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The Preparer’s Perspective of XBRL
Conference: Citigroup 16th Annual Entertainment, Media and Telecommunications Conference Date: Monday, January 9, 2006 Speaker: Brian L. Roberts Location: Arizona Biltmore Resort & Spa Time: 12:30- 1:15PM (45 minutes) Lunch Presentation Presentation will be Webcast on No press on-site (many listen to webcast) Business Wire Webinar November 20, 2008 NEXT SLIDE Safe Harbor
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Agenda XBRL @ 100,000 Feet Comcast’s Experience
History Process Cost and Time Estimates The Preparer’s View Point SEC Comment Letters – Common Themes Preparation – In-house vs. Outsourcing Investor Relations Responsibilities
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XBRL @ 100,000 Feet Taxonomy Extensions Tagging / Mark-up
Element = Label + Definition Linkbase (Calculation & Presentation) Extensions Tagging / Mark-up
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XBRL @ 100,000 Feet Excerpt of 3rd 2006 Quarter 10Q:
(Dollars in millions, except share data) September 30, 2006 December 31, 2005 ASSETS Current Assets Cash and cash equivalents $ 2,774 693 Scenario: Unaudited Precision: Digits as Shown Scale: In Millions Element: Cash & Cash Equivalents Numeric Unit: $ - US Dollars Date: As of 9/30/06 <usfr-pte:CashCashEquivalents contextRef="BalanceAsOf_30Sep2006_Unaudited" unitRef="USD" decimals="INF"> </usfr-pte:CashCashEquivalents>
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XBRL @ 100,000 Feet Taxonomy Extensions Tagging / Mark-up
Element = Label + Definition Linkbase (Calculation & Presentation) Extensions Tagging / Mark-up Instance Documents
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Similar to what HTML is to the Internet…
100,000 Feet Similar to what HTML is to the Internet…
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…XBRL is to financial reporting
100,000 Feet …XBRL is to financial reporting
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XBRL @ 100,000 Feet Taxonomy Extensions Tagging / Mark-up
Element = Label + Definition Linkbase (Calculation & Presentation) Extensions Tagging / Mark-up Instance Documents Voluntary Filer Program vs. Pending Mandate Bolt-on vs. Integrated Process
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Comcast’s Experience History:
Summer 2006 – Educated ourselves and investigated software and 3rd party solutions Fall 2006 – Selected software vendor and prepared initial filings Dec 2006 – Educated Audit Committee & made initial filings Mar 2007 – Filed K in XBRL May 2007 – Transitioned responsibility to the Financial Reporting Team Jun 2007 – Filed 1Q07 10-Q in XBRL Sep 2007 – Filed 2Q07 10-Q in XBRL Nov 2007 – Filed 3Q07 10-Q in XBRL Apr 2008 – Filed K in XBRL May 2008 – Filed 1Q08 10-Q in XBRL Fall Re-evaluate Software & Process
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Comcast’s Experience Process:
“Tagging” is Performed Using Rivet Software Assistance Provided by Rivet Software as Needed 8-K is Prepared Review Checklist Completed (PCAOB Q&A) XBRL Committee Review 8-K Reviewed by Legal Counsel Documents are Validated and Filed by RR Donnelley
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Comcast’s Experience Cost and Time Estimates: Comcast –VFP
SEC – Mandate Comcast - Mandate Research, Education, & Training 120 Hours N/A First Filing – VFP 60 Hours Subsequent Filings – VFP 22 Hours First Filing – Year 1 of Mandate 133 Hours & $41K Subsequent Filings – Year 1 of Mandate 25 Hours & $13K 25 Hours First Filing – Year 2 of Mandate 127 Hours & $39K 150 – 300 Hours Subsequent Filings – Year 2 of Mandate 72 Hours & $25K ???
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The Preparer’s View Point
SEC Comment Letters – Common Themes: Major Concerns Other Concerns Vendor readiness Detailed Tagging of Footnotes Implementation Timing Grace Periods Form of Submission IFRS Liability Auditor Involvement
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The Preparer’s Viewpoint
Preparation – In-house vs Outsourcing: In-house Solutions Outsourcing Solutions Why? Greater Control Greater Understanding of XBRL Technical Support Experience Consolidation of Service Why Not? Time Constraints Resource Constraints Lack of Expertise Conflicting Priorities Availability of Resources
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The Preparer’s View Point
Investor Relations Considerations: Website Posting Requirements Increased Coverage for Small Companies Expect Questions Industry Standards Regarding Extensions The Future – MD&A and Earnings Releases
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Phillip J. Gaudreau Comcast Corporation (215)
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