Note: This article has been referenced at Hitachi Data Interactive, a fantastic review of current topics in XBRL. Check it out, here:
As Phil Mennona, Charlie Hoffman, Compliance Week, and the SEC themselves noted; the SEC has come out with a new (XBRL) Taxonomy. The Taxonomy is for Form SD. This Form is a disclosure of certain
Blood Diamond Conflict Mineral* information… and I have a few brief observations.
Firstly: it’s telling that conflicts in the DRC – the Democratic Republic of Congo – have had as far-reaching an impact as SEC Disclosure Requirements… in the form of XBRL, no less!
Secondly: SEC press release does a great job of outlining the disclosure requirements in “Who, What, When, How” form. So “What” must be disclosed? Payments…
- Made to further the commercial development of oil, natural gas, or minerals.
- “not de minimis”
- Within the types of payments specified in the rules.
Well, we won’t get into the rules here. We’d rather get into the schema! The 2013 draft is indexed here, with the full entry point available here. I viewed it with Arelle, and here are the rest of my observations:
- (Noted by Phil Mennona): they define a new yesItemType
- Is that really necessary? It is used on the element “K“; to tag in-kind payments, as described in the rule here.
- The element’s Documentation says: “Y or Yes to indicate an in-kind payment.“
- It seems like a boolean should suffice. Or if the distinction between Cash and In-Kind (mutually exclusive set?) is important, maybe a Member.
- (Noted by Phil Mennona): they use QNameItemType for element’s like “Pr”
- When would a business user want to express/tag a value of the “QName” type?
- We remembered that the <xbrli:measure> element is a QNameItemType, because it should tag strings like iso4217:USD.
- In that context, the prefix identifies the authority, and the localName identifies the thing itself
- I suppose the filing company will be the “authority” or “owner” of the project; the prefix will be their taxonomy prefix.
- But for the “Pr” element, there is a separate “ProjectAxis”
- And for the “Gv” element, there is a separate “GovernmentAxis”
- Presumably, the project, like nateCompany:TantalumMiningProject, will be defined as a Member in the “ProjectsAxis”
- Then will it also be tagged with the element? And wouldn’t that be redundant?
- Finally, what are “L001_Member“, “L002_Member“, all about?
- These are part of the LineAxis,
- Their Standard Labels are “1“, “2“, etc
- So they must represents lines like those in a form; like those on IRS forms, or FDIC forms.
- It reminds me of the FDIC taxonomy, which has an abstract called “Lines”, and elements corresponding to fields in its RI and RC reports
- Is this a good approach? Is a Line number important information? Well, I suppose it could be!
- (I think it’s more appropriate as a Member; [I might say “secondary/contextual” information], rather than an Element [which I’d call “primary/conceptual” information]
I submitted a comment letter to the OID. Do you have insight into any of the above? I’d love to hear from you!
*I don’t mean to make light of the situation. In fact I think the term has some poetic irony; it reminded me of the term “Blood Diamond”. The circumstances are similar. The term “conflict minerals” refers to tantalum, tin, gold or tungsten, (often referred to as “the 3T’s and G”) mined from the Congo and adjacent countries, in “conditions of armed conflict and human rights abuses“ All of these metals are used in modern-day electronics, in some form or another; in service of technology. And now, technology like XBRL, will be in service of this metal trade. I hope the benefit (to business, to environment, to human life and dignity) is worth any additional cost! Maybe a followup post on the politics behind all this… I’d love to hear any insight about that, too!