Monday, October 12, 2009

iXBRL - Don't Panic

Introduction

Companies in the UK will have to submit financials to Her Majesty’s Revenue and Customs (HMRC) via an online process within the next 2 years. I had a session with Ernst & Young about the language to be used called XBRL. I have also attended a workshop at HMRC titled “Company Tax Returns and Online Filing”. This is a summary of my findings and my personal views on the impact.

Overview of XBRL

XBRL stands for eXtensible Business Reporting Language. It is one of a family of "XML" languages which is becoming a standard means of communicating information between businesses and on the internet. (1). iXBRL is a slight derivative of this language which stands for InLine eXtensible Business Reporting Language and allows the data to be read by computers and viewed by humans all from the same file.

Impact

All companies filing tax after 31st March 2011 will have to comply with the requirements of submitting all the data online. This will affect 3 submissions as follows:

  • CT600 – Currently can be submitted via XML and will not change.
  • Accounts – Must be submitted online in iXBRL format.
  • Tax Computations – Must be submitted online in iXBRL format.

What will not change is WHAT you submit, WHO is responsible for submitting it and WHEN it must be submitted, only HOW you submit it will change.

4 Taxonomies will be supported by HMRC but for the first 2 years of implementation only a limited subset of each taxonomy will be required.

Taxonomy

Full Tag Set

Limited Tag Set

UK GAAP

4375

1182

UK IFRS

3400

<1600

UK Common Data

900

900

CT Computational

4548

1350

One is not restricted to the limited tag set but you are only required to at least submit these for the first 2 years. Thereafter the full tag set will be required.

The current versions of the taxonomies can be downloaded from this website.( http://www.xbrl.org/uk/Taxonomies/)

The Companies House and HMRC issued a joint statement on 1st September 2009 stating that they are working together and that both their filing services are being aligned so that a single point of filing can be used.

Software

As with any technology solution we will find many ways of solving this challenge ranging from ERP Supplier based solutions right through to stand-alone file converters. Unfortunately iXBRL is not yet widely used so I have not yet managed to find anything worth taking a look at yet. HMRC is busy reviewing a number of products and certifying them but when pushed they did not want to yield any names or costs just in case they were seen to favour one supplier over another. They did assure us that a number of suppliers would be ready for market in Q1 of 2010.

Here is a list of companies who I believe are working on a solution. Do not take this as gospel, just through my googling.

www.savanet.net

www.corefiling.com

www.semansys.com

www.rivetsoftware.com

www.ibs.nl

www.edgarfilings.com

www.allocationsolutions.com

www.justsystems.com

Approach

Awareness of XBRL and its impact is at an acceptable level within the UK market. Based on the Q&A session with HMRC the first 2 years are really going to be a phased/teething process and companies will not be penalised or prosecuted if they don’t get it quite right. We also do not have any products to work with as they are still being developed.

I would suggest a measured approach to the online filing which starts with Finance obtaining the taxonomies that they intend to use for filing and to start manually mapping the figures across from the financials. This in my opinion is going to be the largest portion of the work required. A deadline of the mapping tables by end Q2 2010 should be achievable.

Get your IT Department to keep tabs on the development of the various alternatives in the software space and then organize demonstrations and evaluations as and when possible. I estimate that we should be able to find something by Q2 2010. Based on all the input I would at this point suggest that we look to purchasing an Office Add-In that will allow you to continue with our current method of producing the financials and thus reduce impact on the business.

Works Cited

1. XBRL International. What is XBRL. [Online] [Cited: October 9, 2009.] http://www.xbrl.org/WhatIsXBRL/.

- Paul Steynberg

Thursday, October 8, 2009

Solvency II - Data Requirements

Overview of Solvency II

Solvency II is a piece of legislation (directive to be exact) adopted by the European Parliament on 22nd April 2009 and is a fundamental review of the capital adequacy regime for European insurers and reinsurers. Planned effective date is October 2012 and it aims to establish a revised set of EU-wide capital requirements, valuation techniques and risk management standards that will replace the current Solvency I requirements. (2).

The full text of this legislation can be found here. Powers have been granted to CEIOPS in order to produce consulting papers and to engage with the industry in order ensure uniformity and clarity.

IT Impact

A section of the proposed framework deals with Standards of Data Quality which is outlined in a consultation paper from CEIOPS, referred to as CP43. (3). Data, according to this paper, is used to refer to all the information which is directly or indirectly needed in order to carry out a valuation of technical provisions, in particular enabling the use of appropriate actuarial and statistical methodologies, in line with the underlying (re)insurance obligations, undertaking’s specificities and with the principle of proportionality. In the context of this Paper, data comprises numerical, census or classification information but not qualitative information. Assumptions are not regarded as data, but it is noted that the use of data is an important basis in the development of actuarial assumptions.

