XBRL US and AICPA Create XBRL Certification Program

Written by Tammy Whitehouse
Posted on August 15, 2012 Comments
August 15, 2012 | General | Barron King

The American Institute of Certified Public Accountants and XBRL US have collaborated to create an XBRL certification program for accountants and preparers who are working with XBRL. The 30-hour online course is intended for public company accountants, external accountants who work with public companies, consultants, and service providers to give them some basic training in working in XBRL.

“This is intended to help our members in business and industry who are doing actual filings, as well as those in public practice who might be asked to provide XBRL services,” said Ami Beers, senior technical manager of XBRL and business reporting for the AICPA. She said XBRL US and the AICPA decided on an online format for the course to meet the needs of those taking the course but also to facilitate a hands-on approach. “This market has a lot of time pressures, and there’s not a lot of extra time to leave the office and go to outside training,” she said. “It’s also very hands on, so they can get the look and feel of what they would be doing in preparing XBRL filings.”

Content for the course was developed by XBRL US, the AICPA, and the Financial Accounting Standards Board, which maintains the U.S. GAAP Taxonomy, with additional input from accounting firms and XBRL service providers. The course content will focus on the basics of XBRL and the U.S. GAAP Taxonomy as well as detailed footnote tagging.

The AICPA and XBRL US said research among its members suggests there is a clear market demand for online training, especially among preparers of financial statements who are still learning the ropes of XBRL. “When we did our surveys among both memberships to see if this is something that would interest them, we got an overwhelming response that people really needed this type of information and education,” said Beers.

XBRL International has developed a similar certification program that covers a broad range of topics from an international perspective. XBRL International describes the program as an intensive training and exam process meant to prepare stakeholders at all levels to understand the implications of using XBRL to meet business objectives. “The content (for the U.S. certification) is completely different from the international content,” said Beers. “This will go into more detail in tagging financial statements and how to tag using the GAAP taxonomy.”

Given how new XBRL still is, Beers said she is hopeful accountants and preparers will take advantage of the program to continue to improve the quality of XBRL submissions. “We keep hearing about data quality from the Securities and Exchange Commission and that there are errors occurring in the filings,” she said. “Education will help that.”

Those who participate in the U.S. certification program will be eligible for continuing professional education credits. The program is expected to launch in the first quarter of 2013.

 

 

 

 

Matherne Explains Taxonomy Changes in Proposed 2013 Release

Written by Tammy Whitehouse
Posted on August 8, 2012 Comments
August 8, 2012 | General | Barron King

The Financial Accounting Standards Board has published its proposed 2013 U.S. GAAP Taxonomy. While attending the XBRL US Conference in Austin, Texas, Sept. 10-12, Louis Matherne took some time to talk about the changes. Matherne is the Director of Taxonomy Development at the FASB.

Can you tell us about the most significant changes to the GAAP Taxonomy for 2013?

When we updated the GAAP Taxonomy last year, we recognized all filers would be coming on board with that release and doing their full detailed tagging, so we worked very hard to get through as many changes as possible. We knew it would be important to look at changes going forward much more carefully -- validating and revalidating to assure it’s absolutely necessary to make changes going forward because we know how it impacts filers. We are mindful of that. We measure it, and we consider how many filers are affected by a specific change to assure the change is worth it for the value it brings.

With that in mind, we must update the Taxonomy for any accounting standards updates, and there were only a few ASUs that came out this year, so we picked those up with this release. There were new rules on balance sheet offsetting, accounting for costs associated with insurance contracts, and refundable advance fees for certain health care entities. We know there are others that are or will be final before we finalize this Taxonomy, and we will pick those up in the revision process. We will expose those in some fashion so folks can see what we are doing with that.

We’ve also removed all references to accounting standards that predate the Accounting Standards Codification, so all accounting standard references going forward will refer only to the ASC.

Can you explain the changes that are based on common reporting practices?

As the Taxonomy matures and stabilizes, we expect this to become less of an area of emphasis. Over the past year, we have received and addressed more than 1,000 individual comments from constituents, our Taxonomy Advisory Group, and the best practices committee at XBRL US. We identify many issues that become projects. One of them, for example, was focused on segment reporting. We put some considerable effort into understanding the problems that filers were having in this area, and we came to recognize filers were presenting information in a variety of different ways. As a result of diversity in practice, we are seeing inconsistent and different types of tagging for disclosures. As a result, we focused on developing a model that would accommodate all disclosure practices for segments and assure we’re including that framework within the Taxonomy.

We also have recognized, especially over the past several months, that we need to provide preparers with some implementation guidance so they have a clearer picture of our intention. Our goal has always been to assure the Taxonomy will convey that as best as possible, but the reality is we can only include so much information in the Taxonomy. We have determined we will publish implementation guidance for segments, and we are looking at developing guidance for other areas as well, such as shareholders equity and subsequent events.

It’s also important for preparers to know that the Securities and Exchange Commission no longer supports the 2009 Taxonomy so any elements that are deprecated with the 2009 release are now removed from the Taxonomy. Any filer that has not made the changeover or is still using 2009 deprecated elements will need to pay attention to that. When they go into the 2013 release, the elements won’t exist, and that will break their filing.

Can you characterize how significantly the Taxonomy is changing in 2013?

We don’t have data on this, but I would say relative to the changes in 2012, I would think this is going to be less material than in the prior cycle. The volume of ASUs is lower this year than last year.

 

FASB, SEC Proposed New Taxonomies

Written by Tammy Whitehouse
Posted on August 1, 2012 Comments
August 1, 2012 | General | Barron King

The Financial Accounting Standards Board and the Securities and Exchange Commission have published some new taxonomies, and they’re looking for feedback on both.

FASB has published a proposed 2013 U.S. GAAP Taxonomy to update the current taxonomy for a number of new accounting standards and common reporting practices. In the area of accounting standards, the Taxonomy has been updated to reflect the following changes in GAAP that have occurred since the 2012 Taxonomy was finalized:

  • Balance Sheet (Topic 210): Disclosures about Offsetting Assets and Liabilities (2011-11);
  • Health Care Entities (Topic 954): Continuing Care Retirement Communities— Refundable Advance Fees (2012-01); and
  • Financial Services—Insurance (Topic 944): Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts a consensus of the FASB Emerging Issues Task Force (2010-26).

