On March 1, 2017, the SEC proposed the use of the Inline XBRL (eXtensible Business Reporting Language) format for the submission of operating company financial statement information and certain mutual fund information.  Inline XBRL allows filers to embed XBRL data directly into an HTML document.  With Inline XBRL, filers need to tag the required disclosures using the applicable taxonomy.  The tagging would be performed within the HTML document instead of a separate XBRL exhibit.  The objective of using Inline XBRL is to improve the data available to investors and other market participants.  The proposed Inline XBRL requirements for financial statement information would apply to all operating company filers, including smaller reporting companies, emerging growth companies, and foreign private issuers that are currently required to submit financial statement information in XBRL.  The proposed Inline XBRL requirements would be phased in based on the category of filer.

On March 1, 2017, the SEC also made IFRS taxonomy available.  As a result, foreign private issuers under Securities Act Rule 405 that prepare their financial statements in accordance with IFRS as issued by the IASB may begin submitting their financial data in XBRL format with their first annual report on Form 20-F or 40-F for fiscal periods ending on or after December 15, 2017.

For more information, see our client alert available at: https://media2.mofo.com/documents/170306-inline-xbrl.pdf.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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