SECURITIES AND EXCHANGE COMMISSION

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[Release No. 34-106339]

Order Granting Exemptive Relief, Pursuant to Section 36(a)(1) of the Securities Exchange

Act of 1934, from Inline XBRL Requirements for Portions of Form CA-1 and Form 1 and

for Form X-17A-5 Part III, Form 17-H, and Security-Based Swap Entity’s Annual

Compliance Report

September 11, 2026.

Introduction

On December 16, 2024, the Securities and Exchange Commission (“Commission”)

adopted rule amendments that require, among other things, that certain Commission forms or

submissions be filed or submitted electronically. 1 The rule amendments also require some of

these forms and submissions to be filed or submitted in structured data format. More

specifically, the rule amendments require the following forms or submissions to be filed or

submitted with the Commission in Inline eXtensible Business Reporting Language (“Inline

XBRL”): 2

•

Schedule A, and Exhibits C, F, H, J, K, L, M, O, R, and S to Form CA-1, the application

for registration (or amendment thereto) or for exemption from registration filed by

clearing agencies; 3

See Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments

Regarding the FOCUS Report, Exchange Act Release No. 101925 (Dec. 16, 2024), 90 FR 7250 (Jan. 21,

2025) (“Adopting Release”).

Inline XBRL is a structured data language. Data in documents can be tagged with Inline XBRL tags,

which offers the benefit of making the document machine-readable since machines can “read” the tags.

This functionality, in turn, is intended to enable more efficient retrieval, aggregation, and comparison

against different filers (or submitters) and time periods, as compared to an unstructured document.

See 17 CFR 232.405 introductory text, (a)(2), (a)(3)(i), (a)(3)(ii), (a)(4), (b)(1), (b)(5), Note 1, as amended.

•

Exhibits D, E (in part), and I to Form 1, the application for registration (or amendment

thereto) or for exemption from registration filed by national securities exchanges; 4

•

Form X-17A-5 Part III, annual reports filed by broker-dealers (including over-the-counter

derivatives dealers), as well as security-based swap dealers and major security-based

swap participants (collectively, “SBS Entities”) for which there is no prudential

regulator; 5

•

Item 4 of Form 17-H, the risk assessment report filed by certain larger broker-dealers; 6

and

•

The annual compliance report of an SBS Entity, which must be prepared and signed by

the SBS Entity’s chief compliance officer (“CCO”) pursuant to Securities Exchange Act

of 1934 (“Exchange Act”) Rule 15fk-1(c) (“CCO report”); 7

For the reasons discussed below, the Commission is granting exemptive relief to

registrants, 8 pursuant to its authority under section 36(a)(1) of the Exchange Act, 9 from filing or

submitting the following forms or submissions in Inline XBRL: Form CA-1 (except Exhibit H

See 17 CFR 240.6a-1(e), as amended; Form 1 General Instructions section A, as amended; 17 CFR 232.405

introductory text, (a)(2), (a)(3)(i), (a)(3)(ii), (a)(4), (b)(1), (b)(5), Note 1, as amended.

See 17 CFR 240.17a-5(d)(6)(i), (k)(2), as amended; 17 CFR 240.17a-12(b)(6), (k), (l)(1), (m)(1), as

amended; 17 CFR 240.18a-7(c)(6), as amended; 17 CFR 232.405 introductory text, (a)(2), (a)(3)(i),

(a)(3)(ii), (a)(4), (b)(1), (b)(5), Note 1, as amended.

See 17 CFR 240.17h-2T(a)(2), as amended; 17 CFR 232.405 introductory text, (a)(2), (a)(3)(i), (a)(3)(ii),

(a)(4), (b)(1), (b)(5), Note 1, as amended.

See 17 CFR 240.15fk-1(c)(2)(ii)(A), as amended; 17 CFR 232.405 introductory text, (a)(2), (a)(3)(i),

(a)(3)(ii), (a)(4), (b)(1), (b)(5), Note 1, as amended.

This exemptive relief extends to clearing agencies with respect to Form CA-1, self-regulatory organizations

with respect to Form 1, broker-dealers and SBS Entities with respect to Form X-17A-5 Part III, brokerdealers subject to Exchange Act rule 17h-2T with respect to Form 17-H; and SBS Entities with respect to

the CCO report. This exemptive relief also extends to SBS Entities relying on a Commission order

granting substituted compliance from submitting Form X-17A-5 Part III and the CCO report in Inline

XBRL. This order does not provide any exemption from the requirement to file or submit these forms and

reports electronically on EDGAR.

15 U.S.C. 78mm(a)(1).

thereto), 10 Form 1 (except Exhibit I thereto), 11 Form X-17A-5 Part III, Form 17-H, and the CCO

report.

II.

Discussion

Section 36(a)(1) of the Exchange Act grants the Commission the authority to

“conditionally or unconditionally exempt any person, security, or transaction…from any

provision or provisions of [the Exchange Act] or of any rule or regulation thereunder, to the

extent that such exemption is necessary or appropriate in the public interest, and is consistent

with the protection of investors.” 12 As discussed below, the Commission finds that the

exemptive relief granted herein is necessary or appropriate in the public interest and consistent

with the protection of investors.

