Bridging compliance and internal use: XBRL & DPM value for data organisation, sourcing and analysis for banking and insurance entities AALTO University, XBRL Finland Helsinki, March 25, 2013 Michal Piechocki
Introduction: Michal Piechocki Member XBRL International Member Assembly Member IFRS XBRL Quality Review Team Member Institute of Management Accountants XBRL Committee Member IBM Information Governance Council Subject Matter Expert XBRL International Certification Board Co-author Leveraging XBRL for Value in Organizations (IFAC & ISACA) Co-author XBRL for Interactive Data: Engineering Instructor XBRL International Taxonomy Development Training CEO Business Reporting Advisory Group Past: Member At Large XBRL International Steering Committee Chair XBRL International Certification Committee Member IASCF XBRL Team (IASB)
Introduction: BR-AG
European Banking Authority (EBA) Supervisory colleges European Insurance and Occupational Pensions Authority (EIOPA) Supervisory colleges European Securities and Markets Authority (ESMA) Supervisory colleges European Supervision (new architecture) micro level macro level European Systemic Risk Board (ESRB) Chairperson Chairperson Chairperson until 2011 until 2011 until 2011 European System of Financial Supervisors (ESFS)
Three pillars approach for Basel III Basel III Pillar I Minimum capital requirements and Ratios For example: Own funds Credit, market, operational risk requirements Minimum capital ratios Minimum liquidity ratios Minimum leverage ratio Regulatory reporting Pillar II Risk management and supervision For example: Stress testing Prudential supervision Risk management Capital buffers Corporate governance Supervisory colleges Pillar III Market discipline For example: Public disclosure Reconciliation of regulatory capital to accounting framework
Lack of comparability of data for CRD I-III reporting Basel II Global best practices EC 2006/48 & 49 European Law 9X,XX% best practices + EU requirements Country 1 NBP 1 Country 2 Country 3 Country 27 NCB 2 FSA 3 NBB 27 Transition into national legislation (national options) National implementation Report 1 ------------ ------------ ------------ Report 2 Report 3 ----------------------------------------- ----------------------------------------- ----------------------------------------- ------------------------------------- Report 27 ----------------------------- ----------------------------- ----------------------------- ----------------------------- ----------------------------- --------------- Challenge! Relations between information models. Necessity to introduce single rule book based on regulation (not only directive)
Old way of modelling COREP financial liabilities total instruments total portfolio residence (not usable) at least one base item is necessary 1 base item - 3 breakdowns (# of members: 6, 4, 4) 4 base items - 2 breakdowns (# of members: 6, 4) 6 base items - 2 breakdowns (# of members: 4, 4) 15 base items - 1 breakdown (# of members: 4)? base items? breakdowns (# of members:?) hidden (implicit) dimensions: measurement - carrying amount net or gross? consolidation scope (CRD/IFRS) counterparty sector (e.g. debt securities issues by non-retail) derivatives short positions deposits debt securities issued held for trading designated at FV through P&L measures at amortised cost domestic EMU other EU other other
Old way - consequences only base items few base items, many breakdowns each data point defined as a base item high total number of items easy to define, difficult to maintain significant consequences of little changes to data model each data point defined as a base item in a combination of members of breakdowns lower number of items in total (Cartesian product is multiplication) distinguishing between base items and breakdowns not always easy supports maintenance: relation concept-breakdown is stable but components of breakdowns tend to change which is a base item, what is a breakdown? alignment with design of analytical models
"form centric based on presentation that conveys semantics (interpretation in certain contexts) identification of data based on location in table (i.e. Table XYZ, Row 010, Column 200) "data centric explicit definition irrespective of presentation (every term fully understood by its own with all properties included in its definition) identification of data based on its attributes (i.e. Type of instrument, Counterparty, Currency)
Need for a data model 1 2 3 Business Domain Experts data model definitions of business terms and their classification IT Experts information requirements (legal acts, templates and guidelines) Processes valid combinatinos analysis (query, comparisons, manipulation) and supervision business rules and error messages $v1 = $v2 + $v3 $v1 = abs($v2 div $v3)...