FASB said it also has issued ASU No. 2012-02, Intangibles—Goodwill and Other (Topic 350) but the proposed taxonomy does not incorporate those changes. The board also anticipates other accounting standards updates to be issued in the next 60 to 90 days that may still be incorporated into the 2013 Taxonomy before it ultimately is finalized.

Other changes to the 2013 taxonomy include changes to reflect common reporting practices that FASB notices in company filings, correction of errors and rationalization of duplicated concepts, and updated modeling of existing taxonomy structures and other architectural changes. FASB said some of the changes were made in an attempt to minimize the effect on instance documents that are prepared using prior versions of the taxonomy and at the same time minimize the effect for users and systems that rely on the instance documents.

FASB says it has provided a complete list of all proposed changes from the 2012 to the 2013 taxonomies in the appendices to make it easier for users to make the transition. Even easier, FASB has posted the listing of changes in a worksheet format.

FASB is accepting comments on the proposed taxonomy through Oct. 29 and hopes to have it finalized with approval of the Securities and Exchange Commission in early 2013.

The SEC, meanwhile, is busy with a taxonomy of its own. The SEC recently adopted new rules requiring companies in the “resource extraction” business (oil, gas and other mining) to file form SD to disclose payments to the U.S. or any foreign government related to commercial development of oil, natural gas, or minerals. The SEC is requiring entities to complete the filing using XBRL, so it created a draft taxonomy to facilitate the filing.  The taxonomy is open for public review and comment through Oct. 31.

Singapore Study: XBRL Lowers Capital Costs and Increases Stock Liquidity

Written by Tammy Whitehouse
Posted on July 25, 2012 Comments
July 25, 2012 | General | Barron King

singapore studying

Companies that file financial statements in XBRL are showing lower equity capital costs  and increased stock liquidity, according to the findings of a recent study from the National University of Singapore.

In a study of more than 11,000 observations across 2,300 companies from 2003 to 2011, the researchers said companies that file in XBRL get increased analyst coverage after they adopt. They also get more accurate forecast and forecasts that are more narrowly dispersed. Investors also get a reduced cost for processing information.

To construct the cost of equity measurers, researchers relied on four different methods established in earlier studies from 2001 to 2004. They performed multivariate analysis by regressing companies’ cost of equity capital as an indicator for XBRL adoption, along with other common determinants of the cost of equity capital. They found a 60-basis-point decline in the cost of equity capital after XBRL adoption.

Titled “Does XBRL Adoption Reduce the Cost of Equity Capital?,” the study says the effects are more significant for smaller companies, high-growth companies, and companies that may have had illiquid stock or low analyst coverage before adopting XBRL. The effects are less significant, however, for voluntary early adopters, probably because their adoption came before increased analyst coverage and the improved research capability that XBRL creates.

According to the authors -- Oliver Zhen Li, Yupeng Lin, Chenkai Ni -- the study presents “strong evidence supporting the argument that information processing cost affects the cost of equity capital.” The paper establishes a link between information processing costs and asset prices on the one hand and the economic consequences of improved financial reporting practices on the other hand. In other words, investors reward companies that produce good information.

The authors say the study also establishes evidence that explains the economic consequences of XBRL adoption. “Significant concerns have been raised over the cost versus the benefit of the interactive data,” the researchers wrote. “Our study highlights the benefit of XBRL adoption by showing that firms experience a significant reduction in the cost of equity capital after XBRL adoption.”

Finally, the study also makes it clear that the benefits of XBRL are there because it is mandatory and wouldn’t necessarily be present if XBRL were optional. “As the voluntary program allows too much flexibility for filers, it does not generate enough reliability and timeliness for the interactive data filings, and the cost of equity effect is weaker for voluntary filers than for mandatory filers,” the authors wrote in their report. “Our evidence supports the SEC’s mandate that all firms be required to conduct interactive filings.”

 

Data Transparency Coalition Pushes XBRL As Solution to U.S. Government Data Reform, Part II

Written by Tammy Whitehouse
Posted on July 18, 2012 Comments
July 18, 2012 | General | Barron King

Hudson Hollister is founder and executive director for the Data Transparency Coalition, a trade association that is calling on the U.S. government to reform its collection, handling, and reporting of data, specifically to encourage federal agencies to publish their data online using standardized, machine-readable, nonproprietary identifiers and markup language. He is a believer that XBRL is the leading solution to achieve such reform.

It was an enormous undertaking to create taxonomies for financial reporting. How would those be created if the government were to adopt XBRL for other data reporting purposes?

The taxonomy that was developed for GAAP is gigantic. I can’t think of another one that would be that big. U.S. accounting is so diverse, but there’s no other reporting need I can think of that would require so many data elements or where extensions would be used so much. As federal agencies would adopt data transparency policies, there would be separate considerations for each circumstance as to who would set data standards and how it would be done.

Are you supporting the DATA Act?

Definitely. The DATA Act would introduce government-wide recipient reporting, and it would require federal agencies to report all obligations and disbursements. The Treasury Department would be required to report all expenditures, and a single web-based transparency portal would publish all three categories of spending information. Plus, it would impose consistent data identification codes and markup languages. It wouldn’t require any particular data standard, so it would not mandate XBRL as the markup language of choice. It would only say that there ought to be a standard. It passed the House of Representative unanimously in April and it was under consideration in the Senate Committee on Homeland Security and Governmental Affairs before the Senate left for the August recess. With the full agenda Congress faces in September and the November elections, it’s hard to say whether it will pass in Congress this year. But if it doesn’t, there’s a lot of enthusiasm for it into next year and beyond.

 

Data Transparency Coalition Pushes XBRL As Solution to U.S. Government Data Reform, Part I

Written by Tammy Whitehouse
Posted on July 11, 2012 Comments
July 11, 2012 | General | Barron King

Hudson Hollister is founder and executive director for the Data Transparency Coalition, a trade association that is calling on the U.S. government to reform its collection, handling, and reporting of data, specifically to encourage federal agencies to publish their data online using standardized, machine-readable, nonproprietary identifiers and markup language. He is a believer that XBRL is the leading solution to achieve such reform.

Hudson, what is the Data Transparency Coalition trying to achieve?

The Coalition is pursuing reform for the federal government’s data, and its the only association specifically for that purpose. There are other associations that represent the interests of the technology industry or that support government transparency, but there’s a gap between those objectives. In order for the government to utilize big data search tools, it needs to standardize its own data. That’s what we are advocating. We are hoping to persuade the government to adopt standard identifiers and markup language for data and to publish data -- and not just financial data. The government generates data about health, spending, performance tracking, regulatory activities, information on regulated entities, and more.

