XBRL US Comments on SEC Proposal on Filing Fee Disclosure and Payment Methods Modernization
By Toppan Merrill
1 min read | Industry Insights Insights Home

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Last week, XBRL US submitted a comment letter weighing in on the SEC proposal that fees and calculation tables in fee-based tables be prepared in Inline XBRL format. XBRL US supports the proposal and agrees with the Commission that structuring fee data will improve the efficiencies of the fee validation process for SEC staff, and will increase the confidence of registrants in the accuracy of their calculated filing fee.

Thanks goes to the work of an XBRL US member working group, including Toppan Merrill team members, Chase Bongirno and Jen Froberg, who helped identify and prepare detailed recommendations that will help the Commission as they work to finalize the rule.

In addition to questions about various aspects of the proposal, the SEC also asked if a pilot or test period would be advisable. We supported the idea of a pilot as a good means to identify and resolve issues that may arise during implementation.

Read the rule: https://www.sec.gov/rules/proposed/2019/33-10720.pdf

Read the XBRL US letter: https://xbrl.us/wp-content/uploads/2019/12/XBRL-US-Comment-RE-SEC-File-Number-S7-20-19-Fee-Based-Filings.pdf

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Toppan Merrill


Toppan Merrill, a leader in financial printing and communication solutions, is part of the Toppan Printing Co., Ltd., the world's leading printing group, headquartered in Tokyo with approximately US$14 billion in annual sales. Toppan Merrill has been a pioneer and trusted partner to the financial, legal and corporate communities for five decades, providing secure, innovative solutions to complex content and communications requirements. Through proactive partnerships, unparalleled expertise, continuous innovation and unmatched service, Toppan Merrill delivers a hassle-free experience for mission-critical content for capital markets transactions, financial reporting and regulatory disclosure filings, and marketing and communications solutions for regulated and non-regulated industries. With global expertise in major capital markets, Toppan Merrill delivers unmatched service around the world.


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