XBRL: The Israeli Experience

Written by Bob Schneider
Posted on July 30, 2010 Comments
July 30, 2010 | General | Bob Schneider

Written by Bob Schneider     Posted on July 30, 2010

A few weeks ago, Haaretz, Israel’s oldest daily newspaper, published an article about the country's adoption of XBRL with the chilling headline A third of Israeli companies get int'l financial reports wrong.  Summarizing the findings of a recently published study by a trio of researchers, the piece states:

The ISA [Israel Securities Authority] had hoped that Israel would be a light unto the nations. Barely a flicker, really: In practice the project has been more reminiscent of the Tower of Babel…34% of the 2008 corporate reports showed inconsistencies between the XBRL reports and the Hebrew versions. In 11% data was missing, and in 28%, there was a mismatch in the content. 

The article includes this eyebrow-raising quote from Ariel Markelevich, a member of the research team:

...There were cases in which companies reported losses per share as profits per share in XBRL, and a case in which a company put its data for 2008 in its balance sheet, but in the middle of the collection of numbers, it switched to figures from 2007. There were 15 companies that simply didn't report a profit and loss statement in XBRL.

In the paper, which is available online, the authors describe how XBRL statements are prepared in Israel. Filers neither map or tag their financials; instead, they enter line-item data (footnotes are largely excluded) into a form at the ISA's TOFES website. The ISA converts the company data to XBRL and uploads it to its MAGNA reporting site. Importantly, the authors note that “...a similar data entry form has existed on the ISA’s website for a while. The only difference seems to be that the ISA is now converting this data to XBRL format.”

After reading the paper a couple of times, I’m uncertain how things went wrong. Some of the mistakes described -- such as a reversal of signs that would, for example, turn an EPS loss into a profit -- have been well documented in XBRL conversions. The SEC (among others) has cautioned filers about the potential for error, and these mistakes are unlikely to reappear in any number in future XBRL exhibits. Wholesale mistakes such as the complete absence of any P&L numbers at all, however, are just baffling.

But for argument’s sake, let’s assume the errors in the XBRL statements are as serious and as extensive as the authors contend. What does the Israeli experience tell us about the utility of XBRL adoption, and what lessons does it hold for regulatory agencies throughout the world that are implementing XBRL reporting?  

Very little. As the authors make clear, the “unique process” by which XBRL statements are prepared in Israel -- with filers doing no tagging, and the ISA itself performing the XBRL conversion -- is poles apart from that of SEC and many other national registrars. Because Israel’s method of implementing XBRL bears no resemblance to the way other regulators are pursuing XBRL adoption, drawing any conclusions about the viability of XBRL statements from the Israeli experience is impossible.  

Nevertheless, the authors occasionally imply such a connection. Although stating the uniqueness of Israeli adoption, they spend much time discussing the SEC experience, focusing almost exclusively on the Voluntary Filing Program (VFP) and the mistakes researchers have found in participants’ XBRL exhibits. Based on this evidence, the authors state that “Due to the amount of human intervention (manual or software tagging), the reliability of XBRL filings currently made available is highly worrisome.”

That’s like a baseball writer in mid-May forecasting that, given its lousy spring training record, a team will finish last in their division -- when they’re already 26 and 14 in the regular season. The largest companies have now been filing XBRL exhibits for a year, and by most accounts adoption has gone relatively smoothly with low data error rates. (Footnote data may prove more challenging, but, as noted, the ISA adoption did not include footnote disclosures.)

I understand the needs of researchers, who are eager to analyze whatever large sets of data are available. And it’s both reasonable and useful to discuss mistakes in XBRL financials prepared under such programs.

But the VFP was specifically set up so that companies could gain experience with XBRL without worrying about getting everything right. Assessing the overall viability of XBRL adoption for financial reporting on this data is not only wrongheaded: it can also discourage regulators from inaugurating such programs, and companies from participating in them.  

XBRL Developments in India

Written by Bob Schneider
Posted on July 22, 2010 Comments
July 22, 2010 | General | Bob Schneider

Written by Vinod Kashyap     Posted on July 22, 2010

Vinod Kashyap is a Director at  NextGen Knowledge Solutions Private Ltd., which is engaged in the business of conducting training courses on XBRL for banks, corporations, and financial professionals in India. He is a member of the Institute of Chartered Accountants of India and is a qualified Information Systems Auditor.  

XBRL is making steady progress in India for external and internal reporting of banks and companies. These advances are underpinned by the work of XBRL India, a provisional jurisdiction of XBRL International.

