On January 30, 2009, the SEC issued Final Rule No. 33-9002, Interactive Data to Improve Financial Reporting, which will require public companies to use eXtensible Business Reporting Language (XBRL-tagged data) for the reporting of financial information. XBRL is a global standard that provides unique electronically readable codes (tags) for each item in the financial statements or other business report. Tagging can be thought of as placing a unique barcode on each item of information included in business reports so that XBRL-enabled software can search for a specified tag, recognize it, and retrieve it.
On April 28, 2009, the American Institute of Certified Public Accountants issued Statement of Position (SOP) 09-1, Performing Agreed-Upon Procedures Engagements That Address the Completeness, Accuracy, or Consistency of XBRL-Tagged Data, which was effective upon issuance. This SOP provides guidance on performing agreed-upon procedures engagements that address the completeness, accuracy, or consistency of an entity’s XBRL-tagged data of information as of a specified date and for a specified period. The objective of the engagement described in the SOP generally is to provide information to management or the audit committee of the entity about its XBRL-tagged data. The SOP includes guidance regarding:
- Management assertions
- Establishing an understanding with the client
- Nature, timing, and extent of procedures
- Involvement of a specialist
- Responsibilities and written representations of management
- Reporting considerations
- Illustrative management assertions
At this point, the SEC does not require the auditor to audit, attest to, or otherwise be involved with the submission of financial statements in XBRL. We do not believe it would be appropriate for our Firm to assist our SEC audit clients with services outside the scope of this SOP, such as the tagging of data or other preparation of financial statements in XBRL due to independence considerations. Our Firm can, however, perform agreed-upon procedures to address the completeness, accuracy, and consistency of XBRL-tagged data for an entity that either is, or is not, an SEC audit client.
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