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Remarks to the IFRS Taxonomy Annual Convention 2012

Mike Starr

Deputy Chief Accountant
U.S. Securities and Exchange Commission

London, England

April 25, 2012

Thank you Olivier for that warm introduction. I appreciate you and Hans inviting me to participate in this, the 2012 IFRS Taxonomy Annual Convention.

Before I begin my remarks, I must remind you that the Securities and Exchange Commission, as a matter of policy, disclaims responsibility for any private publication or statement by any employee or Commissioner. Therefore, the views expressed today are my own, and do not necessarily reflect the views of the Commission, the Commissioners, or the other members of the staff of the Commission.

To appreciate how much has been accomplished in the last decade, we need to return to the beginning of the XBRL journey. The journey began in the late 1990’s with the development of a standard to define and exchange financial information. For the next few years, the focus, from my perspective, was on improving the taxonomy and promoting the case for the adoption of XBRL. In the beginning, there were just a few people who recognized the potential impact of this innovation – a disruptive innovation that would change the status quo and eventually could lead to the development of new businesses and new ways to produce, distribute and consume financial information. An innovation that eventually could give a new group of consumers easy access to financial information that was previously only accessible to consumers with a lot of money or skill.

Over the last decade, we have seen the widespread adoption of XBRL around the globe. On the European front, I was encouraged by Dr. Klinz’s remarks earlier today.

The SEC was one of the first regulators to mandate the use of XBRL. And today in the US, approximately 9,600 companies are filing XBRL formatted information with the SEC and those companies have reported over 18 million discrete financial facts in 35,000 filings.

Over the last three years, the companies filing with the SEC have made tremendous progress in implementing the XBRL mandate and, in the process, we have all learned a lot. In the past year, we have seen reports that there has been a tenfold increase in the number of companies bringing the tagging activity in-house and making this activity a part of the financial reporting process, not just a bolt on at the end to comply with the SEC mandate. In the past year, the extensions used in the core financial statements have fallen from 11% to 8% and for the detail tagging of the footnotes from 26% to 17%.

As the volume of US GAAP XBRL-formatted data has increased, use of the data has likewise increased. We have seen the development of new consumption tools and increased use by data aggregators, investors and other users of financial information. Investors are downloading the data from or they are using various open source data providers to analyze individual companies. We also know that investors are eager to expand their use of XBRL formatted data as more sophisticated software tools become available.

At the SEC, we use IDAP, a customized program to shred the XBRL formatted data and put it in a relational database and we use this database to analyze filings.

Indeed, there has been significant progress over the last decade. However, I believe that to reach the final destination of our XBRL journey, investors should be able to consume XBRL-formatted information using the same software application and process regardless of which XBRL financial reporting taxonomy is used and what the underlying content is. Today, that is not possible. Consequently, I believe it is imperative that future XBRL taxonomy development efforts give due consideration to the needs of investors.

There is one question that I know several of you have. It is a question that I have been asked every time I have given a speech on XBRL over the last year. When will the SEC approve an XBRL taxonomy for foreign private issuers? The short answer is we don’t know. There are taxonomy design differences between the US GAAP taxonomy and the IFRS taxonomy that prevent users from using the same application and process to consume data from either taxonomy.

However, I and I know others are committed to exploring a solution. I understand that the FASB and IFRS development teams are working collaboratively to that end. I want to emphasize that this is not a reflection on the quality of either taxonomy. The differences between the two taxonomies can represent different, but equally acceptable, technical design choices. Ultimately, design choices can be a delicate balancing act between the burden to the preparer to tag the information and the benefit to the investor derived from efficient access to the data.

In less than 15 years, this innovation has moved from a mere idea to widespread use around the world. While much has been accomplished, the journey is not complete, and the last leg of this journey is critical. We must not forget that the original objective was to develop a standard to define and exchange financial information and facilitate financial analysis. The driver for this development was the opportunity to provide investors timely access to financial information with enhanced transparency.

To reach the final destination of this journey, the XBRL community and policy makers must focus on the needs of investor and take actions so that all investors have the opportunity to easily access timely, transparent financial information regardless of which XBRL financial reporting taxonomy is used and what the underlying content is.

In closing, I want to acknowledge the efforts of Walter Hamscher, Susan Yount and Virginia Meany and publicly thank them for all that they done to implement the SEC’s XBRL mandate.

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