Recognizing the enormous benefits that an XBRL-based reporting system offers, the Reserve Bank of India (RBI) formed a high-level steering committee for the purpose of adopting XBRL for various returns being submitted by India’s commercial banks. On October 6, 2008, the RBI launched its XBRL-based electronic filing system for capital adequacy return (RCA II), which is based on the Basel II-related capital measurement framework. India is one of the few, if not the only, developing country that has implemented XBRL-based reporting of data under Basel II. RBI has also developed a taxonomy for two more returns being submitted by commercial banks, namely, (1) the Gaps Position and Balances return for monitoring compliance of the cash reserve ratio (CRR) by banks, and (2) the so-called Return A for monitoring net overnight open positions and aggregate gap limit by banks authorized to deal in foreign exchange. RBI is in the process of adopting taxonomies for several other returns, including annual and quarterly financial statements.
 
Turning to operating companies, the Institute of Chartered Accountants of India (ICAI) has completed a draft  financial reporting taxonomy for commercial and industrial (C&I) companies, which awaits approval of XBRL International. ICAI has also finished work on a draft XBRL banking taxonomy, an extension to the core C&I taxonomy.  

The Bombay Stock Exchange and National Stock Exchange, India’s two leading stock exchanges, have already adopted an XBRL-based reporting system under a unified electronic platform popularly known as the CorpFiling system. Currently, the top 100 companies in India are using CorpFiling to submit their disclosures to the two exchanges.
 
The Central Electricity Regulatory Commission (CERC), the regulatory body for the power sector in India, has embarked upon development of an XBRL-based Regulatory Information Management System (RIMS) that would facilitate information collection, regulatory analysis, compliance monitoring, decision-making, and other regulatory functions.

Finally, the Ministry of Corporate Affairs (MCA) has decided to implement an XBRL-based financial reporting system for all companies in India from April 1, 2011. There are about  900,000 companies that submit data to MCA. However, the necessary regulatory notification from MCA on this system has not yet been made.

Not much has been done so far by the accounting bodies in India to educate their members on XBRL. In the absence of sufficient XBRL-trained professionals in India, companies will find it difficult to adopt an XBRL-based reporting system if implemented as scheduled from 2011. In addition, it is expected that a very substantial amount of work will also be generated because of outsourcing from other countries. Clearly, after perhaps a relatively slow start compared with some other Asian nations, India is emerging as a significant force in XBRL adoption.  

The SEC’s XBRL Mandate for NRSROs

Written by Bob Schneider
Posted on July 17, 2010 Comments
July 17, 2010 | General, SEC | Bob Schneider

Written by Bob Schneider     Posted on July 17, 2010

SEC requirements for XBRL disclosures affect three types of entities: operating companies, mutual funds, and credit rating agencies that are Nationally Recognized Statistical Rating Organizations (NRSROs).

The mandate for operating companies has, quite properly, received the great bulk of the attention, and there has been a continuous flow of information and commentary. For mutual funds, the Commission’s recent webinar on providing XBRL data for the risk/return summary offers an excellent outline and many of the specifics.

Comparatively little has been written about the requirement for NRSROs. I hope this short Q&A is useful.

1. What is a Nationally Recognized Statistical Rating Organization?
NRSROs are credit rating agencies (CRAs) that are registered with the SEC under guidelines of the Credit Rating Agency Reform Act of 2006 and whose ratings are consequently deemed acceptable for a variety of regulatory purposes, including capital requirements. Given their Federal government imprimatur, NRSROs enjoy enhanced status vis-à-vis other CRAs, and their ratings are widely used by other government entities and investors.

2. How many NRSROs are there, who are they, and what securities do they rate?
As listed on this SEC webpage, there are currently ten NRSROs which “…may be registered with respect to up to five classes of credit ratings: (1) financial institutions, brokers, or dealers; (2) insurance companies; (3) corporate issuers; (4) issuers of asset-backed securities; and (5) issuers of government securities, municipal securities, or securities issued by a foreign government.”

3. What was the process for adopting XBRL disclosure for NRSROs?
Unlike the XBRL-specific interactive data rule for operating companies, the regulations to implement XBRL for NRSROs were part of a series of amendments to the larger set of rules that govern these entities. As readers are aware, many observers place substantial responsibility on credit rating agencies for the subprime mortgage meltdown and consequent financial crisis. In response, in 2008-2009, the Commission proposed amendments -- including provisions for XBRL disclosure -- to existing rules governing NRSROs, modifying them after considering the Comments they received from the NRSROs and other parties.

4. What views were expressed in the Comments to XBRL implementation?
The Comments I reviewed were mostly unconcerned with either the utility or difficulty of adopting XBRL. Instead, the Comments – particularly those from NRSROs – focused on the threat to the agencies’ subscription revenues from public disclosure of ratings data soon after the rating was issued. One Comment noted that the drop in subscription revenue from fast public disclosure would have the perverse effect of making NRSROs even more reliant on income from issuers – a revenue source at the heart of the criticism credit rating agencies received for their role in the financial crisis. 

