Interactive Data

Question: How should registrants subject to Inline XBRL requirements identify the Interactive Data Files in the exhibit index of an applicable filing?

Answer: Registrants subject to Inline XBRL requirements should identify any Interactive Data File required under Rule 405 of Regulation S-T as exhibit 101 in the exhibit index and any Cover Page Interactive Data File required under Rule 406 of Regulation S-T as exhibit 104 in the exhibit index. Additionally, when an interactive data file is submitted using Inline XBRL, Instruction 1 to paragraphs (b)(101)(i) and (ii) of Regulation S-K Item 601 requires that the exhibit index include the word “Inline” within the title description for any such exhibit.

As described in Volume II, Chapter 6.3.2 of the EDGAR Filer Manual, registrants should satisfy the requirement to submit a Cover Page Interactive Data File using an Inline XBRL Document Set with EX-101.* attachments other than EX-101.INS. Accordingly, in the case of a Cover Page Interactive Data File identified as exhibit 104 in the exhibit index, the exhibit index should cross-reference to the Interactive Data Files submitted under EX-101. For submissions made with Form 8-K, see Question 101.04. [Aug. 20, 2019]

Question: If an issuer voluntarily submits Interactive Data Files in Inline XBRL format prior to its applicable phase-in date, must the issuer comply with the cover page data tagging requirements with those submissions?

Answer: No. Cover page data tagging requirements apply to issuers that are “required to submit Interactive Data Files in Inline XBRL format.” See Rule 406 of Regulation S-T. Issuers that voluntarily submit Interactive Data Files in Inline XBRL format prior to their applicable phase-in date are not “required to submit Interactive Data Files in Inline XBRL format” and, therefore, such issuers are not subject to the cover page data tagging requirements. [Aug. 20, 2019]

Question: Registrants subject to Inline XBRL requirements are required to tag all of the information on the cover page of Form 10-K, Form 10-Q, Form 8-K, Form 20-F, and Form 40-F using Inline XBRL. Are all Forms 8-K subject to this requirement?

Answer: Yes. All Forms 8‑K, not only those that contain financial statements for which XBRL data is required, are subject to this requirement. [Aug. 20, 2019]

Question: Item 601(b)(104) of Regulation S-K requires a Cover Page Interactive Data File to be filed as an exhibit to the respective forms listed in the exhibit table. Are registrants subject to Inline XBRL requirements required to identify the Cover Page Interactive Data File as exhibit 104 under Item 9.01 of Form 8-K?

Answer: As discussed in Question 101.01 above, Cover Page Interactive Data Files required under Rule 406 of Regulation S-T should be identified as exhibit 104 in the exhibit index of an applicable filing. If, however, the exhibit index of a Form 8-K would include only a Cover Page Interactive Data File as exhibit 104, and would not include any other exhibit, the staff will not object if the registrant does not add an exhibit index to the Form 8-K solely for the purpose of identifying the Cover Page Interactive Data File as an exhibit under Item 9.01 of Form 8-K. [Aug. 20, 2019]

Question: Registrants subject to Inline XBRL requirements are required to tag all of the information on the cover page of Form 10-K, Form 10-Q, Form 8-K, Form 20-F, and Form 40-F using Inline XBRL, including the company name. How should registrants comply with the cover page tagging requirements where the company name, as it appears on the cover page of the applicable form, differs from the company name, as conformed to EDGAR naming conventions in the company’s EDGAR file?

Answer: Where a company’s name, as it appears on the cover page of a form, differs from its conformed name in EDGAR, it is permissible for the Inline XBRL tagged company name shown on the cover page to vary from the EDGAR conformed name in various ways. Most such variations will not prevent the filing from being accepted and disseminated. In rarer instances, a variation may result in a notice of suspension. In those instances, the filer should contact EDGAR Filer Technical Support. Registrants whose company name does not match their EDGAR conformed company name may wish to consider updating their conformed company name in EDGAR. See Volume I, Chapter 5.4 of the EDGAR Filer Manual for instructions on how to edit your company information. [Aug. 20, 2019]

Question: If an issuer elects to voluntarily submit Interactive Data Files in Inline XBRL format prior to its applicable phase-in date, can the issuer cease such voluntary submissions prior to its applicable phase-in date?

