Written by Bob Schneider     Posted on August 22, 2008

As I mentioned in my post last week, Ed Hodder has done a nice job of summarizing the comments the SEC has received from public companies on the Interactive Data to Improve Financial Reporting rule.  He notes that companies (1) had reservations about the detailed tagging of notes, (2) would like more leniency on grace periods, and (3) would prefer that the first XBRL filing be a 10-Q (instead of the 10-K that the majority issuers would start with under the proposal). One item I would add to the list is that several companies requested that traditionally filed (ie, ASCII or HTML) statements continue to be accepted for the foreseeable future.

Besides the filing companies, comments were received from CPA and law firms, industry associations, software vendors, individuals, and a few other entities. As one can imagine, their remarks ran the gamut from “XBRL is the greatest thing since sliced bread” to “What in the world do we need this for?” A few comments were as short as one or two paragraphs, while United Technologies offered answers to all of the (apparently) 93 questions the Commission asked in the proposed rule.  Some comments merely note a meeting with a concerned party took place. (It was interesting to learn, however, that SEC representatives met with Interactive Data Corporation to discuss “some instances of public confusion” about the company’s name and the SEC’s XBRL initiative.)

As listed on the SEC’s website, the comments are (unhelpfully) sorted by date. To help readers review comments pertinent to their interests and needs, I have organized them into categories by respondent type (industry association, CPA firm, etc.) and alphabetized them. I show the number of pages in the comment in parentheses. I divided the companies into those whose support of the rule is total, or nearly so; those with some reservations, as noted above; and those who generally dislike the whole XBRL initiative. Comments for foreign filers are also listed separately.

Companies Whose Comments Are Overwhelmingly Positive
Peter A. Bridgman, PepsiCo, Inc. (1)

John E. Stantial, Assistant Controller, and Margaret Smyth, Vice President, Controller, United Technologies Corporation, Hartford, Connecticut (16)

Companies that Support the Rule with Various Caveats
Samuel H. Pilch, Group VP, Controller and Acting CFO, The Allstate Corporation (3)

Katherine A. O’Brien, First Vice President and Director of Financial Reporting, Astoria Financial Corporation (2)

Jonathan Chadwick, Senior Vice President, Corporate Controller and Principal Accounting Officer, Cisco Systems (3)

Lawrence J. Salva, Senior Vice President, Chief Accounting Officer and Controller, Comcast Corporation, Philadelphia, Pennsylvania (3)

Reese K. Feuerman, Vice President, Controller & CAO, Constellation Energy (4)

Rudolf Bless, Managing Director and Chief Accounting Officer, and Susan Carpenter, Vice President, External Reporting Team, Credit Suisse Group (20)

Harvey L. Wagner, Vice President, Controller and Chief Accounting Officer, FirstEnergy Corp. (3)

Richard O. Lund, Vice President, Controller, General Mills (2)

Gregg L. Nelson, Vice President, Accounting Policy & Financial Reporting, IBM Corporation (5)

James Campbell, Vice President, Corporate Controller, Intel Corporation (4)

Douglas K. Chia, Senior Counsel, Assistant Corporate Secretary, Johnson & Johnson (4)

Bernard G. Dvorak, Senior Vice President and Co-Chief Financial Officer, Liberty Global, Inc., Denver, Colorado (4)

Susan M. Kinsey, Assistant Treasurer, National City Corporation, Cleveland, Ohio
(5)

Loretta Cangialosi, Senior Vice President and Controller, Pfizer, Inc. (4)

William H. Hernandez, Senior Vice President, Finance, PPG Industries, Inc. (2)

David F. Bond, Senior Vice President, Finance and Control, Safeway Inc. (3)

W. Ron Hinson, Comptroller and Chief Accounting Officer, The Southern Company, Atlanta, Georgia (7)

Larry G. Schultz, Senior Vice President and Controller - United States Steel Corporation, Pittsburgh, Pennsylvania (4)

Companies Whose Comments Are Mostly Negative
Richard J. Schlueter, Vice President and Chief Accounting Officer, Emerson Electric Company (4)

K. Michael Davis, Controller and Chief Accounting Officer of FPL Group, Inc., and Vice President, Accounting and Chief Accounting Officer of Florida Power & Light Company (3)

Clayton E. Killinger, Senior Vice President and Controller, Valero Energy Corporation (4)

Wayne S. DeVeydt, Executive Vice President and Chief Financial Officer, WellPoint, Inc.
(3)

Individuals
James J. Angel, Ph.D., CFA, Associate Professor of Finance, Georgetown University (2)

Scott M Draeger (Product manager for Dialogue;1)

Robert Gilmore, CPA, Redondo Beach, California (5)

Glen L. Gray, PhD, CPA, Dept. of Accounting & Information Systems, College of Business & Economics, California State University, Northridge (1)

Walter C. Hamscher, Technology Standards Consultant, Standard Advantage; Member, XBRL International Board of Directors; Concord, Massachusetts (2)

Pete Haynsworth, Independent Business Analyst, East Greenwich, Rhode Island (3)

Gary Purnhagen, Principal, Gary Purnhagen Consulting (3)

Jay Starkman, CPA, Atlanta, Georgia (8)

Paul M. Vuksich, Esq., Public Company Attorney, San Francisco, California (1)

Industry Associations and Other Entities
John Endean, President, American Business Conference (4)

CFA Institute Centre for Financial Market Integrity (17)

