XBRL Voluntary Program on the EDGAR System April 2005 Brigitte Lippmann Attorney Division of Corporation Finance Jeffrey Naumann Enabling Technologies Specialist Office of the Chief Accountant

Disclaimer The Securities and Exchange Commission, as a matter of policy, disclaims responsibility for any private publication or statement by any of its employees. Therefore, the views expressed today are our own, and do not necessarily reflect the views of the Commission or the other members of the staff of the Commission.

Interest in Assessing XBRL  Our mission:  Protect investors and maintain the integrity of the securities markets  Potential Impact of Tagged Data and XBRL  Internal -  Screening / Risk Assessment  Financial statement reviews  External -  Better and faster investor access to financial information  Improved analysis for investors

Voluntary Program - Objectives  To investigate the use of XBRL in the marketplace today including:  Maturity and capabilities of the XBRL standard  Maturity of taxonomies  Software available for data tagging, and consumption & analysis of XBRL data  Depth of data tagged  Level of effort to tag data in XBRL format  Usefulness of tagged data for Commission processes  Suitability of XBRL data for investor analysis & review

Voluntary Program Assessment XBRL Voluntary Program - Status Establish Task Force Decide Next Steps Concept Release & Proposed Rule Comment Period Preliminary Assessment / Press Release Final Rule Amendment s XBRL Voluntary Program Effective Date First Submissions of XBRL Documents Assess / Decide July ‘04 Sept ‘04 Feb ‘05 March ‘05 April ‘05

Final SEC Rules Amendments to Regulation S-T establish voluntary program EDGAR Filer Manual was updated for XBRL upgrade to EDGAR system Rules were effective March 16, 2005 Volunteers may furnish supplemental financial information using XBRL Official html or text filings still required

Form of Submissions XBRL documents are furnished as Exhibit 100 to: Exchange Act periodic reports Exchange Act Reports on Forms 8-K or 6-K Investment Company Act filings XBRL documents are disseminated on EDGAR

Timing of XBRL Submissions  Must be furnished no earlier than related official html or text filing  May be furnished:  with the related official filing  after the related official filing either by:  an amendment to official filing or  a Form 8-K or 6-K  No deadline – but we encourage volunteers to submit with official filing or shortly thereafter  Free to start or stop anytime

Description of XBRL Data Volunteers must provide disclosures about the XBRL documents:  Provide cautionary language  Describe as “unaudited” or “unreviewed”  Forms 8-K and 6-K must reference the official filing to which the data relates

Content of XBRL Documents Mandatory Content: Complete set of financial statements, however: Notes to financial statements may be omitted, Schedules may be omitted, but IM companies must include Schedule I – Schedule of Investments or Earnings information in a Form 8-K or 6-K or Financial highlights or condensed financial information for IM companies

Content (continued) Optional Content: Audit opinion Interim review reports Reports of management on the financial statements Certifications MD&A (or MDFP for IM companies)

Format of XBRL Documents  Each data element must reflect the same information in the related official filing  text  line item names  associated values  dates  other labels  No data element in the related official filing can be changed, deleted or summarized

Format (continued)  XBRL documents must correlate to the appropriate taxonomy (extensions are allowed):  Commercial and industrial  Banking and savings institutions  Insurance  Investment companies  Each data element must be matched with appropriate tag in the taxonomy (e.g., $100 million in revenues must be tagged as to correlate to official filing)  XBRL documents may contain mark-up related content not found in official filing to comply with the XBRL specifications and EDGAR Filer Manual requirements (e.g., )

Liability XBRL documents are “furnished” not “filed” Not deemed filed under Section 18 of the Exchange Act or Section 34(b) of the Investment Company Act Rule 10b-5 still applies

How you can help our assessment  Participate in the Voluntary Program  Submit XBRL Documents as part of the program  Provide support to registrants (software, services, etc.)  Evaluate XBRL  XBRL Specification & Features  Standard Taxonomies  XBRL-enabled Software  XBRL Documents submitted in voluntary program

How you can help our assessment  Provide Feedback  Participant Feedback  Process for creating and submitting XBRL  Level of effort  Issues with voluntary program rules  General Feedback  Issues faced working with the XBRL Specification  Suggested enhancements to XBRL-enabled software  Improvements and enhancements to the standard taxonomies

Where to get more information  SEC XBRL Spotlight Page:   Final Rule Release Establishing XBRL Program:   EDGARLink Filer Manual   Frequently Asked Questions About the XBRL Program 

Contact us  Brigitte Lippmann, Jeff Naumann or any of the other names listed on the final rule release  For general inquiries, us at