I am very proud of the vote I cast with Commissioner [Kara] Stein to propose this rulemaking last year while serving as Acting Chairman of the Commission.[1]  I am equally glad today to have the opportunity to see this important rulemaking finalized at my last open meeting as a Commissioner.

Machine-readable XBRL formatting facilitates creating and analyzing comprehensive datasets with state-of-the-art statistical methodologies.  While the technology of XBRL is a product of the twenty-first century, dispersing financial information ever more swiftly, widely, and cheaply is very much in keeping with the principles of the Commission's founding in the twentieth.  As the adopting release points out, today's action will benefit issuers, investors, analysts, and regulators in ways both great and small.  I would like to focus my remarks on the usefulness to academic researchers in my own profession.

As a financial economist, I have naturally followed the work of our Division of Economic and Risk Analysis ("DERA") with great interest over the course of my term.  Unlike most of our rulemakings, DERA had primary drafting responsibility for today's release and has done an admirable job.  While the release stands as a fine exemplar of the work DERA can do, I am even more excited to see the economic research—both here at the Commission and elsewhere in academia and the private sector—that will surely occur once inline XBRL has been universally adopted.

In my view, today's rulemaking will not add appreciably to the compliance burdens of our registrants.  As discussed in the release, the preliminary results of a pricing survey conducted by the AICPA and XBRL US indicate that the costs of XBRL formatting have declined 41% since 2014, with an average cost of $5,850 per year for small reporting companies in 2017.[2]  This is an encouraging trend, and I expect compliance costs to decline further as a result of today's elimination of the requirement that operating companies and funds post Interactive Data Files to their public websites.

I enthusiastically support the release.  Thank you.

 

[1] Acting Chairman Michael S. Piwowar, Opening Statement on Inline XBRL Filing of Tagged Data (Mar. 1, 2017), https://www.sec.gov/news/statement/opening-statement-on-inline-xbrl-filing-of-tagged-data.html.

[2] Letter of Campbell Pryde, President and CEO, XBRL US, Inc., to Rep. David Kustoff (Jun. 6, 2018), https://xbrl.us/wp-content/uploads/2018/06/XBRL-US-Letter-to-HFSC-RE-HR-5054-6-6-2018.pdf .