On February 11, 2009, the SEC issued the final XBRL rule adopting amendments requiring mutual funds to provide risk/return summary information in a form that is intended to improve its usefulness to investors. Rules were also adopted permitting investment companies to submit portfolio holdings information in the interactive data voluntary program without being required to submit other financial information. The voluntary program begins July 15, 2009 and the compliance date is January 1, 2011.
| SUMMARY REQUIREMENTS - SEC XBRL FINAL RULE |
| Timing and Type of Submission |
- The Risk/Return Summary section of the Prospectus must be provided to the SEC in the XBRL interactive data format, as an exhibit to the registration statement, after, but within 15 days of, the effective date of the prospectus
- The XBRL document files as an exhibit to a Post Effective Amendment under rule 485b
- The Rule becomes effective for initial registration statements and updates to effective registration statements after January 1, 2011
- The XBRL document must also be available on the Fund’s web site on the day that the exhibit was submitted or was required to submit to the SEC
- If the file is not available or filed the fund will not be able to file post-effective amendments to the SEC under rule 485b until such time that the fund is compliant with filing and post to the website
- Voluntary program modified for participation until January 1, 2011 for Risk/Return but will continue for financial statements after that time
|
| Tagging Requirements for the Risk/Return Summary |
- The XBRL document must be created using the most recent list of XBRL tags released by XBRL US
- Liability Provisions:
- Subject to anti-fraud provisions of Section 17(a)(1) of the Securities Act, Section 10(b) of the Securities Exchange Act of 1934 and Section 206(1) of the Investment Advisers Act of 1940
- Deemed not filed or part of registration statement or prospectus for purposes of Section 11 or 12 of the Securities Act, is deemed not filed for purposes of Section 18 of the Exchange Act or Section 34(b) of the Investment Company Act and otherwise is not subject to liability under these sections
- Deemed filed for purposes of rule 103 of Regulation S-T
- Subject to liability for failure to comply with rule 405 of Regulation S-T; would not be liable if they make a good faith effort to comply and also promptly amend the interactive data rule to comply
- Liability provisions apply until October 31, 2014
- Can submit the portfolio of holding without submitting other financial statements in the voluntary program
- The SEC intends to monitor implementations and will make adjustments as needed
- New tags are available and the viewer will be updated to render the new data tags by mid-2009
- Will also be required to file an exhibit in XBRL for filing pursuant to Rule 497 when updates to the Risk/Return Summary section are made pin filing pursuant to this rule
|
|
| |