Everything is a perspective Portfolio breakdown (purpose and measurement) e.g. held for trading - acquired or incurred principally for the purpose of selling or repurchasing it in the near term ; includes different instruments: Derivatives, Loans, Debt securities, Equity instruments, portfolios held-for-trading designated at fair value available-for-sale loans derivatives debt securities instruments Instruments breakdown: e.g. debt instrument - contractual or written assurance to repay a debt ; can fall into different portfolios: Held-for-trading, Designated at fair value, Available for sale, assets liabilities income/ expense natures assets: property, resources, goods, etc that a company possesses and controls, e.g. financial instruments owned by a reporting entity that shall generate economic benefits in the future liabilities: sources of funding for company s assets and operations, e.g. financial instruments that have been issued by a reporting entity, thus represents an obligation that needs to be settled in the future by a transfer of some assets (such as cash) from the entity income/gains or expenses/losses: economic benefits that occurred during the period and originated from increase/decrease in value or result on sales/purchase of a given financial instrument
Data point Net carrying amount of not yet unimpaired but already past due (over 180 days) debt securities held, issued in EUR by MFIs located in EMU with original maturity under one year, measured at amortised cost and relating only to business activities conduced in Spain (local business). Measure (metric): Monetary Text Date Base terms: Assets Liabilities Equity Off-balance sheet Exposures Categories: Total ( ) Cash Loans Debt securities Equity instruments Tangible and intangible Other than ( ) Amount types: Carrying amount Gross carrying amount (Specific allowances) (Collective allowances) Original currencies: All / Not-applicable EUR Other than EUR Portfolios: Total ( ) Fair value through profit or loss Amortised cost Base term: Category: Portfolio: Amount type: Impairment status: Past due period: Original currency: Original maturity: Counterparty sector: Counterparty residence: Location of activity: Measure (metric): Time reference: Impairment status: All / Not-applicable Impaired Unimpaired Assets Debt securities Amortised cost Carrying amount Unimpaired 180 days EUR < 1 year MFIs EMU EU Monetary Current period end Time reference: Current period end Previous period end Current period Past due periods: All 0 days < 180 days 180 days Original maturity: All < 1 year 1 year < 2 year 2 years Counterparty sectors: All / Not-applicable MFIs MMFs MFIs other than MMFs Central Administration Other general government Non-MFIs other than government Counterparty residences: All / Not-applicable EMU Other than EMU ( ) Locations of activities: All / Not-applicable EU Other than EU ( )
Queries based on DPM assets by counterparty residence SELECT SUM(factValue) FROM allfacts WHERE item= assets AND portfolio= held-for-trading AND category= derivatives AND amount= notional AND ctresidence= uk AND ctsector= credit institutions AND originalcurrency= eur AND risktype= commodity AND market= OTC AND 24.320.223,54
Analysing data based on DPM static views modelling of databases (e.g. by regions, by products, by clients, etc.) dynamic analysis
Impact of DPM Fact Data point = new point of view on fact Unit Cunterparty Entity Period Risk type Exposure type
DPM oriented data model (databases)
DPM and cross-sector reporting FINREP rev 2 Market FINREP Fair value level Comprehensive income Controling/ Non-controlling Transfer Loan type ECB Statistics Amount interval Minimum reserve Main categories Amount type Portfolio Risk type Impairment Currency Geographical areas Collateral Sector Percentage Intervals Entity code Time intervals Line of business Type of business Change in basic own funds Type of claim Approach/Model used Exposure type Securitization type Diversification Type of contract COREP SOLVENCY II
COREP XBRL (EBA) Architecture aim: coherency, stability, flexibility (+ simplicity and efficiency) aspects: implementation and maintenance (both at filer and supervisor sides) Conceptual level (Dictionary) + Dimensional relationships (coherent with definitions in legal format) National extension Presentation relationships layer (flexible views) Dictionary Concepts declarations, labels and references Dimensional relations Complete model of data requirements Presentation relations Current data requirements design and stability of mapping flexible views Data warehouse User interface
EBA development process macro DPM Architect information requirements (legal regulations) analysis matrix (information from annotated templates) metadata database conv conversion tool (XBRL properties) XBRL taxonomy XBRL taxonomy exchange and validation mapping and storage analysis and publication
Implementation scenarios Benefits Challenges 1. Receiver provides XBRL enabled excel, word, PDF templates Portal no implementation costs need for manual work (rekeying data) error prone no benefit outside of this particular reporting context 2. Outsourcing (printer, consultant, vendor to prepare reports ) Portal comprehensive support low risk no knowledge required lack of control possibly high cost lack of internal capabilities 3. Bolt-on (tools to transform your reports into XBRL at the last stage ) ERP REPORT WRITER Portal simplified approach potential cost-saving control over result knowledge required time risk significant effort for change update 4. Integrate (build XBRL into company s business reporting supply chain) Portal ERP comprehensive approach cost-saving (mid-long) control over result automated processing enhanced reporting high data quality upfront investment level of complication
Compliance REPORTING ENTITY (BANK) XBRL INVESTOR, LENDER (analysis) REPORTING GATE XBRL Taxonomies Data input interface & validation SUPERVISOR (analysis, publication) XBRL Webservice & validation XBRL XBRL file upload & validation XBRL Other (authentication, security, prefill, notifications) REGULATORY AGENCIES (sharing, registry) RELATED ENTITY (e.g. SUBSIDIARY) FOREIGN REGULATORY AGENCY (analysis, publication) XBRL Taxonomies XBRL
Conclusions In internal scenarios: DPM can be used as a bridge allowing precise communication XBRL can be used as electronic information exchange standards In external (compliance) scenarios: DPM allows to map internal data sources XBRL allows to create the final report XBRL software: Disclosure management systems enabled with XBRL and DPM ETL mechanisms understanding DPM and using XBRL Validators, mappers to XBRL
Contact Michal Piechocki, CEO michal.piechocki@br-ag.eu m: +48 505 558628 o: +48 618 522277 f: +48 618 522277 Business Reporting Advisory Group spółka z ograniczoną odpowiedzialnością spółka komandytowa Sniadeckich 28/5 60-774 Poznan Poland http://www.br-ag.eu info@br-ag.eu