5. What are the current requirements for XBRL disclosure by NRSROs?
NRSROs must post on their websites in XBRL format a random sample of 10% of their issuer-paid credit ratings and histories of ratings actions for each class of rating for which the NRSRO is registered and has issued 500 or more issuer-paid ratings. In addition, they must disclose ratings histories for all credit ratings initially determined on or after June 26, 2007. Apparently recognizing NRSRO concerns about revenue impairment, the SEC ruled that, for issuer-paid ratings, ratings actions must be disclosed 12 months after they were taken; for other ratings, ratings actions need not be disclosed until 24 months after they were taken.

6. What is the status of the XBRL taxonomy for NRSRO disclosures?
The taxonomy has been developed by XBRL US, and the SEC hopes to release it shortly. Because the rule requires an NRSRO to use the List of XBRL Tags for NRSROs published on the Commission’s Web page and such a list is not currently available, NRSROs “can satisfy the requirement…by using an XBRL format or any other machine readable format, until such time as the Commission provides further notice.” (see Release No. 34-60451).

For readers who want to do further research on the requirements, the SEC’s Spotlight on Nationally Recognized Statistical Rating Organizations has the links to the relevant documents. Also, note that the financial reform bill passed a few days ago has numerous provisions that will affect NRSROs. I'm not aware that they will have an impact on XBRL disclosure rules, but please let me know of any possible effect. 

 

The SEC’s XBRL Mandate Will Improve Company Accounting

Written by Bob Schneider
Posted on July 9, 2010 Comments
July 9, 2010 | General | Bob Schneider

Written by Bob Schneider     Posted on July 9, 2010

Launched at the start of the new millennium, the Global XBRL Academic Competition is almost as old as XBRL itself.  In an interview with this blog a couple of years ago, Saeed Roohani -- Program Chair for the Competition and Professor of Accounting at Bryant University – noted that the earliest entries focused on “awareness” issues, i.e., “do you know what XBRL is?” More recently, however, with the adoption of XBRL in an increasing number of jurisdictions, the students’ research has been addressing “implementation, value proposition issues, and internationalization.”

A good example is the paper An Analysis of the Implementation of XBRL by Merchandisers and Manufacturers, which received Honorable Mention in the 2009-2010 competition.  Advised by his professor Neal Hannon, a leading XBRL expert, Constantine “Dean” Proestakes compared the elements chosen by six companies -- three merchandisers and three manufacturers -- for the same line items on their respective balance sheets for a quarterly report. His work found interesting variations in the elements companies chose for the same line item. One example he cites is that for Property, Plant, and Equipment (page 5):

Specifically, the computer manufacturing companies of Dell and Apple chose to report this line item using an extension, whereas the other four companies used the standard XBRL element “<us-gaap: PropertyPlantAndEquipmentNet>”. Hewlett-Packard was the only computer manufacturer of the three not to create an extension for this line item. One would think that Hewlett-Packard’s manufacturing operations are similar to that of Dell and Apple. Indeed, there was no separate line item for software on Hewlett-Packard’s balance sheet so there must be a reason why Apple and Dell chose to depart from the existing XBRL Taxonomy and Hewlett-Packard did not.

Mr. Proestakes explains that, according to GAAP, capitalized software is an intangible asset; the definition for the standard Property, Plant, and Equipment element, however, specifically stipulates tangible assets. Mr. Proestakes suggests that Dell and Apple may have believed an extension was necessary to include their (intangible) capitalized software. HP, for whatever reason, did not.

As I read through the paper, I recalled Walter Hamscher’s speech at the recent Rome XII conference, where he noted how XBRL filing is changing traditional accounting statements. Walter noted that data that originally appeared in a few tables in the traditional financials can sometimes be consolidated and better represented in XBRL by using a single table. In turn, the company may decide to use that single table next time for the traditional financials.     

Although presentation questions may be distinguished from the conceptual and definitional concerns Mr. Proestakes describes, the larger issue is the same, namely, the impact that creating XBRL exhibits has on traditional financial statements. The process forces (or, more optimistically, enables) accountants to think about their financials and the underlying accounting in fresh and useful ways. When mapping line items to XBRL elements, questions arise: What exactly does this line item include? How do we best define it for XBRL purposes? How do other companies in our industry treat this item? Why do we treat it differently? And, based on our answers, should we change the underlying accounting (e.g., reclassify transactions) to make our statements more comparable and better reflect GAAP?
 
This potential for improvements to the financial statements and the accounting process may be little solace for overburdened CFOs who consider XBRL exhibits just one more regulatory burden of questionable value. But as with other requirements (for example, Y2K audits) that companies have had to meet, the XBRL mandate will yield unexpected benefits. After the initial hurdles of XBRL filing are passed, CFOs may just find a few pleasant surprises in the cost/benefit calculation.