Answer: Yes. Issuers can cease such voluntary submissions until they are required to submit Interactive Data Files in Inline XBRL format pursuant to the phase-in schedule. [Aug. 20, 2019]

Question: Form 10-Q filers are required to comply with Inline XBRL beginning with their first Form 10-Q for a fiscal period ending on or after the applicable compliance date, as opposed to the first filing for a fiscal period ending on or after that date. Where a registrant files a Form 8-K earlier on the same day as its first Form 10-Q for a fiscal period ending on or after the applicable compliance date, must the Form 8-K comply with Inline XBRL cover page tagging requirements?

Answer: No. Because the Form 8-K was filed before the first Form 10-Q was due for a fiscal period ending on or after the applicable compliance date, the Form 8-K need not comply with Inline XBRL cover page tagging requirements. [Aug. 20, 2019]

Question: What is the applicable phase-in period for compliance with the Inline XBRL requirements for foreign private issuers?

Answer: Foreign private issuers will be required to comply with the Inline XBRL requirements based on their filer status and basis of accounting. For a foreign private issuer that prepares its financial statements in accordance with U.S. GAAP, the phase-in of the Inline XBRL requirements is determined based on its filer status. Large accelerated filers, including foreign private issuers, that prepare their financial statements in accordance with U.S. GAAP will be required to comply with Inline XBRL for financial statements for fiscal periods ending on or after June 15, 2019. Accelerated filers, including foreign private issuers, that prepare their financial statements in accordance with U.S. GAAP will be required to comply with Inline XBRL for financial statements for fiscal periods ending on or after June 15, 2020. All other filers, including foreign private issuers that prepare their financial statements in accordance with IFRS, will be required to comply with Inline XBRL for financial statements for fiscal periods ending on or after June 15, 2021. [Aug. 20, 2019]

Question: Form 10-Q filers are required to comply with Inline XBRL beginning with their first Form 10-Q for a fiscal period ending on or after the applicable compliance date. How does this provision apply to Form 20-F and 40-F filers?

Answer: Form 20-F and 40-F filers do not have quarterly report filing obligations. Therefore, these filers will be required to comply with Inline XBRL beginning with the first filing on a form for which Inline XBRL is required for a fiscal period ending on or after the applicable compliance date, as determined in accordance with Rule 405(f)(1)(i) of Regulation S-T. [Aug. 20, 2019]

Question: If an issuer files Exchange Act reports on a voluntary basis — for example, because its Section 15(d) filing obligation is suspended — must the issuer comply with the interactive data requirements and, if so, what is the first interactive data submission required?

Answer: Yes. The issuer would be included in the group of filers required to comply with the interactive data requirements beginning with the first Form 10-Q, 20-F or 40-F for a fiscal period ending on or after June 15, 2011. [May 29, 2009]

Question: Can a filer rely on Exchange Act Rule 12b-25 to extend the due date of an Interactive Data File?

Answer: No. Rule 12b-25 has been amended to state that its provisions do not apply to Interactive Data Files. Filers that are unable to submit or post Interactive Data Files when required must comply with the hardship exemption requirements of either Rule 201 (temporary hardship exemption) or Rule 202 (continuing hardship exemption) of Regulation S-T. However, filers that are unable to file their traditional format financial statements by the prescribed due date — but qualify for the additional time permitted under Rule 12b-25 and file their traditional format financial statements within that time — would not be required to submit and post their interactive data until the traditional format financial statements are filed. [May 29, 2009]

Question 162.01

Question: The interactive data adopting release provides that controls and procedures with respect to interactive data fall within the scope of "disclosure controls and procedures." See Securities Act Release No. 9002 (Jan. 30, 2009). Exchange Act Rules 13a-15 and 15d-15 require certain officers to evaluate the effectiveness of the filer's disclosure controls and procedures, and Item 307 of Regulation S-K requires the filer to disclose the officers' conclusions regarding the effectiveness of those disclosure controls and procedures. However, the adopting release also adopts amendments to Exchange Act Rules 13a-14 and 15d-14 that exclude interactive data from officer certifications, which, among other things, describe the officers' responsibility for establishing and maintaining disclosure controls and procedures and require statements regarding their design and evaluation. Is a filer that submits interactive data in an exhibit to a Form 10-K or 10-Q required to consider controls and procedures with respect to interactive data in complying with Exchange Act Rules 13a-15 and 15d-15 and Item 307?

