The New York State Society of CPAs submitted comments to the Securities and Exchange Commission on the proposed requirement for filing financial statements in Extensible Business Reporting Language, saying it makes sense for the 500 largest companies to file in XBRL by the end of the year, but that smaller companies should not be held to any deadline just yet.

The SEC recently proposed that about 500 of the largest public companies with a worldwide float of over $5 billion should begin filing in the interactive data format for fiscal periods ending in late 2008 (see SEC Votes for Mandatory XBRL Filing).

"We agree that the 500 largest filers who are required to provide interactive data for filings on or after Dec. 15, 2008, should be able to do so, especially given the proposed 30-day grace period," said a letter from the NYSSCPA. "Generally, such filers have large and sophisticated staffs to deal effectively with XBRL.

"We are concerned, however, about the capabilities of the staffs of other, smaller filers to deal with the XBRL requirements," the NYSSCPA leadership added. "We encourage the commission to monitor the initial filing process for the largest filers to identify any problems and concerns that may indicate that either the Dec. 15, 2009 or 2010, deadlines may not be realistic."

The NYSSCPA encouraged the SEC to hold roundtable discussions or interviews of the initial filers to gain insights that would be useful to smaller filers to help them get up to speed with XBRL. It said that small filers with less than a combined $50 million in public float and public debt outstanding should be able to opt out of the requirement for providing interactive data for the time being.

"We do not believe that there is a sufficient amount of analyst interest in these small filers to justify the additional cost to the companies of providing the data in XBRL," said the NYSSCPA. "However, if any such filer wished to provide XBRL data, it should be permitted to do so."

The NYSSCPA said the SEC should monitor whether a market develops for software and third-party services to help small filers, and if there is adequate assistance available to smaller filers at a reasonable cost when the deadlines approach. If adequate help does not become available, suggested the NYSCCPA, the commission should reconsider the deadlines for smaller filers.

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