With the last phase of implementation of interactive data rules fast approaching, the Director of the Division of Corporation Finance and the Chief Accountant of the U.S. Securities and Exchange Commission (the “SEC”) have provided foreign private issuers that prepare their financial statements in accordance with International Financial Reporting Standards (“IFRS”) as issued by the International Accounting Standards Board (the “IASB”) with relief from having to submit interactive data files to the SEC and post the interactive data files on their corporate websites. The relief is available until the SEC specifies a taxonomy for use by foreign private issuers that prepare their financial statements in accordance with IFRS as issued by the IASB.

In 2009, the SEC adopted rules requiring that public companies submit their financial statements, schedules and notes to the financial statements to the SEC in the form of interactive data, and post such interactive data on corporate websites. The interactive data must be “tagged” utilizing “XBRL,” which stands for eXtensible Business Reporting Language. The implementation of the interactive data filing requirements has been phased-in over a three-year period, with the last group of public companies required to submit and post interactive data files for fiscal periods ending after June 15, 2011. The phase-in began in 2009 with domestic and foreign large accelerated filers using U.S. GAAP that had a public float of at least $5 billion as of the end of the second quarter of the most recently completed fiscal year (approximately 500 companies), continued with all other domestic and foreign large accelerated filers using U.S. GAAP (approximately 1,500 companies) in 2010, and was anticipated to be completed this year with all remaining filers using U.S. GAAP and all foreign issuers that prepare financial statements using IFRS as issued by the IASB (approximately 8,500 companies in total).