days until April 20.

The proposing release was published in the Federal Register on Nov. 21, 2008.

Those calling for the comment period to be extended include Northrop Grumman Corp., Raytheon Co., Honeywell, the Aerospace Industries Association, United Technologies Corp., and Financial Executives International.

The proposed roadmap sets forth milestones that, if achieved, could lead to the required use of IFRS as issued by the International Accounting Standards Board by U.S. issuers by 2014.

SEC chairwoman Mary Schapiro expressed concerns about the current proposal during her confirmation hearing, including the independence of IASB and the cost of switching to IFRS.

“I’ll look at this entire area carefully and will not necessarily feel bound by the existing roadmap that’s out for comment,” she told Senate lawmakers.

Just in time for the weekend, financial reporting executives have some light reading, courtesy of the Securities and Exchange Commission.

The agency has finally posted the long-awaited 206-page adopting release for the rule mandating the use of XBRL technology. The rule, formally known as Interactive Data to Improve Financial Reporting, was approved by the Commission on Dec. 17. It phases in a requirement for issuers that use U.S. Generally Accepted Accounting Principles or International Financial Reporting Standards to provide their financial statements, both to the SEC and on their corporate Websites, in XBRL, as an exhibit to periodic and current reports, registration statements, and transition reports for a change in fiscal year.

Under the final rule, domestic and foreign large accelerated filers that use U.S. GAAP and have a worldwide public float above $5 billion as of the end of the second fiscal quarter of their most recently completed fiscal year—that is, roughly the 500 largest public companies listed in the United States—must comply with the mandate starting with their first periodic filing after June 15, 2009.

All other domestic and foreign large filers using U.S. GAAP (approximately 1,000 more) will be subject to the requirements the following year, beginning with their periodic filings after June 15, 2010. All remaining filers using U.S. GAAP, including smaller reporting companies and all foreign private issuers that use IFRS as issued by the International Accounting Standards Board (roughly 8,700 companies), will comply one year after that.

Financial statement footnotes and financial statement schedules initially will be tagged as blocks of text. After a year, a filer also will be required to tag the detailed quantitative disclosures within the footnotes and schedules and will be “permitted, but not required, to the extent they choose, to tag each narrative disclosure.” The SEC said that change reduced its estimates for detailed tagging in the adopting release by 30 percent to 70 hours for the first filing and 35 hours for subsequent filings.

The SEC estimates the average yearly burden of the requirements over the first three years would be 226 man hours and $27,300 in out-of-pocket expenses per filer.

The SEC also eased the timing of the required Website posting to require filers to post the interactive data exhibit on their corporate Website not later than the end of the calendar day it submitted or was required to submit the exhibit, whichever is earlier. As proposed, Website posting would’ve been required by the end of the business day. The adopting release also clarifies that interactive data must be posted on an issuer’s site for at least 12 months.

The final rule keeps the two proposed 30-day grace periods: one for the issuer’s first interactive data exhibit and another in year two, for the first interactive data exhibit that includes detailed tagging of its footnotes and schedules.

The rule is effective 60 days after publication in the Federal Register.

Compliance Week Will provide readers will full details in upcoming editions.