Dennis A. Johnson, Senior Portfolio Manager, Corporate Governance, California Public Employees’ Retirement System (4)

Stephen F. Roth and Mary Jane Wilson-Bilik, Committee of Annuity Insurers (10)

Christopher Cole, Senior Regulatory Counsel, Independent Community Bankers of America, Washington, D.C.  (3)

Society of Corporate Secretaries and Governance Professionals (6)

David K. Owens, Executive Vice President, Business Operations, Edison Electric Institute (3)

Christine DiFabio, Vice President, Technical Activities, Financial Executives International; Arnold C. Hanish, Chair, Committee on Corporate Reporting, Financial Executives International; and Taylor Hawes, Chair, Committee on Finance & Information Technology, Financial Executives International (13)

Bill Nichols, Director, Securities Processing Automation, FISD, Washington, District of Columbia (1)

Michael P. Krzus, Partner, Grant Thornton LLP and President, The Enhanced Business Reporting Consortium, Chicago, Illinois (3)

Andrey Kuznetsov, Research Analyst, on behalf of the Council of Institutional Investors (3)

Karrie McMillan, General Counsel, Investment Company Institute (30)

Phillip L. Carson, Assistant General Counsel, American Council of Life Insurers (15)

Juliet Estridge, Executive Director, Morgan Stanley Research; Michelle Teitsch, Executive Director, Morgan Stanley Research; Monika Nica, Vice President, Morgan Stanley ModelWare Taxonomy; and Aditi Talreja, Morgan Stanley Research (2)

George L. Yungmann, Senior Vice President, Financial Standards, and Sally R. Glenn, Director, Financial Standards, National Association of Real Estate Investment Trusts
(4)

Comments Concerning Canadian and Foreign Companies
John Mania, Product Manager, and Melanie Kurzuk, Senior Vice President, CNW Group (3)

Jacques Schraven, Chairman, and Dorien M. Fransens, Secretary General, EuropeanIssuers, Brussels, Belgium (Represents public companies in Europe; 4)

Brian Grassby, Vice President and Controller, Canadian Pacific Railway (4)

Noriaki Shimazaki, Chairman, Sub-Committee on Accounting Nippon Keidanren (Japan Business Federation) (2)

Remco Steenbergen, Deputy Group Controller, Senior Vice President, Philips International B.V. (3)

Eyal Desheh, Chief Financial Officer, Teva Pharmaceutical Industries Limited, Israel (3)

Ziegler & Ziegler (2)

CPA Firms and Accounting Associations
Robert M. Tarola, Chair, AICPA Preparer Working Group, New York, New York (9)

BDO Seidman, LLP (3)

Cynthia M. Fornelli, Executive Director, Center for Audit Quality (6)

Deloitte & Touche LLP (7)

Ernst & Young LLP (8)

Grant Thornton, LLP (7)

John Hepp, CPA, Chair, Accounting Principles Committee, Illinois CPA Society (3)

Mick Homan, Chairman, Financial Reporting Committee, Institute of Management Accountants and Bruce Pounder, Chairman, Small Business Financial and Regulatory Affairs Committee, Institute of Management Accountants (5)

Klaus-Peter Feld, Executive Director, and Ulrich Schneiß, Director Auditing, Institut der Wirtschaftspruefer in Deutschland e.V. (Institute of Public Auditors in Germany, 4)

KPMG LLP (5)

Sharon Sabba Fierstein, President, New York State Society of CPAs (5 pages, 2 pages of text)

PricewaterhouseCoopers LLP (5)

Rob G. Bosman, Technical Director, Royal NIVRA (Netherlands accounting association; 4)

Law Firms and Law Associations
Norman D. Slonaker, Chair, Financial Reporting Committee, Association of the Bar of the City of New York (7)

Foley and Lardner, LLP (3)

Keith F. Higgins, Chair, Federal Regulation of Securities Committee, and Linda L. Griggs, Chair, Committee on Law and Accounting, Section of Business Law, American Bar Association (20)

Sullivan & Cromwell LLP (5)

Software Vendors and Financial Reporting Companies
Philip D. Moyer, CEO / President, EDGAR® Online, Inc. (12)

Andrew C. Neblett, Chief Executive Officer, EDGARfilings (2)

Michael L. Rohan, President, Rivet Software, Inc. (2)

Eric P. Linder, CFA CEO, SavaNet LLC (7)

Michael Makris, UBmatrix, Inc. (1)

Gordon Ruckdeschel, Vice President, Vintage Filings (1)

Comments that Merely Note a Meeting Took Place
Memorandum regarding a June 19, 2008, meeting with representatives of Clarity Systems (1)

Memorandum regarding a meeting with representatives of Dynaxys LLC (1)

Memorandum regarding a meeting with representatives of Interactive Data Corporation (1 page)

Memorandum regarding a July 30, 2008, meeting with representatives of Microsoft Corporation (1)

Memorandum regarding a May 21, 2008 meeting with Andrew Neblett, CEO of EDGARfilings (1)

Memorandum regarding a July 29, 2008, meeting with Deepta Rangarajan, Co-Founder, IRIS, in Maharashtra, India (1)

Memorandum regarding a meeting with representatives of XBRL US, Inc. (1)

Finally, note that the comments contain the Transcript of International Roundtable on Interactive Data for Public Financial Reporting Held on June 10, 2008. I haven’t looked through its 80 pages yet; but judging from the list of participants, I’m certain the record of this meeting of international regulators contains important insights.

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