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February 16, 2024

Exhibits: SEC Offers Guidance on Preparing iXBRL Fee Exhibits

On January 29th, the voluntary compliance period under the SEC’s Filing Fee Modernization Rule began and filers became eligible to voluntarily file fee data in Inline XBRL format. Yesterday, the SEC announced that it had posted “How do I” guidance on preparing iXBRL fee exhibits.  If you’re not feeling particularly motivated to click through to the SEC’s website this morning, here’s the guidance in its entirety:

Filers can prepare an Inline XBRL filing fee exhibit (EX-FILING FEES) and submit it to EDGAR for processing with an option to construct structured filing fee information within EDGAR using the Fee Exhibit Preparation Tool (FEPT).

Filers using the FEPT to prepare an Inline XBRL Filing Fee exhibit as part of EDGAR Link Online (ELO) should refer to the EDGAR Filing Fee Interface Courtesy Guide (PDF, 1.2 mb). FEPT includes features such as prompts, explanations, and automated calculations to produce a filing fee exhibit in submission-ready format. Filers using FEPT to construct the EX-FILING FEES in EDGAR generally will receive error and warning messages before they submit both test and live filings.

Filers using XBRL should refer to the EDGAR XBRL Guide (Filing Fee Extract) (PDF, 0.5 mb). Constructing the Filing Fee Exhibit outside of FEPT, however, will provide filers with error and warning messages after they submit both test and live filings.

EDGAR will validate the Inline XBRL fee data submission and generally will issue warnings for any validation failures caused by incorrect or incomplete structured filing fee-related information until an announced date of approximately November 1, 2025, when it will suspend filings rather than issue warnings.

Note that accelerated filers will be required to submit fee data in iXBRL beginning on July 24,2024 and all other filers will be required to do so on July 24, 2025.

John Jenkins