§9.7.2

Footnotes Inside the Frame

A footnote printed inside the table border—a row or a caption?

✅ NormativeSettled. The requirement holds as written.📄 Page ruleCan be applied from the page alone.Read §9.7.2 in the RFC ↗

The requirement

A table footnote MUST be rendered outside the table, as footnote text placed after it — even when the page prints it inside the table's ruled border. It MUST NOT be rendered as a row of the table. It retains the Footnote class and MUST NOT be wrapped in <caption>. This is a deliberate exception to the frame test.

When it applies

A footnote line printed within the table's own ruled border:

Sketch of the printed page — layout, not output

| Rate A     | 1.10¹   |
| Rate B     | 1.25    |
| ¹ Excludes riders    |   ← printed INSIDE the ruled frame

Reading the examples. Each one pairs a source page with the output the rule expects. ✅ Sample: the rule applies. ❌ Counter-sample: it looks like it applies and does not, or a rendering got it wrong. A non-conforming output, in red, is shown only for contrast. … marks content left out of an excerpt.

Why the frame test does not decide footnotes

The frame test — ink inside the border is a row, ink outside it is a caption — decides titles and banners in Titles Banners Captions (§9.7.3) and totals blocks in Bottom Edge Totals and Islands (§9.7.1). It is worth having because it is mechanical.

A footnote is where it gives the wrong answer. The line names no columns and carries no values, so rendering it as a row asserts something false about the table: a consumer counting records gets one too many, and the row's single cell has no relationship to any column above it. Where the typesetter drew the border is a layout accident — the footnote is commentary on the table either way.

The carve-out costs the frame test its single-signal property, and that price is paid deliberately: the frame decides titles and banners; it does not decide footnotes.

✅ SampleThe rule applies

(Justify Selection and Trend Period in Filing Memorandum) is printed inside the…`wwa`

(Justify Selection and Trend Period in Filing Memorandum) is printed inside the table's grid, under the last data row — the case where the frame test and instinct disagree. It is set in italics, and it follows the table as footnote text.

Source page

Expected output · excerpt, table 1 of 4 and its footnote

	Quarterly Data				Rolling 4-Quarter Data
Calendar YYYYQ	Earned Exposures	Earned Premium	On-Level Earned Premium	On-Level Earned Premium per Exposure	Earned Exposures	Earned Premium	On-Level Earned Premium	On-Level Earned Premium per Exposure
20181	7,922	7,176,347	12,371,356	1,562
20182	8,182	7,482,355	12,699,979	1,552
20183	8,457	7,873,442	13,047,208	1,543
20184	8,533	5,931,377	9,267,627	1,086	33,095	28,463,522	47,386,171	1,432
20191	8,455	7,542,332	11,782,122	1,393	33,627	28,829,507	46,796,936	1,392
20192	8,731	8,310,237	12,647,017	1,448	34,176	29,657,389	46,743,974	1,368
…
20243	6,762	10,399,111	11,171,105	1,652	26,922	40,293,219	44,436,437	1,651

(Justify Selection and Trend Period in Filing Memorandum)

Rendering the footnote

Wherever the border falls, the footnote MUST be footnote text placed immediately after the table. It MUST be transcribed verbatim, including its leading marker, and MUST stay attached to the table it annotates rather than drifting into the surrounding prose.
A line opening ¹, *, (a) or Note: that refers to a marker printed in a cell above it is a footnote, not a row.
Superscript markers inside cells MUST stay attached to their values — see Marks and Symbols in Cells (§9.6.6). The footnote body leaving the table does not take the reference with it, so 1.10¹ in the cell and ¹ Excludes riders after the table still point at each other.
The text MUST survive either way. Only its placement is decided here; dropping it is never conforming.

✅ SampleThe rule applies

two footnotes inside a shaded frame

Footnotes 1 and 2 sit inside the grey-bordered panel that frames the trading table, under the Total row, in a smaller face. Both follow the table as footnote text; the superscript markers stay in the header cells and the Other trading label. Only the year band and the Total row are printed bold; the hyphenated header wraps (per- / form- / ance) are joined.

Source page

Expected output · table and its footnotes

	2025			2024
in € m.	Trading revenues reported	Net trading related interest¹	Trading performance	Trading revenues reported	Net trading related interest¹	Trading performance
Interest and credit trading	1,412	1,486	2,898	1,977	1,240	3,217
Equity trading	58	392	450	1,486	402	1,888
Foreign exchange, metal, commodity trading	1,180	4	1,184	1,301	(5)	1,296
Other trading²	1,290	(214)	1,076	720	(392)	328
Total	3,940	1,668	5,608	5,484	1,245	6,729

¹ Includes interest income from trading assets and interest expense from trading liabilities, as well as allocations of interest expense and income representing the funding cost or benefit associated with trading positions. These amounts are included in net interest revenues in the Consolidated Statement of Income. Also adjusts net interest revenues on derivatives entered into for nontrading purposes, but failing to qualify for hedge accounting treatment.

² Includes gains and losses from derivatives not qualifying for hedge accounting treatment.

Look-alike

Two similar pages that call for different decisions. Synthetic, for teaching the boundary.

Two lines printed inside the ruled border, neither of them data. Rows or not?

A title band sharing the border

APPLICABILITY CHART
State	Version	Effective
Alabama	*	*

The convention

A header row inside the table, full width.

A footnote inside the frame

Rate	Factor
A	1.10¹
B	1.25
¹ Excludes riders

The convention

Outside the table, as caption text after it.

Look at the structure. What evidence changes the answer?

Rule id tables-footnotes-inside-the-frame · tables captions boundaries