As we approach the end of the first quarter of 2011, planning for the implementation of presenting financial statements submitted to the Securities and Exchange Commission ("SEC") in interactive data files using eXtensible Business Reporting Language, or XBRL, should be at the forefront of every smaller reporting company’s agenda.
Starting as soon as the filing of the Form 10-Q for the quarter ending June 30, 2011, these companies are the third wave of SEC reporting companies required to submit financial statements using XBRL reporting in response to a SEC rule that took effect in 2009. Although there is a phase-in period for certain reporting requirements, smaller reporting companies should be in the process of familiarizing themselves with the rule requirements and the XBRL reporting process. Initially, they must determine whether the financial statement ‘tagging’ will be performed in-house or with the assistance of a third-party vendor. Most importantly, the companies need to incorporate XBRL reporting into their financial reporting process and be prepared to accommodate additional time required for the creation and review of the XBRL exhibits, as well as any last-second updates to their financial statements which will also need to be manifested in the XBRL exhibits.
For more information on XBRL reporting please view our Securities Compliance Update posted July 2, 2010. If you should have questions on XBRL reporting or require assistance with implementation, please contact any member of the firm’s Public Companies/Securities practice group.
- Gordon Forth, Chairman - 585-987-2801 or gforth@woodsoviatt.com
- Gregory Gribben -585-987-2875 or ggribben@woodsoviatt.com
- Timothy D. Condon – 585-987-2803 or tcondon@woodsoviatt.com
- Christopher Rodi - 585-987-2820 or crodi@woodsoviatt.com
- Sean Jensen -585-987-2819 or sjensen@woodsoviatt.com
This Memo has been prepared by Woods Oviatt Gilman, LLP for informational purposes only and does not constitute legal advice. This information is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this without seeking advice from professional advisers.
To receive future copies of Securities Compliance materials via e-mail, please send your name, company or firm name and e-mail address to Kelly Beauchamp at kbeauchamp@woodsoviatt.com.
