In an effort to facilitate “comparison shopping” by mutual fund investors, the Securities and Exchange Commission (the “Commission”) has adopted rule amendments requiring mutual funds to file risk/return summary information with the Commission using an interactive data format.1 With interactive data as a resource, the Commission believes investors will be able to compare and contrast funds efficiently and select a mutual fund that best matches their appetite for risk. The amendments call for mutual funds to file with the Commission risk/return summary information in XBRL (Extensible Business Reporting Language), an electronic format that enables web browsers and software applications to recognize and process “tagged” information.2 This information would be filed only as an exhibit to registration statements and thus would not impact the disclosure or format standards required for mutual fund prospectuses. (Fund prospectuses are already required to include a risk/return summary containing key information about the fund’s investment objectives and strategies, costs, risks and past performance.) Funds will also be required to post on their websites the interactive risk/ return summary data in XBRL format.3
The Commission anticipates investors using the XBRL data in different ways, such as for downloading cost and performance information directly into spreadsheets or incorporating the data into commercial software.4 This XBRL initiative follows other programs established by the Commission to transform and modernize information access for investors. For instance, on August 19, 2008, the Commission unveiled the Interactive Data Electronics Applications database (“IDEA”), an advanced information portal that allows investors to perform customized searches of fund information, and which supplements, and eventually will replace, the EDGAR system for electronic filing.5
It is important to note that, for the time being, the interactive data file generally will not be subject to liability under antifraud provisions of the federal securities laws, provided the fund makes a good faith attempt to comply with the data submission requirements (i.e., tagging and formatting the data as required by the rule).6 However, after October 31, 2014, this liability exception would cease to apply and the interactive data file will be subject to the same liability provisions as the underlying filing.7
The first required submissions of XBRL data are in connection with registration statements that become effective after January 1, 2011.8 The full text of the Adopting Release is available at http://www.sec.gov/rules/final/2009/33-9006.pdf.