Our colleagues at XBRL US have responded to the Securities and Exchange Commission (SEC) consultation on disclosure requirements for credit ratings agencies, or Nationally Recognized Statistical Rating Organizations (NRSROs). They support the continuing use of XBRL for reporting ratings data, and they also make some interesting further recommendations to make reporting more efficient, reduce burdens on filers, and increase the value of the data gathered.
One of these recommendations is for credit ratings agencies to use the new xBRL-CSV specification. This is a very efficient way for regulators to handle large volumes of information, and XBRL US believes it would produce data that is easier to access and use, as well as facilitating preparation. Another proposal to aid data consumption is for it to be submitted directly to SEC’s one-stop EDGAR system instead of posted to the NRSRO website. XBRL US also suggests reducing the delay on making the XBRL-formatted data, machine-readable data available to the public, to increase the timeliness and therefore value of this information and encourage its use.
Updating the taxonomy to include the Legal Entity Identifier (LEI) and the Financial Instrument Global Identifier (FIGI) would encourage the use of these non-proprietary identifiers and reduce costs for issuers and data users. And on a technical note, XBRL US recommends replacing tuples for dimensions to describe the data, because the XBRL dimensions specification is more widely used.
Smart, common-sense proposals, we think – that may apply to other regulators too.