No Time for XBRL Filing Complacency

We are pleased to say that we have the opportunity to hear from Andrea Whitehouse, Marketing Manager at our partner, acknowledged XBRL experts, CoreFiling who wants to discuss XBRL reporting needs

Banks and other financial institutions may currently be breathing a sigh of relief, having been offered a reprieve – albeit possibly a brief one – from the end-April submission date originally specified for the first Liquidity report filing under the new CRD IV reporting regime.

But even though the deadline has been put back to the end of June, many organisations, both large and small, are still scrambling to put in place a suitable mechanism for producing their XBRL filings – as many of the traditional vendor solutions are still unfit for purpose.

XBRL, the format in which the European Banking Authority (EBA) and its National Competent Authorities around Europe are expecting to receive the new COREP, FINREP and Liquidity reports, is not an easy technology for the uninitiated. And expertise in the market is in short supply.  

Meanwhile, we have heard stories of several organisations that bravely embarked on a DIY approach, only to admit defeat and, having wasted a lot of time, have now resorted to contacting companies that specialise in XBRL products.

So how can you ensure that you will be able to submit valid XBRL filings on time? By trusting in XBRL experts – organisations that can demonstrate in-depth expertise and experience in conquering the challenges represented by XBRL. The easiest way is to rely on XBRL products that are already tried, tested and proven in the market; a solution based on commercial-off-the-shelf (COTS) products goes a long way towards ensuring that all will be well.

However, it also depends upon how those products are integrated into existing systems, especially where data has to be extracted from multiple sources before being turned into XBRL documents.

One of the main challenges all organisations are facing in this new XBRL world is how to understand exactly what data is being reported in the final submission documents, for example. To the layman, the XBRL output from traditional conversion software is virtually unintelligible, so what happens when those in authority need to provide approval and sign off? What steps have been put in place to ensure that the data is correct? These are fundamental issues for most financial institutions, and ones that cannot be solved easily.

Additionally, we have heard reports that several organisations have had filings rejected at the regulatory gateway because of invalid filings, but had no easy way of determining where the problems lie. Relatively few stable COTS solutions exist to handle this issue.

There is also the problem that the situation with CRD IV is less stable than we might like. We have already seen a number of changes to the EBA taxonomy; and as the reporting regime evolves, it is likely that the taxonomy will be subject to regular updates. The problem is that solutions that rely on hard-coding may not be able to be updated easily and vendors may need time, not to mention additional fees, to implement changes; whereas systems that are taxonomy-driven will have provision to drop in a new version of the taxonomy in a relatively seamless manner.

The issues discussed above are all questions you need answers for as you implement your COREP, FINREP and Liquidity reporting solutions.

Those answers may not be readily available or systems easy to implement – but getting financial reports right first time is surely the goal of all regulated entities embarking on XBRL reporting.

About CoreFiling

CoreFiling partners with EMC and SynApps in the production of the XBRL Disclosure Management Platform™.  XDMP™ is a comprehensive XBRL workflow and reporting solution for the creation and management of XBRL documents ready for the submission of COREP, FINREP and Liquidity returns to European regulators.  The solution is built on a number of CoreFiling COTS products, plus EMC Documentum, with the SynApps ConXReporting providing the web front end. 

To handle the XBRL rendering issue CoreFiling provides Magnify® a comprehensive XBRL document review tool that allows filers to check the quality and validity of their disclosures.  Magnify® checks for compliant XBRL, but also checks conformance against regulatory filing rules, for example rules issued by the EBA, and highlights any discrepancies so that remedial action can be taken.

In April 2014, in advance of the original CRD IV deadline, the Bank of Ireland successfully submitted its first live filing to the PRA/FCA using the XDMP solution.

CoreFiling specialise in XBRL.  Regulators, government agencies and corporations around the world rely on CoreFiling for XBRL-based performance reporting solutions.  The company’s senior management and developers are active members of the XBRL consortium which oversees the development of the XBRL specifications.