XBRL has been used so far for financial reporting. How can it be used for these other types of reporting?

The Securities and Exchange Commission’s adoption of XBRL has been the single biggest data transparency experiment every conducted, and it’s been successful. We’ve seen that it is reducing the cost of capital for companies because it’s cheaper for an analyst to follow a company. We’ve seen that XBRL makes financial filings more transparent for the markets and easier for regulators to use for enforcement purposes. Ultimately, it’s better for everybody.

We’re also interested in XBRL because it is the only XML variant that is optimized for financial information, and it’s the only one that’s been adopted widely by governments around the world. That doesn’t mean there aren’t comparability problems between different models. We still have different accounting rules, like U.S. GAAP and IFRS, so those are very different models. Eventually we need to figure out a way to address that, but there’s nothing else out there that is as advanced as XBRL as a way to standardize data.

 

 

 

Interview with Ariel Markelevich, Part II

Written by Ariel Markelevich & Tammy Whitehouse
Posted on July 4, 2012 Comments
July 4, 2012 | General | Barron King

Ariel Markelevich, Ph.D., CMA. Associate Professor of Accounting, Suffolk University.  Co-chair, Technical Working Group, XBRL Advisory Committee, Institute of Management Accountants. Part I of the interview can be found here.

Most companies would say their staff is already stretched in complying with the regulatory requirement. How can they go beyond that to make better use of the information?

That is a valid point. I’m certainly aware of the burden, but it’s clear that XBRL is not going anywhere. That becomes more and more clear as we move down this path of XBRL adoption. That doesn’t come as any relief to those who are strained by the XBRL requirement, but if they most comply, the may want to treat it as an opportunity to make some changes. Now is the ideal opportunity as they may be designing information systems and information flow as a result of the requirement. I know it is easier said than done, but if a company can go back to its information flow and look for where in the company there is information that is used in several places within the company, then maybe there’s a way to unify the tagging of information so that it can be accessible in those different places. It may be more efficient.

Can you give an example of where it might be more efficient?

Let’s consider inventory. When a company purchases inventory, it later becomes a cost of goods sold. We need the same information in financial reporting and in managerial accounting to determine the cost of the products that are sold. Overhead is another example. There may be any number of instances where the same information is being rekeyed or re-entered into the system throughout the organization. If a company is fairly complex and has several different information systems, then it may not be practical to or beneficial to integrate the external reporting and the managerial accounting functions. But there are cases where an information system would lend itself to this type of integration.

 

Ariel Markelevich will discuss these and other XBRL issues during an upcoming webinar Sept. 7.: http://www.knowledgecongress.org/event_2012_XBRL.html

 

Interview with Ariel Markelevich, Part I

Written by Ariel Markelevich & Tammy Whitehouse
Posted on June 26, 2012 Comments
June 26, 2012 | General | Barron King

Ariel Markelevich, Ph.D., CMA. Associate Professor of Accounting, Suffolk University.  Co-chair, Technical Working Group, XBRL Advisory Committee, Institute of Management Accountants


Your research focuses on how XBRL is regulated in different countries. How does the U.S. approach compare with the approach in other countries?

The approach of the Securities and Exchange Commission in the United States is to take very little control over the process of converting financial data to the XBRL format. In other countries, regulators are a little more hands-on with the conversion of data into XBRL. Some, for example, might require companies to ask permission to create extensions so regulators can decide whether an extension is truly warranted and decide beforehand which extensions are necessary and appropriate. In Israel, regulators are taking the XBRL conversion completely upon themselves. They take the data submitted by companies in traditional formats and perform their own conversion to XBRL. The United States is not taking such a hands-on approach, choosing instead to make companies fully responsible for the conversion of their financial data into XBRL.

Some companies might prefer to be spared the burden of the conversion process. Are there benefits to performing the conversion?

Yes, there are benefits. In most companies today, financial data is managed in silos, and the people that operate in those silos are not fully aware of how the information they manage is used by other people in the organization. In most companies, the XBRL conversion is managed by finance staff as a bolt-on exercise after the financial statement close to comply with the SEC’s XBRL requirements. The information is used heavily by finance staff, but it’s also used extensively by management accountants for purposes of cost accounting, and likely by many others in various capacities throughout the organization. It would make a lot of sense to integrate the information flow between the financial accounting and managerial accounting staff to make better use of the data in the XBRL format. It is a missed opportunity for many companies.

 

Ariel Markelevich will discuss these and other XBRL issues during an upcoming webinar Sept. 7.: http://www.knowledgecongress.org/event_2012_XBRL.html

 

 

Study Suggests CFOs Aren’t Focused on XBRL for Internal Reporting

Written by Tammy Whitehouse
Posted on June 19, 2012 Comments
June 19, 2012 | General | Barron King

A recent Gartner study on behalf of Financial Executives International suggests finance staff generally view XBRL as an external reporting requirement and show little interest in pursuing use of XBRL-formatted data for internal reporting purposes, leaving IT staff open to take the lead.

The 2012 FEI Technology Study says only about 2 percent of CFOs in the sample group see XBRL as a vehicle for internal reporting, while only 3 percent see that it can be used to supplement some internal reporting. The study confirms there still are various approaches in play for how companies address their XBRL reporting requirement. Nearly 40 percent outsource their XBRL tagging and filing processes while an equal number are planning to adopt a disclosure management solution that embeds into another document format. The study says 20 percent of organizations plan to acquire an XBRL tagging solution only, while 9 percent will manage the tagging requirements in another document format.

In Gartner’s view, the results suggest companies are taking a minimal approach to XBRL, using it only to the extent required by the Securities and Exchange Commission for filing of their financial statements. "The benefits of XBRL-enabled financial information system should be clear -- summarized financial information across multiple accounting systems, and reduced reliance on financial consolidation systems to provide consistent in-process financial reporting,” Gartner writes.

The research group surmises finance organizations may be so stretched in scope that they have little opportunity to consider any further use of XBRL-formatted data or XBRL technology beyond the minimal required uses. “Based on our study, finance will not drive a more revolutionary approach to XBRL, so IT must monitor what its ERP and corporate performance and disclosure management vendors offer for XBRL in their road maps, and should ensure that their finance organizations exploit these capabilities where possible,” Gartner writes.