As described in the Adopting Release, Inline XBRL was designed to help machines read

financial statements by linking specific metadata to data points. 13 While useful to many parties,

Inline XBRL primarily helps financial institutions and regulators analyze data; it is less useful

for the specified forms—Form CA-1, Form 1, Form X-17A-5 Part III, Form 17-H, and the CCO

report. Form CA-1 is used to assess applications for registration, or exemption from registration

as a clearing agency, and to assess amendments to clearing agency registration. 14 Form 1 is used

to assess applications for, and amendments to applications for, registration as a national

Exhibit H to Form CA-1 contains a balance sheet and statement of income and expenses, and all notes or

schedules thereto of the registrant, as of the registrant’s most recent fiscal year for which such information

is available, certified by an independent accountant. This order does not exempt firms from filing Exhibit

H to Form CA-1 in Inline XBRL.

Exhibit I to Form 1 contains the applicant’s audited financial statements. This order does not exempt firms

from filing Exhibit I to Form 1 in Inline XBRL.

See 15 U.S.C. 78mm(a)(1).

See generally Adopting Release at 7303.

See Form CA-1 Application for Registration or For Exemption from Registration as a Clearing Agency and

for Amendment to Registration Pursuant to the Securities Exchange Act of 1934 (the “Act”); 17 CFR

249b.200.

securities exchange or exemption from registration as a national securities exchange. 15 Form X17A-5 Part III is used to assess the financial and operational condition of broker-dealers. 16 Form

17-H is used as a risk assessment report for certain larger broker-dealers. 17 The CCO report is a

report signed by the chief compliance officer of an SBS Entity and submitted by such firm that,

among other required content, assesses the effectiveness of the registrant’s internal policies and

procedures as set forth more fully in Rule 15Fk-1(c). 18 What these forms share in common is

that they are specific to market intermediaries and are primarily used by the Commission to

assess whether an entity registered as a market intermediary meets the relevant standards –

including legal, financial, and operational standards – necessary to comply with the Exchange

Act.

Many of these filings have individually tailored information, so standardized tags can be

relatively less useful and, in the case of Form X-17A-5 Part III, duplicate existing

processes. Moreover, since the rule amendments were adopted, the Commission has received

information from industry participants stating that the cost of complying with the Inline XBRL

requirement is higher than the Commission previously estimated. 19 Thus, continuing to impose

Inline XBRL requirements in these cases would result in potentially significant unnecessary

See Form 1, Application for, and Amendments to Application For, Registration as a National Securities

Exchange or Exemption from Registration Pursuant to Section 5 of the Exchange Act, 17 CFR 249.1.

See Annual Reports Form X-17A-5 Part III, 17 CFR 249.617.

See Form 17-H, Risk Assessment Report for Brokers and Dealers, 17 CFR 240.17h-2T.

See 17 CFR 240.15Fk-1(c). The CCO report must contain descriptions of, at a minimum, an assessment of

the effectiveness of the firm’s SBS policies and procedures, material changes to the firm’s security-based

swap policies and procedures, areas for improvement and recommended potential changes to the

compliance program and resources, material non-compliance matters identified, and the compliance

resources dedicated to the firm’s security-based swap business. 17 CFR 240.15Fk-1(c)(2)(i).

See, e.g., Letter from Kyle L. Brandon, Managing Director, Head of Derivative Policy, Securities Industry

and Financial Markets Association (Mar. 13, 2026), available at https://www.sec.gov/comments/s7-0823/s70823-723567-2263574.pdf.

costs, which firms may ultimately pass on to investors through higher fees, without meaningful

gains in transparency or data accessibility to investors.

Furthermore, reducing compliance costs for firms with respect to Form X-17A-5 Part III,

Form 17-H, and the CCO report, by exempting them from the requirements to file in Inline

XBRL, would not impact investors, given that these forms are not primarily used by investors,

and several of them are generally non-public. 20 Instead, a reduction in compliance costs would

enable affected firms to allocate resources more efficiently, including to support or enhance their

operations and existing compliance obligations, thereby providing a benefit to investors and the

market. Accordingly, providing this exemption is necessary or appropriate in the public interest

and consistent with the protection of investors.

III.

Conclusion

For the reasons discussed herein, the Commission determines that the exemptive relief

granted herein satisfies the standard of section 36(a)(1) of the Exchange Act. 21

Accordingly, IT IS HEREBY ORDERED, pursuant to section 36(a)(1) of the Exchange

Act, 22 that the Commission is granting exemptive relief to registrants 23 from filing or submitting

Form CA-1 (except Exhibit H thereto), Form 1 (except Exhibit I thereto), Form X-17A-5 Part III,

As a general matter, the entirety of Form 17-H and the CCO report, and the vast majority of Form X-17A-5

Part III are non-public. See 17 CFR 240.17h-2T(e); 17 CFR 240.17a-5(e)(3); Adopting Release, 90 FR at

7293 and n. 347. See also 17 CFR 240.24b-2; 17 CFR 200.83 (identifying rules and processes with respect

to requesting confidential treatment of materials submitted to the Commission).

See 15 U.S.C. 78mm(a)(1).

This exemptive relief extends to clearing agencies with respect to Form CA-1, self-regulatory organizations

the CCO report.

Form 17-H, and the CCO report in Inline XBRL pursuant to Exchange Act rules 6a-1, 17a-5,

17a-12, 18a-7, 17h-2T, and 15fk-1. 24

By the Commission.

Sherry R. Haywood,

Assistant Secretary.

See 17 CFR 240.6a-1; 17 CFR 240.17a-5; 17 CFR 240.17a-12; 17 CFR 240.18a-7; 17 CFR 240.17h-2T; 17

CFR 240.15fk-1.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.