I’ve eagerly read the many comment letters from my peers in response to the SEC’s Concept Release on Regulation S-K. They’re filled with great feedback, new ideas and important concerns (you can read them here). But few responses have been as pointed as the one issued by the Data Coalition. Not only did the Coalition call on the SEC to commit to fully replacing the current system of plain text disclosures with open data (XBRL) — they called out the SEC for failing to respond effectively to the Coalition’s two previous and equally direct appeals on this matter.
You should know the Data Coalition
The Data Coalition, founded in 2012, is a trade association dedicated to the transformation of government information into standardized, open data. The Coalition’s founder, Hudson Hollister, brings valuable insider insight, having worked on Capitol Hill and as an attorney fellow in the SEC’s Office of Interactive Disclosure.
Coalition to SEC: You’re not listening
The Data Coalition summed up its letter in a recent blog post titled, Coalition to SEC: Replace Corporate Disclosure Documents with Open Data. “This is the Coalition’s third major appeal for the SEC to transform its disclosure system,” they said, reminding readers (and the SEC) that in March 2014, they submitted a detailed critique of the SEC’s Draft Strategic Plan for 2014-2018, and just last fall, they submitted a “road map for open data transformation” to help guide the SEC toward open data disclosures.
The future of disclosure is data, not documents
The Coalition extended a short olive branch by conceding that April’s concept release “shows that we’re making progress” in moving toward open data disclosures. But the Coalition challenged what it sees as the fundamental flaw in the concept release — the SEC’s continued assumption “that the future of corporate disclosure will be based on documents, not data.”
I share the Data Coalition’s view of the data-driven future of disclosures, and I’m happy to see the organization make a bold call for change. The SEC will weigh the response along with the multitude of other comments received, but here’s hoping the Coalition has the SEC’s full attention this time.