The study says 42 percent of organizations using disclosure management software see a decrease in financial statement prep time, with 28 percent saying it decreased their prep time by 10 percent or more; 48 percent said they saw no change in preparation demands. Gartner says it believes the benefits include producing financial statements in a more controlled and auditable environment, although it also concedes that the results suggest applications are still evolving.

Maryland CPAs, Sold on XBRL, Launch Center to Advance Technology

Written by Tammy Whitehouse
Posted on June 12, 2012 Comments
June 12, 2012 | General | Barron King

scissors

Maryland accountants are drinking the XBRL kool-aid as they look to XBRL and structured financial data to create more transparency, more accountability and improved performance management.

The Maryland Association of Certified Professional Accountants recently adopted XBRL for its own uses, turning the group’s finance director, Skip Falatko, into an XBRL believer. “Standardizing our data with XBRL allowed us to re-think our data stores and re-deploy technology to liberate data in a way that makes it more accessible, transparent, and much, much more powerful to analyze in an almost real-time way,” he said. “This allows our team to be able to make informed, data-driven decisions in a real-time way. Structuring the data and giving it context via machine-readable tags, it can be accessed in a whole new way that allows us to tap the wisdom of the crowd.”

The accounting group has launched a center to share best practices, education and support for innovative applications of standardized financial data. The “Center for Transparency, Performance Management and Accountability” held its first session recently and identified five important ways that XBRL and structured financial data could help achieve its purpose.

Most notably, it meets the needs, even the mandates, of financial information users, like the Securities and Exchange Commission and the Federal Deposit Insurance Corp. It also increases transparency and accountability in the capital markets broadly. It also facilitates open government reporting, facilitating initiatives like the Digital Accountability and Transparency (DATA)  Act and health care reform, or even government spending data for citizens.

The new center also notes that XBRL would reduce the compliance and reporting burden to federal and state governments by standardizing business reporting. But the benefits aren’t all focused on the external stakeholders. It also improves performance management, producing more transparent internal business reporting that facilitates better management based on key performance indicators.

The Maryland CPA group says the center will provide a central place to facilitate the sharing of best practices and lessons learned. It also will help support the innovative applications of standardized financial data, giving companies and their accountants even more cutting-edge approaches to consider.

The group says it has developed its own application of XBRL internally and is working with the Financial Accounting Standards Board to develop an XBRL Taxonomy specifically for not-for-profit entities. The group also is working with Congress to help support the DATA Act.

 

 

Can Disclosure Templates Lay Foundation for XBRL?

Written by Tammy Whitehouse
Posted on June 6, 2012 Comments
June 6, 2012 | General | Barron King

Imagine there were templates available for your most common disclosures that must be tagged in XBRL. Would it make the tagging and submission of your financial statements easier? Would it provide some assurance that they are correct?

Charles Hoffman thinks so. Hoffman is one of the early pioneers who helped bring XBRL from a science-fiction fantasy to a modern-day reality. He’s working on creating dozens of disclosure templates that are meant to make it faster and easier to assure your XBRL submission is right the first time.

Preparers of financial statements rarely create new disclosures from scratch, said Hoffman. “They cut and paste,” he said, drawing from various sources, including other financial statements, to capture language that has already been blessed by the Securities and Exchange Commission or other regulators with relevant authority. “XBRL takes this to a while new level,” Hoffman said.

In his study of hundreds, maybe thousands, of XBRL submissions, Hoffman has developed a pretty good feel for what a “correct” disclosure should look like in XBRL. It’s a little difficult to be 100-percent certain, he said, since the SEC and the Financial Accounting Standards Board have so far offered little direct feedback or guidance on what they consider to be correct use of the GAAP Taxonomy and correct submission of financial data in XBRL.

Still, Hoffman believes practice is crystalizing based on the experiences of early adopters who have been through the process several times now. “I see filers doing the same thing, and I understand what they are trying to do,” he said. “I’ve distilled a lot of information and packages it into one place -- disclosure templates. They provide a bunch of extremely good clues about how to bottle information in XBRL correctly.”

Hoffman said the templates are a little like Lego structures. He’s assembled all the Lego pieces necessary to build the specific disclosures that are require,d using precisely defined elements common to all financial statements. It’s something of a jumping off point for companies that are new to XBRL, or a way to check or verify existing processes, he said. “It’s useful for companies that have been at this for a while, and for those that are just getting started,” he said.

While Hoffman has produced about 70 or so disclosure templates to date, he sees the potential to create hundreds. “There are as many templates as there are items in a disclosure checklist,” he said. “I’m building a disclosure checklist with a template for every single disclosure in that checklist.”

In deciding which templates to create, Hoffman said he’s following the 80-20 rule, seeking to produce the most critical 20 percent of templates that will be useful to 80 percent of companies. “I will have a high percentage of the disclosures that people commonly use in very short order,” he said. “I know what they are. This will be for the 80 percent of companies that are more alike than they are different.”

The templates are freely available through Hoffman’s blog, and he’s starting to sense software producers are taking note. As software applications continue to mature, he expects disclosure templates to become standard fare.

 

 

A Practical Approach to Selecting a Disclosure Management Solution: A Primer for SEC Reporting Teams, Part III

Written by Jerry Behar
Posted on May 28, 2012 Comments
May 28, 2012 | General | Barron King

 

Continued from Parts I and II...

4. How do you assess the ROI and how does it compare to initial expectations?

While soft cost considerations are important, I have noted a higher focus on third-party direct costs which ultimately misses much of the broader value proposition.

  • Initial cost—license fee, set-up, XBRL conversion, hardware and related IT costs
  • Recurring costs—maintenance, subscription fee, XBRL services, etc.
  • Discontinued direct costs—document/ change management, rush fees, EDGARizing, filing, XBRL services, etc.

In many cases, the discontinued third-party costs more than offset the fees and costs related to the disclosure management solution

Note that some of these costs hit legal or other budgets and may not be easily visible to the reporting team.

  • If the disclosure management solution expenditures exceeded discontinued or replaced costs, was this deemed to be a good investment from a financial perspective?
  • What were the soft cost implications? Some examples are reporting and IT investment in implementation, re-deployment of team resources to other projects due to shorter reporting cycles, improved morale, lower turnover, increased competency and self-sufficiency, reduced reliance on third parties, reduced risk profile, deemed value of accelerated reporting calendar, etc.
  • What was the structure, length and flexibility of the commitment?
  • Does the pricing vary depending on the number or type of filings or activities or is it time-based or dependent on the number of users?

