Subject: File No. S7-03-17
From: Charles S Hoffman, CPA

May 14, 2017

Based on my testing and analysis of XBRL-based financial reports submitted to the SEC over the past five or so years it is clear that many public companies making decisions on how their XBRL is represented based on how the information is presented in renderings such as the SEC interactive data viewer.

Inline XBRL will, it seems, allow for information to be reported in both machine-readable format and human-readable format in one document. Further, because of the flexibility provided to creators of reports by the HTML presentation provided by Inline XBRL the probability that public companies will convey the meaning of information correctly using the XBRL format will likely increase.

What would help make the XBRL-based machine-readable information more useful would be for the SEC to require that the meaning conveyed by the XBRL-based information be audited just like the meaning conveyed by the human-readable HTML-based information is audited.

While it is true that independent auditors do not have the skills to audit the meaning conveyed by the XBRL-based information today phasing in the audit requirement over a period of several years would help motivate software companies to create and provide quality software which can be used effectively by auditors, would help motivate auditors to learn to audit the meaning conveyed by XBRL-based information, and would allow for a period to work through the details of properly conveying the meaning of reported financial information via the machine-readable XBRL format.

If the meaning conveyed by the XBRL-based information is not of high quality, then it really is simply a waste of time, money, and resources to require public companies to provide XBRL-based information.

I would strongly encourage the SEC to fix the obvious data quality problems of XBRL-based information directly. Inline XBRL will not directly contribute to increased quality.

But indirectly, Inline XBRL will contribute to better decisions related to the meaning conveyed by the machine-readable XBRL format.


Charles Hoffman, CPA