Answer: Yes. Controls and procedures with respect to interactive data fall within the scope of "disclosure controls and procedures." That the principal executive and financial officers do not need to consider such controls in making their individual certifications about their responsibility for establishing and maintaining the filer's disclosure controls and procedures does not mean that the filer can exclude such controls in complying with Rules 13a-15 and 15d-15 and Item 307 of Regulation S-K. [May 29, 2009]

Question: The interactive data adopting release provides that controls and procedures with respect to interactive data fall within the scope of "disclosure controls and procedures." See Securities Act Release No. 9002 (Jan. 30, 2009). Exchange Act Rules 13a-15 and 15d-15 require certain officers to evaluate the effectiveness of the filer's disclosure controls and procedures, and Item 307 of Regulation S-K requires the filer to disclose the officers' conclusions regarding the effectiveness of those disclosure controls and procedures. However, the adopting release also adopts amendments to Exchange Act Rules 13a-14 and 15d-14 that exclude interactive data from officer certifications, which, among other things, describe the officers' responsibility for establishing and maintaining disclosure controls and procedures and require statements regarding their design and evaluation. Is a filer that submits interactive data in an exhibit to a Form 10-K or 10-Q required to consider controls and procedures with respect to interactive data in complying with Exchange Act Rules 13a-15 and 15d-15 and Item 307?

Answer: Yes. Controls and procedures with respect to interactive data fall within the scope of "disclosure controls and procedures." That the principal executive and financial officers do not need to consider such controls in making their individual certifications about their responsibility for establishing and maintaining the filer's disclosure controls and procedures does not mean that the filer can exclude such controls in complying with Rules 13a-15 and 15d-15 and Item 307 of Regulation S-K. [May 29, 2009]

Question: If a Form 8-K contains audited annual financial statements that are a revised version of financial statements previously filed with the Commission and have been revised to reflect the effects of certain subsequent events, such as discontinued operations, a change in reportable segments or a change in accounting principle, then under Item 601(b)(101)(i) of Regulation S-K, the filer must submit an interactive data file with the Form 8-K for those revised audited annual financial statements. Paragraph 6(a) of General Instruction C of Form 6-K contains a similar requirement. Item 601(b)(101)(ii) of Regulation S-K and Paragraph 6(b) of General Instruction C of Form 6-K permit a filer to voluntarily submit an interactive data file with a Form 8-K or 6 K, respectively, under specified conditions. Is a filer permitted to voluntarily submit an interactive data file with a Form 8-K or 6-K for other financial statements that may be included in the Form 8-K or 6-K, but for which an interactive data file is not required to be submitted? For example, if the Form 6-K contains interim financial statements other than pursuant to the nine-month updating requirement of Item 8.A.5 of Form 20-F?

Answer: Yes, if the filer otherwise complies with Item 601(b)(101)(ii) of Regulation S-K and Paragraph 6(b) of General Instruction C of Form 6-K, as applicable. [Sep. 14, 2009]

Question 101.05

Question: If a filer is required to submit an interactive data file with a form other than a Form 8-K or 6-K, may the filer satisfy this requirement by submitting the interactive data file with a Form 8-K or 6-K?

Answer: No. If a filer does not submit an interactive data file with a form as required, the filer must amend the form to include the interactive data file. [Sep. 14, 2009]

Question 115.03

Question: Must a filer provide disclosures under Item 4.02(a) of Form 8-K when it discovers a material error in its Interactive Data File while the financial statements upon which they are based do not contain an error and may continue to be relied on?

Answer: No. Item 4.02(a) requires a Form 8-K only when the filer determines that previously issued financial statements should no longer be relied upon because of an error in those financial statements. If a filer wants to voluntarily provide non-reliance disclosure similar to Item 4.02(a) that pertains only to the interactive data, it can do so under either Item 7.01 or Item 8.01 of Form 8 K. In any event, if a filer finds a material error in its Interactive Data File, it must file an amendment to correct the error. In addition, once a filer becomes aware of the error in its Interactive Data File, it must correct the error promptly in order for the Interactive Data File to be eligible for the modified treatment under the federal securities laws provided by Rule 406T of Regulation S-T. [May 29, 2009]

Question: Even though interactive data exhibits are not required for initial public offerings, can a filer voluntarily submit an interactive data exhibit for an IPO on Form S-1?