Other common uses include the earnings release, earnings call script, board reports and statutory reporting.

  • SaaS solutions are available for as little as three-month rolling contracts with the ability to output all of the data on demand. Some solutions require multi-year commitments or imply a multi-year commitment due to the up-front cost.
  • How flexible is the pricing to expand or reduce the number of users and were subsequent price changes, if any, in line with expectations?

5. Has your company expanded the use of the disclosure management solution?

Most companies start with the 10-Q and 10-K but quickly expand to 8-Ks, proxies and other ’33 and ’34 Act filings the earnings release, earnings call script and statutory reporting. Expanded use cases may include internal reporting, roll-ups for aggregating external reporting data or analyst communications, contracts, IR, legal, marketing collaboration, etc.

There has historically been a high level of consistency among registrants in the process for compiling reports for the SEC. Comprehensive discussions with peer companies can provide valuable insight into the solution attributes that contribute the most to real process improvements. Even companies that compete with each other are generally willing to collaborate on regulatory issues. It is too late to make any major process changes for the June quarter, however registrants are encouraged to observe which solutions are used by companies that have an easier and faster filing process and which are used by companies that have an easier and faster filing process and which are used by companies with more challenging filing processes. The December 10-Ks are around the corner and it’s not too late to plan for them.

 

A Practical Approach to Selecting a Disclosure Management Solution: A Primer for SEC Reporting Teams, Part II

Written by Jerry Behar
Posted on May 21, 2012 Comments
May 21, 2012 | General | Barron King

Part I found here...

If you could only ask only one question in reference checking a disclosure management solution, this is it:

1. How satisfied are you with your disclosure management product and services?

A comprehensive answer to this question should address both product and services and will generally touch on all of the other attributes that you want insight into.

In short, would they make the same decision again? What do they know now that they wish they had known when the disclosure management solution was selected? What has been the major impact vs. the prior reporting approach? Did the implementation process go as planned and was the solution easy to use and deploy? Have there been regular upgrades? How hard or easy has it been to learn and use the software?

As reporting teams are increasing their XBRL competency, the availability of dedicated or periodic XBRL support is essential.

The level of competence in XBRL and in particular, experience with detailed tagging varies considerably among solution providers – and matters a lot. There are also significant differences in the business models of support teams, from a US based specific individual with personal responsibility for your filings, to call centers and distributed models where the actual work is distributed amongst teams around the globe. As reporting teams are increasing their XBRL competency, the availability of dedicated or periodic XBRL support is essential.  Long term, the level of reliance on XBRL services will depend on your company’s philosophy towards achieving self-sufficiency as well as the stability of your team and consistency of your documents.

Service model differences also impact the satisfaction rates for product implementation and ongoing support services.

Software and hardware product architecture also really matter. Product architecture affects collaboration - in particular, cloud-based solutions enable collaboration with colleagues inside and outside the firewall. The level of software integration also greatly influences the user experience.

If the person providing the reference needs some prodding, move on to questions 2 through 5.

2. What was the impact on the SEC reporting process?

Most companies assess this based on:

  • The change in the number of days to file and the change in the gap from the earnings release to 10-Q and 10-K filing
  • The impact on the team resources required to complete the filing
  • The ability to gain control over the entire process including the ability to make last minute changes to both EDGAR and XBRL and eliminate or reduce dependence on outside resources for EDGARizing, XBRL and filing

Note that the change in filing dates after adopting a disclosure management solution vary considerably. Many companies cut a week or more off their fastest previous filing, some more than 20 days while others have added time to their filings. Filing dates alone do not tell the whole story. Many companies found that they were able to complete their 10-Qs and 10-Ks ahead of schedule in the initial quarters but delayed the filing until after the board meeting scheduled.

  • What parts of the document preparation and filing process were the most streamlined and which parts, if any, were not affected?
  • How has the pencils-down period been impacted?
  • Describe the XBRL QA and validation process.

The ability to reduce the reporting team’s night and weekend hours along with shorter reporting cycle rarely drives the ROI assessment but has a significant impact on the reporting team  and indeed on executive management which can reduce  their time focused on compliance reporting.  Legal and auditor fees may also be reduced with a shortened reporting process.

3. Describe the implementation process.

Many reporting teams actually realize time savings during the initial implementation quarter but implementation cycles vary significantly based on the product architecture, who is performing the implementation and company-specific considerations.

  • How long did it take to get the solution up and running and for your team to be comfortable with it?
  • What were the XBRL transition expectations at the time of implementation?
  • Did the implementation go as planned?
  • In hindsight, what would have contributed to a smoother process?
  • Did outsourcing yield a faster and ultimately lower cost implementation?
  • How was the transition from implementation to production?

It is helpful to understand the factors that contribute to shorter (weeks) and longer (months) implementation period(SaaS vs. client server architecture, outsourced vs internal resources, fast tracked reporting calendar objective, XBRL transition phase, etc. as well as when the implementation took place.  On balance, more recent implementations may be more relevant to your planned implementation.

Part III coming soon...

A Practical Approach to Selecting a Disclosure Management Solution: A Primer for SEC Reporting Teams, Part I

Written by Jerry Behar
Posted on May 14, 2012 Comments
May 14, 2012 | General | Barron King

The June 2012 quarter marks the final phase-in for XBRL reporting which requires roughly 6,500 accelerated, non-accelerated and smaller reporting company filers (Tier 3 filers to join the 1,500 large accelerated filers already submitting detailed XBRL reports. High dissatisfaction rates and frustration with the “pencils down” period (the period prior to the planned filing date when no additional changes are allowed by financial printers and other outsourced XBRL solution providers) has been a major factor precipitating the search for a better alternative.

Over the last two years disclosure management solutions (also referred to as built–in SEC reporting solutions) which automate and streamline the SEC reporting process have become mainstream. There is confusion among some registrants of whether or not to consider adopting a disclosure management solution and how to differentiate various solutions. A framework is provided below for reporting teams to evaluate whether a disclosure management solution is right for their company, and if so, which solution they should choose based on the results and experience of peer companies.

Disclosure management solutions more or less encompass a fully integrated SEC reporting process which addresses the collaborative drafting of the document and XBRL and may include integration with ERP systems, EDGARizing, and filing with the SEC. The significant reduction in time, resources, and money required along with the ability to control the entire reporting process contribute to the high adopting rates. Disclosure management solutions are offered on either a Software as a Service (SaaS) or an “on-premise” client server platform which influences the cost structure,   IT support required, time to implement  and accessibility among team members inside and outside of the firewall.

