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  The SEC is hosting a roundtable on the 21st Century Disclosure Initiative tomorrow… bring it on!

I have one word for the Commission… murky… the markets are MURKY… more disclosure is needed…

Go ahead overshoot… swing the pendulum really far in the other direction… here are my recommendations… (which I’ve forwarded to the SEC…)

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The IDEA Disclosure initiative organizes data around interactive “company files”. This will be very useful for retail investors and data vendors.

We would support additional data from filing companies related to:

1. Securities outstanding
2. Exchanges, ATS, ECN or OTC markets on which the filing company has securities
3. NRSRO ratings if the filing company pays the rating agency

The Commission could go a long way in creating transparency for retail investors and financial markets by requiring reporting companies to file a list of the various securities (either cash or derivative) that are issued, outstanding or based on assets or liabilities of the reporting company.

For example Sears Holding Corporation would list, in XBRL format, all domestic equity, option, future, convertible bond, preferred stock, fixed income, and CDS trading symbols or other identifier. This data would be incorporated in the master “company file”.

This information is already required by the ’34 Exchange Act in Section 12-b-1B:

b. Procedure for registration; information

A security may be registered on a national securities exchange by the issuer filing an application with the exchange (and filing with the Commission such duplicate originals thereof as the Commission may require), which application shall contain–

1. Such information, in such detail, as to the issuer and any person directly or indirectly controlling or controlled by, or under direct or indirect common control with, the issuer, and any guarantor of the security as to principal or interest or both, as the Commission may by rules and regulations require, as necessary or appropriate in the public interest or for the protection of investors, in respect of the following:
   1. the organization, financial structure, and nature of the business;
   2. the terms, position, rights, and privileges of the different classes of securities outstanding;
   3. the terms on which their securities are to be, and during the preceding three years have been, offered to the public or otherwise;

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In addition the filing company should list the exchange, ATS, ECN or over-the-counter market that their securities trade on as part of the record of the trading symbol.

This information should be filed in XBRL and be updated on a regular basis.

This information should be required by filing companies to ensure that investors in their securities are able to assess the entire capital structure of the firm.

The detailing of outstanding securities for public reporting companies will create more transparency for investors and financial markets.

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The Commission is considering rules now related to the regulation of NRSROs. The Commission is considering the use of XBRL on the NRSROs website for reporting credit ratings and performance statistics.

In our comments to the Commission on this topic we recommended that NRSROs which are compensated to rate an issuer’s security should post those ratings on their website upon issuance to further market transparency and stability.

As part of these comments we would recommend that a reporting company should include the credit ratings from NRSROs which they compensate to rate their securities within the master “company file” at the Commission.

This would enhance transparency around credit ratings for filing companies and subject credit ratings to an additional layer of market scrutiny.