Answer: Yes. If the filer chooses to submit an interactive data exhibit with an IPO on Form S-1, however, it must include the exhibit as soon as the registration statement contains a price or price range and subsequent amendments also must include the interactive data exhibit if the financial statements are changed. [May 29, 2009]

Question 146.13

Question: If a Form 8-K contains audited annual financial statements that are a revised version of financial statements previously filed with the Commission and have been revised to reflect the effects of certain subsequent events, such as discontinued operations, a change in reportable segments or a change in accounting principle, then under Item 601(b)(101)(i) of Regulation S-K, the filer must submit an interactive data file with the Form 8-K for those revised audited annual financial statements. Paragraph 6(a) of General Instruction C of Form 6-K contains a similar requirement. Item 601(b)(101)(ii) of Regulation S-K and Paragraph 6(b) of General Instruction C of Form 6-K permit a filer to voluntarily submit an interactive data file with a Form 8-K or 6 K, respectively, under specified conditions. Is a filer permitted to voluntarily submit an interactive data file with a Form 8-K or 6-K for other financial statements that may be included in the Form 8-K or 6-K, but for which an interactive data file is not required to be submitted? For example, if the Form 6-K contains interim financial statements other than pursuant to the nine-month updating requirement of Item 8.A.5 of Form 20-F?

Answer: Yes, if the filer otherwise complies with Item 601(b)(101)(ii) of Regulation S-K and Paragraph 6(b) of General Instruction C of Form 6-K, as applicable. [Sep. 14, 2009] [repeat of Question 101.04]

Question: How does a filer determine when it is required to submit interactive data and to "detail tag" the financial statement footnotes and schedules in its interactive data?

Answer: A filer first assesses its filing status at the end of each fiscal year (by looking to its public float as of the end of the most recently completed second quarter) and then follows the phase-in provisions for that status in the filings it makes during the immediately following fiscal year.

For example, as of December 31, 2009, a calendar-year domestic filer is a large accelerated filer with a public float under $5 billion on the last business day of its second quarter ended June 30, 2009. For purposes of its 2010 filings, the filer will follow the submission requirements of Item 601(b)(101)(i)(B) of Regulation S-K and the detail tagging requirements of Rule 405(f)(2) of Regulation S-T. Accordingly, the filer is required to submit interactive data with its Forms 10-Q for the quarters ended June 30 and September 30, 2010 but need not detail tag the financial statement footnotes and schedules until its Form 10-Q for the quarter ended June 30, 2011, assuming that, as of December 31, 2010, it is a large accelerated filer with a public float under $5 billion on the last business day of its second quarter ended June 30, 2010.

If the filer, as of December 31, 2010, is no longer a large accelerated filer, for purposes of its 2011 filings, it will follow the submission requirements of Item 601(b)(101)(i)(C) of Regulation S-K and the detail tagging requirements of Rule 405(f)(3) of Regulation S-T. Accordingly, the filer would not be required to submit interactive data with its Form 10-K for the year ended December 31, 2010 or Form 10-Q for the quarter ended March 31, 2011, but it would be required to submit interactive data with its Forms 10-Q for the quarters ended June 30 and September 30, 2011. The filer would not be required to detail tag the financial statement footnotes and schedules until its Form 10-Q for the quarter ended June 30, 2012.

Conversely, if the filer, as of December 31, 2010, is a large accelerated filer with a public float over $5 billion on the last business day of its second quarter ended June 30, 2010, it will follow the submission requirements of Item 601(b)(101)(i)(A) of Regulation S-K and the detail tagging requirements of Rule 405(f)(1) of Regulation S T. Accordingly, the filer would be required to submit interactive data with its Form 10-K for the year ended December 31, 2010 and Forms 10-Q for the quarters ended March 31, June 30 and September 30, 2011 and to detail tag the financial statement footnotes and schedules in the interactive data it submits with all of these forms, even though the filer is in its first year of interactive data reporting. A filer that is required to begin detail tagging within its first year of interactive data reporting may apply for a continuing hardship exemption pursuant to Rule 202 of Regulation S-T if it cannot detail tag without undue burden or expense. Such applications will be considered on a case-by-case basis. [Sept. 17, 2010]

Question: In detail tagging financial statement footnotes and schedules in its interactive data file, a filer must, among other things, "block-text" tag "[e]ach significant accounting policy within the significant accounting policies footnote" under Rule 405(d)(2) of Regulation S-T. Must the filer also block-text tag significant accounting policies that are described in footnotes outside of a significant accounting policies footnote, either because the significant accounting policies footnote is not the only footnote that describes significant accounting policies or because there is no significant accounting policies footnote?

Answer: Yes. [Sept. 17, 2010]

Question: In detail tagging financial statement footnotes and schedules in its interactive data file, a filer must also, among other things, tag separately "[e]ach amount (i.e., monetary value, percentage, and number)" within each footnote and financial statement schedule under Rules 405(d)(4)(i) and 405(e)(2)(i), respectively, of Regulation S-T. Are there any monetary values, percentages or numbers in footnotes and financial statement schedules that do not need to be tagged separately?