The various solution providers may contribute to the market confusion in their effort to maintain or grow their customer base. Providers often aim to differentiate themselves by focusing on product features and functions or perceived weaknesses in competitor offerings Many SEC reporting directors who undertook a diligent review process with a prioritized list of system requirements, concluded a few months later that some of the highest ranked feature requirements in the evaluation phase were unimportant. An evaluation approach, which focuses on organizational results and user experience, provides a broad perspective and protects against overemphasizing features that ultimately will have a minor impact.

There is now sufficient experience in the market that the limited number of disclosure management solution providers (along with legacy EDGARizer and XBRLsolution providers) should be easily referenced and not just from the hand-picked references given to you by the solution provider. Your peers at other companies are the best source of information about the solutions they are using as well as the solutions they stopped using or are planning on stop using.

Tier 3 filers are strongly advised to check references with large accelerated filers who already use detail tagging.  There is a big step up from first year XBRL tagging and Tier 3 filers will gain insight regarding the detailed filings that they will soon be submitting. The SEC Professionals Group (www.secprofessionals.org) provides an excellent forum for independent reference checking.  A confidential contact list of its 2,500+ members (membership is limited to in-house individuals focused on SEC reporting -- there is no cost to join) is accessible to members who are encouraged reach out to each other on topics of mutual professional interest. Quarterly SEC Professionals Group meetings across the country also provide a venue for informal peer-to-peer discussion.

Part II coming soon...

by Jerry Behar

SEC’s Starr on the Next Big Hurdle for XBRL

Written by Tammy Whitehouse
Posted on May 7, 2012 Comments
May 7, 2012 | General | Barron King

As thousands of public companies are beginning the final march toward their first-ever detail tagging under XBRL Mike Starr, deputy chief accountant at the Securities and Exchange Commission, is looking ahead to what more must be done to drive greater acceptance for XBRL.

At the recent IFRS Taxonomy Annual Convention, Starr said XBRL stakeholders need to work toward an important goal to reach the “final destination” of the XBRL journey. That is, assuring investors are able to view and use XBRL-formatted information using the same software application and process, regardless of which XBRL financial reporting taxonomy is used and regardless of what the underlying content is.

“Today, that is not possible,” Starr said. “Consequently, I believe it is imperative that future XBRL taxonomy development efforts give due consideration to the needs of investors.”

In the United States, companies are required to use an SEC-approved taxonomy to format their financial statements in XBRL and submit them with the SEC. The SEC has approved a taxonomy for companies that follow Generally Accepted Accounting Standards, but it has not yet approved a taxonomy for foreign private issuers who follow International Financial Reporting Standards. That means IFRS filers in the United States are exempt fomr the requirement to submit their financial statements in XBRL.

Starr is often asked when the SEC will approve an IFRS taxonomy. “The short answer is we don’t know,” he said. “There are taxonomy design differences between the US GAAP taxonomy and the IFRS taxonomy that prevent users from using the same application and process to consume data from either taxonomy. He said FASB and IFRS teams working on taxonomy development are working on a solution.

Starr said the SEC’s deferral on approving an IFRS taxonomy is not a reflection on the quality of either the latest IFRS or GAAP taxonomies. “The differences between the two taxonomies can represent different, but equally acceptable, technical design choices,” he said. “Ultimately, design choices can be a delicate balancing act between the burden to the preparer to tag the information and the benefit to the investor derived from efficient access to the data.”

The challenges for the future shouldn’t detract from the achievements to date, Starr said. In the U.S. financial reporting arena alone, more than 9,000 companies are filing XBRL-formatted information across 35,000 filings, producing more than 18 million discrete financial facts.

And companies have improved their use of the taxonomy, he said. The SEC has called on companies to make more careful tax selections and reduce their use of extensions, which reduce comparability. In the past year, Starr said, extensions used in the core financial statements fell from 11 percent to 8 percent while extensions for the detail tagging of footnotes declined from 26 percent to 17 percent.

 

 

As DATA Act Heads to Senate, Advocates Plug XBRL to Meet Mandate

Written by Tammy Whitehouse
Posted on May 2, 2012 Comments
May 2, 2012 | General | Barron King

SenateDataThe Digital Accountability and Transparency Act is headed to the Senate after the U.S. House of Representatives passed the measure to establish a consistent, transparent method for reporting federal spending information and making it accessible to anyone with an Internet connection.

The bill doesn’t mandate XBRL as the medium for gathering and reporting data, but it instructs the Federal Accountability and Spending Transparency Commission, to be formed by the bill, to incorporate existing nonproprietary standards such as XBRL if it’s practical to do so. XBRL advocates, like Barry Melancon at the American Institute of Certified Public Accountants and Campbell Pryde at the XBRL US consortium, are already stumping for XBRL to fill the need.

The DATA Act moved quickly through the House after outrage mounted over a lavish Las Vegas conference staged by the General Services Administration. The bill’s primary objective is to make government spending more transparent to the average American, but it also sets caps for government spending on travel and professional conferences.

Whatever brought it to a quick, unanimous vote in the House, groups like the newly formed Data Transparency Coalition are rejoicing at what it means for the proliferation of consistent data identifiers and markup languages for federal spending information. The Act, if approved by the Senate, will establish a complete, accurate, searchable web-based platform to allow the average American to access current government spending data on the Internet.

In a prepared statement, Melancon XBRL would create “intelligent data” to meet the bill’s mandate for consistent electronic identifiers and markup language. “A tag can be attached to each piece of data in a financial or business report,” he said. “All of the tagged data would be put on one public platform, which would make government spending more transparent.”

Pryde also assured the House knows how free and open XBRL is, and that it was developed specifically to provide the kind of reporting of financial and performance-related information that the DATA Act seeks to establish. “The ability of XBRL to enable greater standardization means that government agencies and the entities reporting to them can leverage the same software and infrastructure from agency to agency, and even more importantly, they can avail themselves of the tools already available on the market today,” he wrote to the House to support the measure. “XBRL is a low-cost solution that needs no further development and can leverage existing market tools, infrastructure and expertise.

The bill begins in the Senate with the Committee on Homeland Security and Governmental Affairs.

