ARTICLE · 11 SEPTEMBER 2023

Corp Fin Posts Sample Comment Letter On XBRL

Cooley LLP

Explore more from Cooley LLP

Corp Fin has posted a sample comment letter to companies about their XBRL disclosures. I don't pretend to know or understand a thing about XBRL, much less Inline XBRL...

United StatesCorporate/Commercial Law

Author LinkedIn connections

Corp Fin has posted a sample comment letter to companies about their XBRL disclosures. I don't pretend to know or understand a thing about XBRL, much less Inline XBRL, so I won't even try to elaborate but, for your reading pleasure, here are the comments:

"Item 405 of Regulation S-T

Your filing does not include the required Inline XBRL presentation in accordance with Item 405 of Regulation S-T. Please file an amendment to the filing to include the required Inline XBRL presentation.

Cover Page

The common shares outstanding reported on the cover page and on your balance sheet are tagged with materially different values. It appears that you present the same data using different scales (presenting the whole amount in one instance and the same amount in thousands in the second). Please confirm that you will present the information consistently in future filings.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

[NCBFAA] President’s Update: Enforcement, CAPE Refunds & The 2027 Broker Deadline (Podcast)

United StatesCorporate/Commercial Law

Global Training Center

Phantom Income, Oppression, And Common-Law Dissolution

United StatesCorporate/Commercial Law

SEC Again Puts Disclosures In Focus As The Limits Of AI Bubble Are Tested

United StatesCorporate/Commercial Law

Buying The Black Box: How Dealmakers Can Diligence, Price, And Close AI Transactions

United StatesCorporate/Commercial Law

The New Washington Playbook: Oversight, Enforcement And Corporate Risk

United StatesCorporate/Commercial Law

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Corporate/Commercial Law
- Securities
- Corporate and Company Law

Related Comparative Guides

Comparative Guide

Private Equity

Comparative Guide

Venture Capital

Comparative Guide

Shareholder Activism

Comparative Guide

Technology M&A

See more popular content from

Corporate/Commercial Law

WilmerHale Careers: Diversity (Video)

We are committed to fostering an environment that embraces each individual's unique background, experience and perspective.

United StatesCorporate/Commercial Law

How to Run a Nonprofit Board that is Far from Boring

How do some nonprofit organizations develop and prosper, while others appear passive and static? Thriving and effective nonprofit boards share some important characteristics, which do not include "boring" board meetings.

United StatesCorporate/Commercial Law

Brown Smith Wallace

The Expanding Scope Of CFIUS's Jurisdiction And Mandatory Reporting

Since its establishment by executive order by President Ford in 1975, the Committee on Foreign Investments in the United States, popularly referred to as "CFIUS," has monitored national security...

United StatesCorporate/Commercial Law

Carter Ledyard & Milburn LLP

Healthcare Trends & Transactions Q2 2026

Healthcare M&A activity maintained steady momentum through Q2 2026, driven by physician practice consolidation, AI-enabled technology acquisitions, and strategic outpatient expansion. Private equity investment persisted despite intensifying regulatory scrutiny of MSO arrangements, while digital health buyers paid significant premiums for platforms demonstrating production-grade AI capabilities and proprietary data assets.

United StatesCorporate/Commercial Law

Bass, Berry & Sims PLC

SEC Moves To Open Private Markets To Retail Investors

On 30 September 2026, the SEC proposed rule amendments advancing Chairman Paul S. Atkins’ “responsible retailization” of private markets, expanding retail access to private-market strategies while adding key investor safeguards.

United StatesCorporate/Commercial Law

CLIENT ALERT: 2026 Mid-Year Update On SEC And CFTC Enforcement

The SEC and CFTC have fundamentally shifted their enforcement approach in 2026, moving away from high-volume technical violations toward targeted actions addressing serious fraud and market manipulation. This mid-year update examines new leadership priorities, enhanced inter-agency coordination, revised cooperation policies, the elimination of "no-deny" settlement provisions, and a landmark Supreme Court ruling on disgorgement that collectively reshape the regulatory landscape for market participants.

United StatesCorporate/Commercial Law

Delaware, Texas Step Up Unclaimed Property Enforcement

Delaware continues to issue verified report notices that can require companies to certify their unclaimed property reporting and provide supporting information within specified deadlines.

United StatesCorporate/Commercial Law

Predictions For 2025: The Evolving Landscape Of Debt Financing And M&A Activity

As we look ahead to 2025, the landscape of debt financing and M&A activity is poised for significant transformation.

United StatesCorporate/Commercial Law

Ropes & Gray LLP

SEC Considers Expansions To The Definition Of Accredited Investor

On September 30, 2026, the U.S. Securities and Exchange Commission (the “SEC”) published a series of notices[i] seeking public comment on significantly expanding the definition...

United StatesCorporate/Commercial Law

LLC Operating Agreements: The Complete Guide For Business Owners

What Every Owner Needs to Know Before Signing on the Dotted Line

United StatesCorporate/Commercial Law

Cantrell Law Firm