 NOTE: Constantine Proestakes is a Mr., not a Ms.. I apologize to him for the error in my original post.  

A Collection of Inline XBRL Resources

Written by Bob Schneider
Posted on July 3, 2010 Comments
July 3, 2010 | General | Bob Schneider

Written by Bob Schneider     Posted on July 3, 2010

In the past several months, Inline XBRL (or iXBRL) reached two important milestones. First, it was jointly adopted by HMRC, the UK tax authorities, and Companies House, the UK’s registrar, for filing company tax returns and accounts. Second, in May, XII announced that the Inline XBRL Specification had been approved as an XBRL International RECOMMENDATION.

In addition, in his speech at the Rome XII Conference, Walter Hamscher, Manager, Technology and Taxonomies in the SEC’s Office of Interactive Disclosure (OID), said that he was “very excited” about Inline XBRL and “very heartened” by its adoption by UK authorities. It certainly seems Inline XBRL will receive close attention at the SEC in future adoptions of XBRL technology.

Given the expanding use and heightened interest in Inline XBRL, I have collected several resources for easier research and reference.

John Turner of CoreFiling recommends two posts on the Hitachi blog for learning what Inline XBRL is and, needless to say, I wholeheartedly concur. The first is an interview with Walter Hamscher from July 2008, questions 9 and 10. The second is a piece by Andy Greener, Senior Enterprise Architect at HMRC. 

Next, I would urge you to spend some time with the webinar Evan Lenz gave in March, now archived at XBRL.org.  For whatever reason, I couldn’t get the Windows Media stream to work; but I clicked the “download the presentation…” link, and locally it ran fine. Here are the time markers for the five main sections:

1. (2:38) What is XBRL?

2. (7:54) What is Inline XBRL?

3. (11:00) Why Inline XBRL? [Why not just use regular XBRL?]

4. (35:25) Getting started with Inline XBRL [Inline XBRL tools]

5. (43:00) Q&A

The webinar runs about an hour; if you’re familiar with XBRL, you can probably skip the first eight minutes, and the 15-minute Q&A at the end may not be essential. But Sections 2 and 3, the heart of the discussion, are terrific, not least because Mr. Lenz discusses his own initial “Do we really need this?” skepticism and then relates how he came to see the usefulness of Inline XBRL. 

Other useful resources:

1. The Inline XBRL page at XBRL.org, which has the RECOMMENDATION (Primer, Specification, Schemas, Background, and Use Cases) and other documents;

2. Inline XBRL resources at HMRC, which can be found using this search.  Among the items listed are the documents XBRL-- when to tag, how to tag, what to tag and the technical Style Guide.

3. The series on Inline XBRL at the Insight blog of CoreFiling.

4. Articles by Dianne Mueller, including Making the Case for Inline XBRL and To Render or Not to Render XBRL, as well as an interview she did on the topic.  

5. The article Inline XBRL – An Introduction on Mike2.0.

Finally, a few months ago there was a fascinating thread on Yahoo’s XBRL-Public group. Titled Building an inhouse XBRL viewer, it began as a conversation on viewing SEC filings; the discussion soon became wide-ranging, however, with Inline XBRL being among the principal topics.

Below I have identified all the messages with at least some mention of Inline XBRL by author. That’s not overly useful; but if you read Andy Greener’s posts, including his quoted text from other authors, you’ll get most of the important content on Inline XBRL. (For guidance, I've attempted to include the authors' affiliations; some authors might want me to add that the opinions they express are only their own. Also, I’ve listed the messages from latest to earliest; you may want to start the other way.)  

Andy Greener (HMRC) 5227, 5219, 5212, 5202, 5201, 5200, 5178, 5153 5149, 5145, 5139, 5136

David vun Kannon (KPMG) 5224, 5222, 5208, 5205, 5204, 5196, 5163, 5151, 5147

Charlie Hoffman (UBmatrix) 5221, 5220, 5215, 5187, 5165, 5144, 5142

Rick Beddoe (Merrill)  5217, 5171, 5164, 5148

Phillip Allen (CoreFiling) 5223, 5207, 5143

Cliff Binstock (XBRL Cloud) 5193, 5166

Jeffrey Ferguson 5218, 5137

Louis Matherne 5170, 5150

Dan Roberts (RAAS Consulting) 5197, 5179

Hugh Wallis (XBRL) 5225, 5140

Peter Calvert (XBRL UK) 5184

Roland Hommes (Rhocon) 5180

Evan Lenz (Lenz Consulting Group) 5240

Antonio Willybiro 5134