On December 13, the staff in the SEC’s Division of Risk, Strategy, and Financial Innovation published “Staff Observations From the Review of Interactive Data Financial Statements,” which summarizes its review of interactive data file (XBRL) submissions received during the second quarter of 2011. The review included (1) the first submissions of the third group phased-in under the SEC’s interactive data rules and (2) the first detailed-tagged submissions of the second phase-in group. The staff noted that “the filings continue to indicate that filers are devoting significant effort to understand their responsibilities under this program, comply with the new rules and provide high-quality submissions.” However, the staff still identified a number of areas for improvement, some of which had previously been noted in similar communications made earlier this year and in previous years.

Observations regarding the following topics were recurring: (1) format of the statements, (2) negative values, (3) extended elements, and (4) completeness of tagging. The staff also provided a new observation related to the interactive data requirements for registration statements:

Filers that are subject to the interactive data requirements must include XBRL with certain registration statements filed under the Securities Act of 1933 that physically, rather than through incorporation by reference, include financial statements once the registration statement contains a price or price range.

Registrants that fail to comply with this requirement will temporarily lose their short-form eligibility until the required interactive data files are both submitted to the SEC and posted to their corporate Web site (if any).