Whereas this Paper is focused on setting out advice in the context of a valuation of technical provisions, it is noted that the issue of data quality is also relevant in other areas of a solvency assessment, for example for the calculation of the Solvency Capital Requirement (SCR) using the standard formula or internal models.

From the materials I have been reading and through a breakfast (1) I attended here are some issues that I would like to flag up. The CP papers expand on the concept that data should be Accurate, Complete and Appropriate. In doing so they highlight the following potential gaps.

Data Governance
  • Most IT policies focus on security. Substantial changes to policies will be required in order to ensure that we focus on data quality.
  • As a group you will need to understand what data quality means within your context and how to measure it. This also requires documenting.
  • Clear responsibility versus ownership of the data is required which also requires documenting. In my view this would be split between the business units and IT.
  • You need to start looking at the technologies/tools required within your Group in order to ensure data quality.
Monitoring
  • The subtleties of the text indicate a focus on both transactional and non transactional data.
  • Both regular and adhoc types of data will require a degree of monitoring and appropriate controls in place to deal with both types.
  • A move to focusing away from the accuracy of the data but rather its relevance and content is required.
Documentation
  • Additional documentation required with regular updating.
  • Decisions to data quality deviations now require specific documenting and approvals.
In order to ensure accuracy, any data deficiencies should be rectified, with each adjustment justified and documented and should not overwrite the raw data. It was also hinted that a more detailed review of the data is required to ensure that it is valid and appropriate. In other words the fact that data made it from your store system through a multitude of layers to a warehouse does not absolve you from the responsibility of ensuring that the original data was correct. This, in reality, leads me to believe that data profiling and review of individual pieces of data with appropriate monitoring tools is required. This applies to both external and internal data.

Addressing the issue of data quality will go to the core of your IT department and if the hype is to be believed will require substantial investment in ensuring that your processes and tools are up to the task. This will have an impact on your IT strategy both from a technology and approach view.

Audit Impact

Article 46 of the Directive Consolidated Text referred to as Insurance and reinsurance (Solvency II)(recast) defines the responsibility of the Internal Auditors (IA) within the scope of Solvency II. (4). This article requires the usual stance of being independent and specifically requires that IA provide an effective internal audit function which includes an evaluation of the adequacy and effectiveness of the internal control system and other elements of the governance system. (This gets a bit circular as the resolution passed under (18a) says that the governance system includes the risk management function, the compliance function, the internal audit function and the actuarial function, which implies that they audit the same system that they are part off).

CP33 from CEIOPS deals with the advice on Governance and makes reference to the functions of Internal Audit. (5).

Although the requirements do not appear to be any different from any IA business as usual functions they are advised to submit a written report on its findings to the administrative or management body at least annually. It makes sense then to assume that IA have a full understanding of the Solvency II requirements.

Conclusions

Solvency II is going to have quite an impact on the way we do business as an Insurance Company and is something that should be driven from the highest possible position in the company as it will require substantial resourcing. This initiative should not be driven from within one department.

Works Cited

1. Addressing the data and technology challenges of Solvency II. PriceWaterhouseCoopers. London : s.n., 2009.
2. Financial Services Authority. Insurance Risk Management: The Path to Solvency II. s.l. : Financial Services Authority, 2008.
3. CEIOPS. Consultation Paper No.43 - Technical Provisions - Article 85 f Standards for Data Quality. Frankfurt : CEIOPS, 2009.
4. European Parliment. Insurance and reinsurance (Solvency II) (recast). Strasbourg : s.n., 2009.
5. CEIOPS. Consultation Paper No.33 - Draft CEIOPS Advice for Level 2 Implementing Measures on Solvency II: System of Governance. Frankfurt : s.n., 2009.

Thursday, October 1, 2009

Who Still Trusts the Gorilla?

Where does a 500 pound gorilla sleep? Anywhere it wants. Enter left stage - Microsoft.

At the beginning of the year Microsoft canned development on PerformancePoint Server Planning and laid off a whole pile of people. Some of them by e-mail, I know, one of them was on site with me in the UK when he got the news via an e-mail. To me this was a pivotal moment in our relationship with Microsoft. A year ago nobody questioned Microsoft's commitment to software development and products. Today a very different story. A few weeks ago I was discussing the way forward in our ETL architecture with my current employer and we had 2 roads, either IBM DataStage or Microsoft SSIS. The most senior person in the room posed this question "Are we sure that Microsoft SSIS will still be around in the future given the demise of PPS?". A year ago that question would have elicited chuckles from the boardroom table as an obvious joke. Not anymore, it was a serious question which required follow up.

I don't think that Microsoft has any idea how much damage they have done to their reputation in the market.

What do you think? If you have time please complete my on-line quick poll on this.

- Paul Steynberg