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July 31, 2019

Inline XBRL Reminders for Large Accelerated Filers


Inline XBRL requires filers to embed XBRL data directly into an HTML document. As noted in our August 15, 2018 Advisory, operating companies and funds, on a phased-in basis, will be required to use Inline XBRL for the submission of financial statement and fund risk/return summary information, embedding a part of their interactive data file within an HTML document, and including the rest in a related exhibit.

For operating companies, the first phase-in period applies to large accelerated filers that prepare their financial statements in accordance with US GAAP, and commences with the first Form 10-Q for a fiscal period ending on or after June 15, 2019 (thus including 2019 second-quarter filings for large accelerated filers with a calendar year-end). The exhibit index of the filing must include the word "Inline" in the title description for any XBRL-related exhibit. In addition, and as noted in our April 4, 2019 Advisory, all of the information on the cover page of the Form 10-Q must be tagged using Inline XBRL, and the filing must include a "Cover Page Interactive Data File" containing cover page data. Note that the Form 10-Q cover page has recently been revised to include the title of each class of registered securities, each exchange on which such securities are registered, and the applicable trading symbol.

© Arnold & Porter Kaye Scholer LLP 2019 All Rights Reserved. This Advisory is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.