 

 

How to Differentiate Disclosure Management Features

Written by Mike Willis
Posted on April 25, 2012 Comments
April 25, 2012 | General | Barron King

Companies are quickly migrating from outsourcing with third party XBRL tagging vendors to built-in application implementations, which are also commonly known as 'Disclosure Management' applications.  With the March 31, 2012 XBRL reports submitted to the SEC's EDGAR over 2,000 companies have made this transition.  As a result of these 'built-in' implementations, leading practice companies are realizing 30%+ cost and time reductions in their report assembly and review processes.

For the companies that are considering Disclosure Management applications, there are some features that may help to differentiate individual application feature strengths and weaknesses as it relates to company specific reporting environment process, controls and diversity of reporting requirements.

Following is a listing of some of the differentiating features reporting professionals may consider when assessing the effectiveness of Disclosure Management applications for their specific and unique reporting environment and corporate culture:

  • Client Server or SAAS - The implementation approach may have an effect on how Disclosure Management applications are used as well as potential access to and security of draft company reports. Client Server implementations typically require engagement of corporate IT Resources where SAAS implementations may require less consideration of internal corporate infrastructure. Certain SAAS-oriented Disclosure Management applications may not enable connectivity to source systems, thereby requiring an incremental manual step to upload relevant source information into the SAAS platform. Further, the nature of the application (e.g. Client Server of SAAS) may also affect license and maintenance costs as well as the timeliness of application updates.  Care should be taken to understand licensing costs for some SAAS applications where costs are associated with report volume; and can appear to be very reasonable when thinking about the problem in the context of three 10-Q's and a 10-K per year and possibly less reasonable when thinking about the hundreds to thousands of compliance reports required by regulators here in the U.S. as well as in countries around the world.
  • Connectivity with the full range of source systems relevant to reporting and quality analysis. How does the Disclosure Management application 'connect' to company consolidation, ERP, spreadsheet applications and other relevant information sources? How easy can reporting professionals connect to the broad range of internal information sources relevant to reporting?
  • Interoperability -- Connectivity with relevant information sources via a semantic XBRL-format interface.  Does the Disclosure Management application 'consume' XBRL thereby enabling reporting professionals to pull information from a broad range of information sources including external sources such as the SEC EDGAR system?  In the short term, the ability to consume XBRL is particularly relevant for those companies looking to streamline their peer analysis and risk assessment processes.  In the longer term, the ability to pull standardized content from a range of internal data stores may be particularly relevant to a broad range of performance management, business intelligence and integrated reporting efforts.
  • Taxonomy Mapping -- automated taxonomy mapping "wizards" that provide suggestions for specific taxonomy elements relevant to specific company disclosures.   More advanced Disclosure Management applications also provide peer company benchmarking on disclosure elements.  Reporting professionals may also want to inquire as to the range of taxonomies for which the mapping wizards apply and how quickly new taxonomy versions are incorporated.
  • Taxonomy Management -- features targeting the import, view, and management of multiple taxonomies relevant for a single report.  Reporting professionals may also want to inquire as how Disclosure Management applications handle unused extension elements and presentation links, the units registry and the timeliness of addressing new taxonomy releases.
  • Rules Management -- features enabling assessment and analysis of various standardized rule bases such as those outlined in the SEC's EDGAR Filer Manual and those developed and maintained by company reporting professionals.  Reporting professionals may also want to inquire as to the collaborative nature of rules with others, both within the company and within the vendor customer base.
  • Collaborative Workflow and Controls -- Empower the entire extended reporting team to collaborate on report disclosures (within a single document or one constructed of document components) in a simultaneous, multi-user process.  Collaborative processes within controlled workflows that enable management oversight and monitoring of widely distributed and authorized professionals who can author, tag, review and edit disclosures.  This common feature empowers reporting professionals to more effectively share and build corporate intellectual property and when desirable collaborate with trusted partners outside of the enterprise (e.g. legal counsel, audit committee members, third party auditors, advisors, etc.).
  • Report management -- Manage a broad range of report attributes highly relevant for reporting professionals including the roll forward of prior period values, metadata, dates, headers, references, etc.; and the synchronization of report disclosures and related metadata used within a single report and/or across multiple reports; and report navigation including ease of disclosure filtering, visualization, reference management, comments and revisions management; and query or search capabilities across disclosure content and related metadata.
  • Presentation management -- Management of a broad range of reporting templates reusing company disclosure information.   Value added features may include a range of reporting formats (e.g. pdf, html, ppt, xls, doc, xbrl, EDGARization, etc.) as well as standardized communication methods including RSS.
  • Reference management -- Identification and management of the explicit relationships between disclosures and relevant standards and SEC Regulations (such as those included within the US GAAP Taxonomy) as well as those within the company such as those relevant to company policies and resources.
  • Analytical Assessments -- Support for reporting professionals to effectively interrogate draft and final reports to identify reporting issues that some investors and analysts may perceive as material errors.  Reporting professionals may want to inquire as to how the Disclosure Management application enables them to more effectively identify common disclosure meta-data issues and make the subjective assessments critical for high quality reports.  This feature is particularly relevant when it enables identification and review of subjective assessments in the presentation context of reported disclosure.
  • Technical Compliance -- Support of the XBRL Technical Specification and periodic updates including the XBRL Inline Specification (iXBRL) which is increasingly the compliance format of choice for regulatory XBRL mandates.
  • Support -- Technical support for users in countries around the world, including taxonomies and rules relevant to specific regulatory agency reporting requirements.  Support would also include languages relevant to professionals working in countries around the world (e.g. English, French, German, Japanese, Mandarin, Spanish, etc.).
  • Solvency II Taxonomy -- support for this taxonomy requiring information disclosures as well as those for risk models and formulas.  This feature is particularly relevant to reporting professionals in the insurance sector and may also be more broadly relevant to reporting professionals looking to collaborate on reporting concepts such as financial and nonfinancial Key Performance Indicators.

While the above is certainly not a complete listing, it does provide reporting professionals with some feature topics that may be useful when considering Disclosure Management alternatives.  When discussing these features with software vendors, it is a good idea to ask questions in the form of "How does the application do XYZ?" question rather than simply "Does the application do XYZ?"  The response to a 'How does' question may allow reporting professionals to gain better insights as to the level of complexity, effort, time, cost for a particular feature rather than a more 'yes' or 'no' response as to the existence of a specific feature.  How does that sound?

Comments to this blog that identify additional differentiating features would be greatly appreciated.

