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Extensible Business Reporting Language Analysis

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Additionally, on March 1, 2017, the SEC voted to propose amendments relating to data submitted using eXtensible Business Reporting Language (“XBRL”), in connection with the SEC’s disclosure modernization initiative. In a Fact Sheet accompanying its announcement, the SEC indicated that the “proposed amendments would require the use of Inline XBRL format for the submission of operating company financial statement information and mutual fund risk/return summaries. The proposal would also eliminate the requirement for filers to post XBRL data on their websites.” The Fact Sheet indicates that the amendments would update SEC rules, adopted in 2009, requiring mutual funds to submit risk/return summaries in XBRL to the SEC in Interactive Data File …show more content…

It is possible that any new obligations and associated costs could be significant. On April 7, 2017 the DOL finalized a 60-day delay in the applicability date of the new fiduciary rule. On May 22, 2017 the DOL issued a New Temporary Enforcement Policy on the Fiduciary Rule, stating that “during the phased implementation period ending on January 1, 2018, the [DOL] will not pursue claims against fiduciaries who are working diligently and in good faith to comply with the fiduciary duty rule and exemptions, or treat those fiduciaries as being in violation of the fiduciary duty rule and the exemptions.” On June 9, 2017 compliance with the Fiduciary Rule was generally required. However, the day before, on June 8, 2017, the House of Representatives passed the Financial CHOICE Act, which includes a provision to rescind the Fiduciary Rule, this Act is still pending in the Senate, and analysts state that the Republicans will face a difficult task to gather enough votes to pass the legislation. On July 3, 2017, the DOL filed an amicus brief in a case challenging the fiduciary rule, in which the agency conceded that the portion of the BIC Exemption that would require providers to waive contractually the ability to insist on arbitration and to consent to being sued in a class action (in relevant part currently suspended) is invalid under other federal law. On August 31, 2017, the DOL published a proposal to delay (from January 1, 2018 to July 1, 2019) the applicability

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