On March 11, 2020, the Securities and Exchange Commission (SEC) adopted a proposal and released a draft taxonomy for changes to the Variable Insurance Product (VIP) disclosure requirements. Our previous blog reviewed the disclosure changes, and here we will take a deeper dive into the draft taxonomy that was released. The draft VIP taxonomy details the concepts and structures required to create an iXBRL package for a filing.
Similar to mutual fund iXBRL tagging, only a summary section of the variable insurance product disclosure would be tagged. This summary disclosure would be tagged beginning with the first filing after the registration statement becomes effective. The tagged sections would include the most important data used by investors to make their investment decisions. Sections tagged would slightly vary based on which type of insurance product is being tagged.
|Key Information Table||Key Information Table||Key Information Table|
|Fee Table||Fee Table||Fee Table|
|Principal Risks||Principal Risks||Principal Risks|
|Benefits Available||Benefits Available||Standard Death Benefits
Other Benefits Available
|Investment Options Available||Portfolio Companies||Portfolio Companies|
|Additional Information about Investment Options|
While cover page tagging would not be required for these filings, the identifying document entity information would still be. These fields include Registrant Name, Central Index Key, Amendment Flag, Amendment Description (if AmendmentFlag is true), Document Type, and Investment Company Type.
Another similarity to mutual funds is that the same six iXBRL exhibits are included in the filing. All six of these exhibits are required for Form N-3 iXBRL filings, but N-4 and N-6 filings do not require a calculation linkbase.
Variable insurance product tagging also allows for inline tags to be nested to capture several facts within the same sections. This means that entire sections will be tagged using a text block-level concept, tables will have a table text block tag, and each fact or excerpt with the text block or table will also be tagged using the more detailed concept.
There are also new data transformations that will be included with the release of this taxonomy. An example is for the concept vip:StandardBenefitFlag. Using the text “Is benefit standard or optional,” the words “standard” and “optional” will transform to “true” and “false,” respectively. This will allow the filer to use this concept without creating a hidden fact within the iXBRL filing.
Because variable insurance disclosures are so complex, the draft taxonomy outlines some common dimensions that can be used for contracts which describe several classes (vip:ClassAxis), generations (vip:GenerationAxis), benefits (vip:BenefitAxis), or investment options (vip:InvestmentAxis). Each of these axes has specific custom members that are allowed to be used to differentiate the offerings.
These iXBRL requirements do not go into effect until January 1, 2023. This gives filers time to review and understand the requirements. Our team of iXBRL experts is ready and waiting to help you create and file your disclosure in compliance with the new ruling.
The SEC has requested any comments regarding the draft taxonomy to be reported within 90 days of its release. Any comments should be sent to StructuredData@sec.gov and include “Draft VIP Taxonomy Guide” in the subject line.