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Comply with XBRL Automate Compliance with U.S Comply With XBRL Automate Compliance With U.S. and European Financial-Reporting Standards A White Paper by Gerald D. Cohen Gerald D. Cohen Gerald D. Cohen is president and CEO of Information Builders, the leader in Web-based business intelligence (BI) and the largest software manufacturer in New York City. He also serves as CEO of iWay Software, an Information Builders division and leader in enterprise integration. Mr. Cohen co-founded Information Builders in 1975 with the mission to develop a software product that would allow non-programmers to create their own information systems. The resulting product, known as FOCUS, was the industry’s first fourth-generation language, thus delivering an innovative way for people without formal computer programming skills to work with information systems. Building on this foundation for the past 34 years, Information Builders’ solutions have been used to construct business intelligence systems for thousands of leading companies, universities, and government agencies around the world. The company’s business intelligence platform, WebFOCUS, is the category leader in Web-based reporting. Through his dedication, Information Builders’ customers include most of the Fortune 100 and U.S. federal government agencies. Headquartered in New York City with 90 offices worldwide, the company employs 1,450 people and has more than 350 business partners. Table of Contents 1 Executive Summary 2 A New Standard for Financial Reporting 3 Issues of Compliance 4 XBRL-Compliance Automation 6 Using the WebFOCUS XBRL Generator Executive Summary A new standard file format, Extensible Business Reporting Language (XBRL), for submitting financial reports to the SEC in the United States is being mandated for June 2009. A similar standard is currently in effect in Europe and other jurisdictions. This standardization initiative requires that all terms in all financial reports must be submitted in an approved taxonomy, so comparable terms are used across different companies. While this is another task for companies to master, it has some positive benefits. The main one being that financial analysis will be easier to perform when comparing different companies. But, it can also be used within multi-entity companies as an internal standard of reporting and as an error-free method of exchanging documents between systems and users. This imposes an accepted uniform taxonomy for existing and new entities as they arrive. As with any new compliance requirement the process of preparing the submission of XBRL files should be documented and certified as part of proper governance. The quality of the XBRL document does not depend on the tags, but on the process that ensures their conformity to the standards. This paper discusses the pitfalls of using manual steps that are currently common for transposing financial documents into compatible XBRL files, looks at the advantages of substituting an automatic process, and illustrates that process. The ability to report from an XBRL file so a company can check their own submissions and analyze and compare them with other companies is also becoming an important new capability. Both the creation of, and reporting from XBRL, are functions performed by the same new tool described in this paper. 1 Information Builders A New Standard for Financial Reporting The Extensible Business Reporting Language, which is commonly referred to by its acronym XBRL, is a file structure that can contain the elements of a financial report that has been vetted to appear in a very standardized way by a taxonomy that controls the validation of the elements. In this way all parties that submit their financial reports will have comparable elements that have the same titles and should mean the same thing. What makes this file structure important is that in the United States the Securities and Exchange Commission (SEC) has mandated that all public companies using US GAAP with worldwide public float over $5 billion must start to submit their financial statements to the SEC in XBRL format starting in the first fiscal period – on or about June 15, 2009. It is expected that the threshold of submission will be lowered in the future. In fact, many companies make voluntary submissions and the SEC is providing incentives to encourage this practice. In addition the International Financial Reporting Standard (IFRS) developed by the International Accounting Standards Board (IASB) has developed an IFRS XBRL taxonomy that is gaining acceptance worldwide. In Spain, for example, all financial institutions are currently required to report in XBRL format. 2 Comply With XBRL Issues of Compliance Public companies will have the added chore of maintaining SEC reporting compliance and being IFRS-compliant overseas. Some may think of this as yet one more government requirement that takes time and effort without much return. And they might want to comply by pasting together a solution that tucks the problem under the rug to get rid of it cheaply and as fast as possible. This approach would be a mistake because this is part of a serious worldwide effort to enforce financial transparency. Proper governance of this effort is essential because too many manual steps and procedures will allow errors, as well as outright fraud to creep into the submissions. XBRL is a complex file structure and is not an easily scanned printed sheet of paper. Of course the file will be used as report input, but it is essentially a small database of information and a report writer is needed to render the information in the database as understandable output. The resulting reports need not have any resemblance to how the current printed reports look, or even have all of the items found in the original reports. One of the purposes of the new file format is to allow analysts to pick common items from different company’s XBRL files for comparison. Because the taxonomies use the same names and meanings of the items, the reports are expected to find comparable data, guaranteeing the accuracy of the comparison. This is a benefit that all companies will share. The governance of information submitted to the public and government agencies requires an efficient and standard process with built-in verification. 3 Information Builders XBRL-Compliance Automation Compliance is mandatory, but the process of preparing compliant documents is not. There are no government guidelines or suggested best practices on process. Doing the right thing wrong can result in the very same deficiencies that XBRL intends to eliminate. Companies are opting for either one of the following two methods to prepare XBRL documents: ■ Post processing for XBRL compliance: The XBRL structure and tags are applied after the docu- ment has been generated. This process is separate from the document generation process. It is done either manually or semi-manually with the assistance of specialized tagging software ■ Integrated XBRL reporting: The XBRL structure and tags are applied during the report prepara- tion phase. The XBRL standards are fully integrated with the reporting system, allowing for the automation of the entire process (as shown on Figure 1 below). The process starts with access to data in the general ledger and other systems. The data is used to prepare the printed reports in multiple formats, of which the XBRL file is one output type generated and verified automatically without manual intercession Other Financial General Ledger Data Sources WebFOCUS Original Document XBRL Template Template Transformation Process Report Verification of XBRL Template Figure 1: A process for automated XBRL preparation. 4 Comply With XBRL It is interesting that the manual vs. automated approach is debated at all given that all industrial and information management processes have been gradually automated. Manual tagging is the natural byproduct of early stage adoption of XBRL. Companies are reluctant to make long-term investments in infrastructure and automation technologies when there is uncertainty about the future. Opting for manual tagging mitigates such risks. The SEC mandate has eliminated the uncertainty – XBRL is here to stay! Automation is expected to proliferate rapidly because the SEC mandate will drastically change the scale and scope of XBRL implementation: ■ Multiple systems integration: Financial data resides in multiple systems and as standards are applied more stringently, data from all disparate systems must be brought into the reporting process in a uniform and cost-effective way. The diversity of reports coming from disparate systems will create a reconciliation nightmare if a manual tagging process is selected ■ Increasing number of XBRL report authors: As more accountants and financial specialists begin to create XBRL reports, the propensity for errors either in the taxonomies or in the tagging process increases if a manual process is used. An enterprise level reporting system ensures that all users have access to the same corporate taxonomy regardless of their location and data source ■ Increasing number of XBRL report analysts: As more analysts begin to slice-and-dice the tags in XBRL documents, it is important to ensure the integrity of the source documents and the persistence of tags in derivative documents. Derivative documents inherit the qualitative characteristics of the originals. To use an analogy, Excel has created a “truth problem” because each derivative workbook deviates further and further from the original. An enterprise-level reporting system diminishes the propensity for erroneous
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