February 10, 2007
This proprosed program is a very good idea and an excellent way to test XBRL. I would strongly encourage the commission to consider imposing validity testing above and beyond the current voluantary filing program in order to improve the quality (or rather ensure high quality) XBRL instance documents are submitted.
Even requiring submissions to be compliant to XBRL International's FRIS (Financial Reporting Instance Standards) which is currently a public working draft would significanlty help. In fact, it would be significanlty better to be MORE restrictive now that the SEC migh be later. This will help the SEC understand better understand any additional characteristics an XBRL instance document should have, above and beyond FRIS.
The ramifications of not addressing certain issues relating to instance documents and the data they contain will be reduced quality of instance documents, poor comparability, and other usability issues.
If additional information is needed regarding this suggestion, please feel free to contact me and I can elaborate further.
Regards,
Charles Hoffman, CPA