 

by Mike Willis

 

XBRL US Updates Corporate Actions Taxonomy

Written by Tammy Whitehouse
Posted on April 18, 2012 Comments
April 18, 2012 | General | Barron King

XBRL US has published the second release of its Corporate Actions Taxonomy, a digital dictionary of terms describing more than 50 corporate action announcements that companies can tag voluntarily.

The taxonomy covers corporate actions that public companies are required to report and publicize to investors, such as dividends, stock options, mergers and acquisitions. The new release has been updated to accommodate the active ISO 20022 standard for corporate actions announcements and to support the ongoing American Depositary Receipts pilot. It also has been updated to reflect updated XBRL technical specifications.

Companies are not required to tag corporate action announcements in XBRL, but the taxonomy was developed as part of the Issuer to Investor: Corporate Actions initiative launched in 2009 by XBRL US and others to improve data quality and reduce processing cost and time. A pilot program involving an estimated 2,000 ADR banks is under way to test the premise that the use of structured, computer-readable data can streamline the process and introduce straight-through-processing.

“A lot of companies now report these actions in press releases and may eventually tag them,” said Campbell Pryde, President and CEO of XBRL US. “There is a significant amount of money spent collecting this information and getting it right. And yet there are still errors and delays that happen, and it ends up costing a lot of money.” It’s a highly manual exercise for entities downstream from the reporting companies to manage the data that is produced through corporate action announcements, Pryde said.

XBRL could streamline the reporting process for the companies, especially by getting information out faster and with no errors, according to Pryde. It also precludes the possibility that data presented in press releases can be misunderstood or misused.

But the real benefit to tagging corporate action announcements will be felt more by the consumers of the data. “Companies are blissfully unaware of the downstream problems,” he said. “I’m not sure they want to know. But as a result there is a lot of real cost to investors and to society in general. We want to get to point where it is easy for filers to create this so there is no difference between doing it in XBRL or on paper.”

The taxonomy, the related architecture and scope documents, the release details, and sample instance documents are available online for public review through June 15. XBRL US is hoping to get feedback from the financial services community, including brokers, custodians, investment managers, and public companies, as well as XBRL specialists.

“We need to get the taxonomy finished and get the mechanisms and infrastructures in place so companies can start using it,” said Pryde. “Once we have that in place, regulators might say maybe we should use this because it will be beneficial to us and to filers.”

 

Companies Will Cheer In-Line XBRL Option, Expert Says

Written by Tammy Whitehouse
Posted on April 11, 2012 Comments
April 11, 2012 | General | Barron King

If it eventually becomes an option in the United States, in-line XBRL may become “the only thing that saves XBRL from itself,” according to XBRL pioneer/consultant/blogger Dan Roberts.

The Securities and Exchange Commission is testing the waters to see if companies are interested in having the option to file their financial statements in in-line XBRL. In Roberts’ view, they’re more than interested.

“Until there is the ability to file a single report with the SEC, there will continue to be resistance” to XBRL broadly, according to Roberts. “Of course, until the SEC can prove that XBRL is delivering benefits exceeding the cost to business, then there will continue to be opposition.”

In-line XBRL allows XBRL tags to be embedded within an HTML document. Members of the SEC staff, including Deputy Chief Accountant Mike Starr, have begun talking with practitioners about whether companies would like to have a choice between continuing to file HTML and XBRL financial statement separately, or skipping those separate filings and instead filing a single submission via in-line XBRL. It’s already the norm in the United Kingdom, where companies file financial statements and tax returns using in-line XBRL.

In-line XBRL is a natural step in the continued development of XBRL technology, in Roberts’ view, and a necessary step to further drive acceptance. XBRL makes data readable by computers, but it’s rugged on the human eye. In-line XBRL solves that problem. “In the end, if it does not pass the eyeballs test, how can we give assurance that all that data is really what we thought it should be?” he asks.

In-line XBRL enables human eyes to better comprehend the data produced through XBRL, he says. It also would solve a big problem that continues to crop up in XBRL submissions. Companies continue to create extensions in their XBRL filings specifically to produce a specific look to the filing, to make it easier to read and comprehend, even though the SEC has asked them repeatedly to quit doing so.

Tags should be chosen solely based on the definition of the data to be tagged, and extensions should be created solely to describe items so unique a company’s financial statements that none of the thousands of tags in the GAAP taxonomy adequately explains it. Still, some companies continue to produce extensions to correct linear problems that the eyes just can’t reconcile.

Starr has invited companies to share their views on whether they would welcome an in-line XBRL option. You can contact him at the Office of Interactive Disclosure at Ask-OID@sec.gov or 202-551-5494.

 

Applying XBRL to Corporate Actions Requires Paradigm Shift, Part II

Written by Max Mansur
Posted on April 4, 2012 Comments
April 4, 2012 | General | Barron King

The Outcome: 10K/10Q reporting must first satisfy the SEC. Transparency and consistency determines comparability, and XBRL dramatically increases the accessibility of data. The long-term and growing financial reporting database is of enormous commercial analytic value for investors. Corporate actions primarily drive transactions, with some analytical contribution to the front-office buy-side, especially with intra-day announcements. Instead of being targeted to a single consumer, there are hundreds of cascading services to literally millions of investors holding trillions of dollars of investment. Using XBRL, a corporate action announcement can immediately benefit all direct consumers, replacing manual data entry, but it is even more important that the improvement in data quality affects all indirect consumers in the value chain. The timeliness and efficiency gains improve investor confidence and reduce costs.

The Impact: Corporate actions affect all investors in listed equities and bonds, overall market capitalization, and cross-border investments. There are about 45,000 listed companies globally and an estimated US$1 billion of preventable, wasted cost on corporate actions annually. With data available at the source, via XBRL or any other standardized format, interpretation risk is virtually eliminated, consumers’ confidence improves, and transactions have far fewer market claims. Implementing corporate actions within existing vendor tools should be fairly straightforward – tagging is template-driven with few formulae and no rendering concerns. Tools offering collaboration, workflow, and cloud-based management are likely to be successful with corporate actions. The taxonomy minimizes the need for extensions, maintains a linkage to the standard that will be used once consumed by the market, and will stimulate collaboration between consumers and producers.

The adoption of the corporate actions taxonomy in the near term will be incremental, voluntary, and a best practices approach, with a small initial cost bearing a great deal of cost savings and value for the investor and shareholder.

Summary

maxgraph