XBRL for Mutual Funds – Filing and Publishing Considerations

We are 59 days away from the effective date of the XBRL ruling – requiring all open-end mutual funds to file the Risk/Return Summary section in XBRL format as an exhibit, as well as publish the XBRL files to the fund’s website (when one exists).

This week, we will continue our discussion of the functional steps of XBRL by covering the filing and publishing steps. With so much focus on the mechanics of 'tagging' the data in XBRL, filing and publishing seem to be after-thoughts when in fact they are where the “rubber meets the road.” Remember, until you file or publish your XBRL-tagged data, it does not exist to the SEC. So, this article will focus on these important final steps in the process.

In the end, the XBRL data needs to be filed and published to your fund’s website on the “same day.” If you have multiple funds filing and publishing on or around the same day, then it will be critical to have a structured, systematic process for both of these steps. A reputable vendor who offers XBRL tagging-filing-publishing services must be structured to scale and support many funds on any given day. When considering a vendor, you should carefully discuss each step in the process as well as the hand-off between each of the steps to ensure that the “same day” aspect of the ruling can be met. Look for manual steps in the process or hand-off as they will slow the process and introduce risk.

For example, at Merrill Corp, we simply modified our existing, time-proven process for filing EDGAR to fit the specific requirements for XBRL.

For publishing, we followed a similar approach as we used for tagging. To ensure that the published data is identical to the filed data – we, again pull it from the SEC. We call the data that is filed, accepted and stored by the SEC  “golden data.” By pulling the golden data, we ensure that any last second changes to the XBRL data that was filed is included in the published data, too.

Now, the Interactive Data ruling requires only the XBRL-tagged data is to be published to the fund’s website. Here’s an example of XBRL-tagged data that your investors would see if they opened up that file:

As you and I know (and we have mentioned in previous blog posts), this data is not intended for humans to read. However, how you plan to convey this information to your investors is important. The XBRL Complete product has responded with three different publishing options to fit how you want to publish and share this information with your investors. We will explain these three options in our next post.

As always, our overall message is that the time to prepare is now. Don’t be caught off guard and start the on-boarding process approximately 30-45 days before the beginning of the year. This will allow you to understand your tagging and publishing needs well in advance to make the proper business decision. Being prepared is the key to a successful transition to XBRL.

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Merrill Corporation is proud to offer XBRL Complete, a suite of services that meets - and has options to exceed – the mandated requirements for XBRL for mutual funds. For more information, please click here or call 866-367-9110.