1. Tagged Data Initiative (XBRL) Brigitte Lippmann Attorney Division of Corporation Finance Eric J. Schuppenhauer Senior Advisor to the Chief Accountant Office of the Chief Accountant

2. 2 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. Disclaimer

3. 3 Goals v To enable better dissemination of financial information. v To improve financial analysis for investors. v To improve the staff’s ability to review filings on a more timely and efficient basis.

4. 4 Enablers are Key v Investigating technology and other tools that enable further improvements to the financial reporting model and to Commission processes is essential. v Data tagging, using technological advances such as eXtensible Business Reporting Language (XBRL), may be a meaningful step toward achieving these improvements.

5. 5 Where Are We Today? v Electronic Data Gathering Analysis and Retrieval System (EDGAR) u ASCII or HTML u Tagging of high-level document sections u Not easily searchable v Review of registrant filings is largely a manual exercise using text-based information v Investor community must re-key data or purchase third-party data for financial analytics

6. 6 Where Are We Today? v Sarbanes-Oxley requirement to review registrants at least every three years. v Currently, about 13,000+ registrants fall into the population subject to review every three years. v Staffing increases are underway, but we wish to provide tools to make reviews faster, better and cheaper.

7. 7 Process for Investigating Data Tagging Establish Task Force Decide Next Steps Voluntary Program Analysis Concept Release / Proposed Rule Preliminary Investigation / Press Release Investigate / Decide

8. 8 Concept Release Overview v Concept Release can be accessed on the SEC website at www.sec.gov/rules/concept/33-8497.htm v Concept Release explores broad areas being considered by the Commission to improve financial information. v The Release provides an avenue for the public to provide their insight on: u Tagging - generally u XBRL - more specifically

9. 9 Concept Release Focus Areas v The Concept Release is organized as follows: u Overview u Tagged Data as Part of Our Initiative to Improve Analysis and Disclosure u XBRL and Tagged Data u Information For and Filing of Tagged Data u Impact on Various Parties v Comment Period Ended Yesterday, November 15 th

10. 10 Proposed Rule Overview v Concurrently issued a Proposed Rule to establish a Voluntary Program to allow Registrants to furnish XBRL information on a supplemental basis using the EDGAR system. The Proposed Rule can be accessed on the SEC website at - http://www.sec.gov/rules/proposed/33- 8496.htm

11. 11 Proposed Rule - Purpose v To investigate the use of XBRL in the marketplace today including: u Test technology features u Software available for data tagging u Maturity of taxonomies u Depth of data tagged u Level of effort to tag data in XBRL format u Usefulness of tagged data for Commission and investor analysis/review

12. 12 Proposed Rule Summary of Key Provisions v The Program is Voluntary. v Open to All Registrants for purposed of 34 Act and 40 Act Filings u Corporate u Investment Companies u Foreign private issuers, if using US GAAP v Hope to provide a standard style sheet to render the XBRL data v Anticipate program will be available for the 2004 calendar year reporting season v No end date proposed for the voluntary program

13. 13 Proposed Rule Summary of Key Provisions v Participants must use the standard US GAAP taxonomies developed by XBRL-US for XBRL Specification 2.1 v XBRL data is supplemental and must present the same information contained in official filings v Participants will likely need to extend from the standard taxonomies v Participants are encouraged to contact one of the individuals listed in the proposed rule if they are interested in participating

14. 14 Proposed Rule Steps to Encourage Participation v We have attempted to encourage participation in the program u Ability to furnish information using Form 8-K u Limited liability relief for XBRL exhibits u Ability to tag only specified parts of the disclosure document u Ability to start and stop v Comment Period ended November 1 st