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kpmgReforming Regulatory
ReportingJohn Turner
Leader KPMG Global XBRL Services Team
kpmg
Topic Outline Walking the tight rope Reaching common understanding Evolution of regulatory reporting Why XBRL?
kpmg
Walking the tightrope Regulation, and government as a whole, cannot
exist without information from private corporations Lots of information No really Lots and lots of information This is variously estimated as around 0.6% of
GDP…. > 8 Billion hours per annum in the US alone Regulators must balance their legitimate
information needs against this “provider burden”.
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An ongoing balancing act… Viewed as a whole,
regulators appear to move between favouring industry and favouring government in terms of their data collections.
Both extremes are undesirable for all concerned
Reasons are complex, but include regulatory policy taking its lead from altering community expectations
kpmg
Topic Outline Walking the tight rope Reaching common understanding Evolution of regulatory reporting Why XBRL?
kpmg
Six principles for regulatory reporting requirements…
Timely
To be useful, information needs to be available within a reasonably short period from the time of measurement. The “rear view mirror” view of any qualitative measure is only useful where information is current—and its currency rapidly fades.
Accurate
Information should be free of data anomalies and errors and tested for manipulations. Reasonable
Regulators should seek to minimize provider burden (the amount of effort imposed on the regulated community by the scope of the data collection).
Relevant
The definitions and interrelationships between data definitions need to be up to date and as tightly linked to information used for the running of the business as possible.
Efficient
The cost of collecting the information needs to be proportionate to the value of the data collected. Transforming
Legitimate governmental information needs change markedly over time. Sometimes information collections are allowed to go stale as a result of a policy that favours the private sector. Stale information is resented, and eventually ignored by users, or, perhaps worse, is assumed to remain relevant by agency analysts, who quickly become out of touch with industry developments.
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Reaching common understanding…
Headline People turn to XBRL to help
exchange information between systems.
The sub-text In order to exchange information you
need to understand it. Understanding metadata turns out to
be tough. XBRL can help provide a consistent
view of all the information that is used around the enterprise (or across enterprises)
This is a way to componentise business activity without replacing systems
Facilitates system-to-system data integrity
XB
RL
Pro
prie
tary X
ML
Pro
prie
tary
No
n-X
ML
Pa
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r
Supported bydevelopment tools in
use by firms
Supported byaccounting packages in
use by firms
Facilitates datadefinition
Facilitates validationdefinition
Can leverage publicaccounting framework
kpmg
Topic Outline Walking the tight rope Reaching common understanding Evolution of regulatory reporting Why XBRL?
kpmg
Evolving processes for data collection…
kpmg
Paper Bound = Unusable data The process of designing
and deploying paper-based data collections is, of course, pretty simple.
The actual use of paper-based data is problematic!
kpmg
“Program Bound” = Continuous Programming
In this mode, the process of implementing the decisions made about regulatory reporting requirements involve:
Providing the Excel and Word (eg: paper) versions of the information requirements to the systems development team.
These requirements get coded (by hand) into electronic forms.
This goes backwards and forwards between the business and technology groups until the forms are right.
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Adaptive = Improvement by the Business
An “Adaptive” system is designed with a view to the need to make changes as being one of the key features of the business environment.
By building requirements in a format that are human readable as well as understandable by a the system, the business experts get very fine-grain control over the creation of the form.
It also imposes new levels of discipline over the creation of the regulatory reporting requirements, with business experts able to share the requirements with a range of stakeholders (internally and externally) in a very precise way.
Used in: Mortgage Firms KPIs
Concept: Reserves
Labels:
"Reserves"
References:
Handbook Reference: Sup 16 Ann 19G MLAR1
Section Reference: C1-2 (3)
Accounting Reference:Companies Act 1985: Part VIII Distribution of Profits and AssetsLimits of company's power of distribution
Text:Audited Reserves are audited accumulated profitsretained by the firm (after deduction of tax, dividends andproprietors' or partners' drawings) and other reservescreated by appropriations of share premiums and similarrealised appropriations. Reserves also include gifts of capital,for example from a parent company. For partnerships, auditedreserves include partners' current accounts according to themost recent financial statement.
Used in: Sup 16 Ann 19G C1
System References
System: Upfront Data Warehouse
Column: FSAABS002765
DataType: Monetary
Nillable: True
Created: 2004-03-19
Participates in
Reports:
Mortgage Firm KPIs
Mortgage Firm Balance Sheet
Validation Rules:
VR98033 - Revenue Movement
VR98033 - Revenue Transfers
Owner: Andy Watson
Data Challenge Date: 12 Dec 2003
Data Challenge Packet: HSF_DC_2003.doc
Consultation: CP197
Derivations and Calculations
Total Eligible Capital
Growth in free reserves
Schema: http://www.fsa.gov.uk/xbrl/2004-05-09_HSF.xsd
"Audited Reserves"
Used in: Mortgage Firms Balance Sheet
kpmg
Topic Outline Walking the tight rope Reaching common understanding Evolution of regulatory reporting Why XBRL?
kpmg
Six principles for regulatory reporting requirements… revisited
TimelyAccurateReasonableRelevantEfficientTransforming