By Cydney Posner

This is a reminder that there is a change to the cover page for upcoming 10-Qs and 10-Ks. Commencing April 13, the cover pages were required to include the following new language:

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T during the  preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).
Yes No 

The new language appears after the check boxes regarding the registrant's having filed all required reports required during the preceding 12 months.

But here's the vexing question: if the company is not yet subject to the XBRL requirements, which is the case for most companies, which box do you check? The intrepid Zev Bomrind asked that question of Corp Fin's office of chief counsel. After diligently researching and discussing the question for almost 10 days, chief counsel's response to Zev this morning was: include the language, but do not check either box.

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