Answer: Yes. Examples of the types of monetary values, percentages and numbers that the staff has agreed are not within the purpose of the current interactive data requirements and, as a result, need not be tagged separately to comply with Rules 405(d)(4)(i) and 405(e)(2)(i) include:

• attributed increased sales to the $1.99 pancake special (the increased sales figure itself would need to be tagged);
• sales of 1% fat milk (the sales figure itself would need to be tagged);
• docket number 34-4589;
• 22nd district court;
• FASB Accounting Standards Codification Section 605-40-15;
• altitude of 27,000 feet;
• drilling 700 feet;
• open new stores no less than 2 miles from existing stores;
• founded a new subsidiary in 2009;
• each restaurant now offers at least 20 entrees under 500 calories; and
• number of the footnote itself. [Sept. 17, 2010]

Question: Under Rule 405(a)(2) of Regulation S-T, a filer may submit its first Interactive Data File (or first Interactive Data File containing or required to contain, whichever first occurs, detail-tagged footnotes or schedules) within a 30-day grace period by amending the form to which the interactive data relates — for example, by filing a Form 10-Q amendment. Assuming the sole purpose of such amendment is to include the Interactive Data File as exhibit 101, what should the filer include in the amendment?

Answer: In the case of an amendment to a periodic report, the filer should include the cover page, an explanatory note, the signature page, an exhibit index, and exhibit 101. [May 29, 2009]

Question 130.02

Question: A filer submits its first Interactive Data File on a voluntary basis — that is, before it is required to do so pursuant to the phase-in schedule — and uses the 30-day grace period applicable to initial submissions under Rule 405(a)(2) of Regulation S-T. When the filer becomes required to submit Interactive Data Files pursuant to the phase-in schedule, may it avail itself of an initial submission 30-day grace period again for its first required Interactive Data File?

Answer: No. Each filer has only one initial submission 30-day grace period irrespective of whether that initial submission is made voluntarily (i.e., in advance of its scheduled phase-in) or as required (i.e., at its scheduled phase-in). Similarly, each filer has only one 30-day grace period for its initial detail-tagged footnote and schedule submission, whether submitted voluntarily or as required. [May 29, 2009]

Question 130.03

Question: If a filer submits its initial interactive data in advance of the phase-in schedule, can it wait to begin submitting its detail-tagged footnotes and schedules until it is required to do so under its scheduled phase-in?

Answer: Yes. Filers can also cease voluntary submissions of Interactive Data Files at any time until they are required to submit them pursuant to the phase-in schedule. [May 29, 2009]

Question 130.04

Question: Rule 405(d)(4)(i) of Regulation S-T states that each amount (i.e., monetary value, percentage and number) within each footnote must be tagged separately. Is an amount expressed as text (e.g., seven percent) required to be tagged under this provision?

Answer: Yes. Each amount, whether expressed numerically or textually, must be tagged separately under Rule 405(d)(4)(i). This guidance also applies to tagging each amount within the financial statement schedules under Rule 405(e)(2)(i) of Regulation S-T. Each tagged amount must be mapped to the applicable monetary, decimal, percent, integer or shares data type element. [May 29, 2009]

Question 130.05

Question: A filer's footnote states, "The assumed discount rate at December 31, 2008 is 7%." Can this fact be tagged as a string of text in satisfaction of Rule 405(d)(4)(i) of Regulation S-T?

Answer: No. Rule 405(d)(4)(i) of Regulation S-T requires that each amount be separately tagged. Each tagged amount must be mapped to the applicable monetary, decimal, percent, integer or shares data type element. Guidance on how to associate a specific date with an amount is provided under Chapter 6 of Volume II of the EDGAR Filer Manual. [May 29, 2009]

Question 130.06

Question: Rule 405(d)(4)(i) of Regulation S-T states that each amount (i.e., monetary value, percentage, and number) within each footnote must be tagged separately. How does this requirement apply when the numbers relate to periods or years, such as used in the following example? "Annual maturities of debt are: Year 1 (or 2010) is $1,000, Year 2 (or 2011) is $2,000, Year 3 (or 2012) is $3,000, Year 4 (or 2013) is $4,000, and Year 5 (or 2014) is $5,000."

