Explore the data

disclosure regimes · United States

When private loan schedules became machine readable

The SEC required business development companies to tag their financial statements, including every schedule set out in Article 12 of Regulation S-X, in Inline XBRL — with each amount tagged separately. Compliance ran from 1 August 2022 for funds eligible to file a short-form registration statement, and from 1 February 2023 for all others.

the dates

  1. 8 April 2020The Commission adopts Securities Offering Reform for Closed-End Investment Companies, Release Nos. 33-10771; 34-88606; IC-33836. It extends to BDCs the Inline XBRL requirement already applying to operating companies.
  2. 1 June 2020Published in the Federal Register at 85 FR 33290. Effective 1 August 2020.
  3. 1 August 2022Compliance date for funds eligible to file a short-form registration statement — listed, current in their reporting obligations, and with at least $75m of public float.
  4. 1 February 2023Compliance date for all other affected funds.

What becomes machine readable

Rule 405(b)(3)(i) of Regulation S-T requires the Interactive Data File to contain the complete set of financial statements and all schedules set out in Article 12 of Regulation S-X — which includes the Schedule of Investments. Rule 405(e) then requires that within each schedule, each amount — monetary value, percentage and number — be tagged separately.

granularity · The individual position. One tagged fact per loan, per amount: fair value, cost, principal balance, and where reported the spread over the reference rate and the interest rate.

What stays out of reach

Nothing requires a standardised borrower identifier in a BDC Schedule of Investments — neither a LEI nor a CUSIP. Matching the same tranche across two filers therefore rests on strings each filer writes its own way, which is the work, and the reason the rate check exists. The fair value level is not tagged at position level either: Rule 12-12 note 9 requires only a typographic symbol on securities valued with significant unobservable inputs, and in the filings we examined no XBRL context crosses the position identifier with the fair value hierarchy axis.

What it changes for the measurement

This is the single change that makes the measurement possible. Before it, a Schedule of Investments was a table in a document; after it, it is a set of tagged facts. Where our published history starts is our own choice — the first period where the whole panel is tagged — and not a regulatory date.

primary sources

this page describes what the texts say · it is not legal advice, and the official text always governs · where we could not read a primary source, we have left the point out rather than paraphrase it