SEC Adopts Rules Requiring Filing of Financial Statements in Interactive XBRL Format

February 19, 2009

The SEC recently published new rules that will require issuers reporting under U.S. GAAP or IFRS to provide their financial statements to the SEC in XBRL, an interactive data format. The final rules were adopted largely as originally proposed, with a handful of technical changes and one major adjustment -- the limitations on liability for errors in the XBRL file will be phased out completely after two years for each issuer and eliminated altogether in 2014.

The attached memorandum summarizes the new rules. It also discusses the liability standards that will apply to errors in the XBRL file and related due diligence implications for underwriters.

Questions regarding the new rules can be directed to your regular contacts at the firm or to any of the partners and counsel listed under Capital Markets on this website.