Answer: In this example, the only amounts that should be tagged are the dollar amounts. The "year" references (i.e., Year 1, 2010, etc.) merely provide context to the dollar amounts. Examples of other disclosures in which this format may be common are future minimum lease payments and unconditional purchase obligations. The filer should carefully review the elements in the standard taxonomy because in some cases, the taxonomy will include separate elements for each specific period, and in other cases, the filer would use the same element from the taxonomy and distinguish each period by creating contextual information (see Section 6.5 of the EDGAR Filer Manual for guidance on defining contexts). [May 29, 2009]

Question 130.07

Question: Will the filer be permitted to include in interactive data format the auditor's report on the financial statements, or an assurance report on the interactive data voluntarily obtained from a third party, in its Interactive Data File submitted to the Commission?

Answer: No. Under Rule 405(b) of Regulation S-T, only the filer's financial statements, financial statement footnotes, and financial statement schedules are permitted to be included in the Interactive Data File submitted to the Commission. [May 29, 2009]

Question 130.08

Question: Must an Interactive Data File that complies with the requirements of Rule 405 of Regulation S-T appear identical to the traditional format financial statements when displayed by a viewer on the Commission's website?

Answer: No. There is no such requirement. [May 29, 2009]

Question 130.09

Question: A filer is required to post an interactive data file on the filer's web site, if it has one. The filer cannot comply with this requirement by providing a hyperlink on its web site to the Commission's web site. See Securities Act Release No. 9002 (Jan. 30, 2009). May the filer comply with this requirement by providing a hyperlink on its web site directly to the interactive data file, which is itself on a non-Commission third-party web site?

Answer: Yes, if the hyperlink goes directly to the interactive data file, the interactive data file is made available in the required time frame, and access to the interactive data file is free of charge to the user. [Sep. 14, 2009]

Question: How does a filer determine when it is required to submit interactive data and to "detail tag" the financial statement footnotes and schedules in its interactive data?

Answer: A filer first assesses its filing status at the end of each fiscal year (by looking to its public float as of the end of the most recently completed second quarter) and then follows the phase-in provisions for that status in the filings it makes during the immediately following fiscal year.

For example, as of December 31, 2009, a calendar-year domestic filer is a large accelerated filer with a public float under $5 billion on the last business day of its second quarter ended June 30, 2009. For purposes of its 2010 filings, the filer will follow the submission requirements of Item 601(b)(101)(i)(B) of Regulation S-K and the detail tagging requirements of Rule 405(f)(2) of Regulation S-T. Accordingly, the filer is required to submit interactive data with its Forms 10-Q for the quarters ended June 30 and September 30, 2010 but need not detail tag the financial statement footnotes and schedules until its Form 10-Q for the quarter ended June 30, 2011, assuming that, as of December 31, 2010, it is a large accelerated filer with a public float under $5 billion on the last business day of its second quarter ended June 30, 2010.

If the filer, as of December 31, 2010, is no longer a large accelerated filer, for purposes of its 2011 filings, it will follow the submission requirements of Item 601(b)(101)(i)(C) of Regulation S-K and the detail tagging requirements of Rule 405(f)(3) of Regulation S-T. Accordingly, the filer would not be required to submit interactive data with its Form 10-K for the year ended December 31, 2010 or Form 10-Q for the quarter ended March 31, 2011, but it would be required to submit interactive data with its Forms 10-Q for the quarters ended June 30 and September 30, 2011. The filer would not be required to detail tag the financial statement footnotes and schedules until its Form 10-Q for the quarter ended June 30, 2012.

Conversely, if the filer, as of December 31, 2010, is a large accelerated filer with a public float over $5 billion on the last business day of its second quarter ended June 30, 2010, it will follow the submission requirements of Item 601(b)(101)(i)(A) of Regulation S-K and the detail tagging requirements of Rule 405(f)(1) of Regulation S T. Accordingly, the filer would be required to submit interactive data with its Form 10-K for the year ended December 31, 2010 and Forms 10-Q for the quarters ended March 31, June 30 and September 30, 2011 and to detail tag the financial statement footnotes and schedules in the interactive data it submits with all of these forms, even though the filer is in its first year of interactive data reporting. A filer that is required to begin detail tagging within its first year of interactive data reporting may apply for a continuing hardship exemption pursuant to Rule 202 of Regulation S-T if it cannot detail tag without undue burden or expense. Such applications will be considered on a case-by-case basis. [Sept. 17, 2010] [Repeat of Question 146.14]

Question: If a filer voluntarily submits an interactive data file before it "first was required to submit" such file for purposes of Rule 406T(d) of Regulation S-T, does that voluntary submission start the rule's 24-month modified liability period?

Answer: No. [Sept. 17, 2010]