Transcript Mode d ’emploi - Eurofiling Initiative

Secrétariat général de la Commission bancaire
COREP - FINREP - XBRL
The French Banking Commission approach
15th International XBRL Conference
Munich, 6 June 2007
Jean-Luc MENDA
Deputy Director, Policy and Research
SGCB
COREP
COREP- -FINREP
FINREP- XBRL
- XBRL
COREP- FINREP- XBRL
The French Banking Commission approach
1 • Project objectives : a european framework
2 • Consequences on our IT system
3 • Challenge : managing complex taxonomies
4 • The French Banking Commission COFINREP project
5 • COFINREP : technical choices - XBRL learning curve
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COREP - FINREP - XBRL
1. Project objectives : a european framework
• The objectives of Committee of European Banking Supervisors :
– Harmonising banking supervision practices in Europe, and
developing a common supervisory culture
– Reducing unnecessary costs of reporting to the banking
supervisors through European convergence
• In order to fulfill this goal, need for :
– The definition of a common framework
– A common vocabulary based on the European legislation
– A degree of flexibility in order to adapt to national specifics.
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COREP - FINREP - XBRL
1. Project objectives : a european framework
• Two european initiatives :
– A common reporting for a common solvency ratio (COREP –
COmmon REPorting)
CRD Directives
 14 June 2006: final adoption of Directives 2006/48/CE et
2006/49/CE
COREP
 13 January 2006: CEBS publishes COREP templates =>
http://www.c-ebs.org/standards.htm
 Adoption of the French COREP project by the Banking
Commission 26 March 2007
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COREP - FINREP - XBRL
1. Project objectives : a european framework
– A common « supervisory financial » reporting for banks
consolidated accounts in IFRS (FINREP, FINancial
REPorting)
 European regulation introducing IFRS is directly applicable in
Europe
 European reporting published by the CEBS on 16 December
2005 => http://www.c-ebs.org/standards.htm
 Adoption of the French FINREP project by the Banking
Commission on 28 June 2006
1st remittance date for COREP and FINREP
30 June 2007 in France
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COREP - FINREP - XBRL
1. Project objectives : a european framework
• XBRL taxonomies built by the CEBS for COREP and
FINREP create a common framework. They include :
– A common vocabulary for European supervisors,
elaborated on the basis of official European regulations
and
– A common « grammar » through its « Linkbases ».
• XBRL allows for a european flexible approach, including
national specific elements
• But XBRL standard must also keep pace with the evolution
of business requirements, and the complexity of COREP
and FINREP reportings.
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COREP - FINREP - XBRL
2 • Consequences on our IT system
• The French Banking Commission decided to make it mandatory
for the banks to transmit their COREP and FINREP reports, using
the XBRL standard for reasons of efficiency and cost.
• The working relationship between banks and the BC will change
only marginally :
 The General Secretary of the Banking Commission has
provided the banks with the adapted French version of the
European taxonomies
 The financial institutions will transmit their reports (instance
documents according to XBRL vocabulary) XML/XBRL, via
the usual data transmission means
 After verification of data quality, anomalies will be restituted to
each institution
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COREP - FINREP - XBRL
2 • Consequences on our IT system
• The Banking Commission decided to go further in the adoption of
XBRL/XmL, for the following reasons :
 First, our present data system, BAFI, is a proprietary one, only
used for the exchange of data between the French financial
institutions and the Banking Commission/Bank of France
 BAFI is now a mature system (1993) which was due to evolve
in the coming years (very complex legacy in mainframe
technology : >1000 programs)
 Communication with many applications inside and outside and
a much parameterised system
 XmL has become a standard in data transmission which
imposes itself in the banking industry
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2 • Consequences on our IT system
• In a first stage, need to run two parallel information systems :
COFINREP and BAFI
• Possible since :
 Relatively few common data between the new reportings and
the present data base
 COREP and FINREP are new and would have, in any case,
needed important and complex developments in the old
system
 This situation will not hinder the supervisors’ work
• However, we will need
systems
to run data exchanges between both
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2 • Consequences on our IT systems
BAFI
Civil statuts data
Financial
Institution
Information
System
Prudential and accounting
Reporting
Input
Output
Configuration
Accreditation
Bâle II
Inside
applications
CB/BDF
SIGNECB
COREP Instances
IFRS
FINREP Instances
Data
Control
and
management
Data
mining
XBRL
Taxonomy management
Accreditation
COFINREP
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COREP - FINREP - XBRL
2 • Consequences on our IT system
• The second stage : we intend to move on with the rest of
the reporting system and to have a single data
exchange system with the financial institutions.
• In order to achieve this, we will have to :
– Create taxonomies regrouping all necessary data for
supervisors
– Add the necessary functionnalities to the new system
– Do the same thing with the other data managed by
BAFI (statistics data, monetary data….).
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3 • Challenge : managing complex taxonomies
• Banking Commission decided to create and manage inhouse the French versions of COREP and FINREP
taxonomies
• COREP:
about 800 entities concerned
19 templates and about 23 000 data (facts)
• FINREP: about 80 entities concerned
42 tables (27 templates ) about 1 700 data
• Final users : 280 supervisors and inspectors
• Team of 4 taxonomy managers
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COREP - FINREP - XBRL
3 • Challenge : managing complex taxonomies
• Creation of the French versions on the basis of the
European taxonomies
• All the labels of concepts coming from the European
taxonomies translated into French
• Creation of a limited number of French specific concepts
(with an English and French label)
• Internal validation of the taxonomies with the help of our
tools (formalism and standards)
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COREP - FINREP - XBRL
3 • Challenge : managing complex taxonomies
COREP and FINREP taxonomies were available at the
end of september :
 FINREP => end-september 2006
http://www.finrep.info
 COREP => 6 october 2006
http://www.corep.info
R
h
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3 • Challenge : managing complex taxonomies
French versions of COREP and FINREP :
 FINREP => version for discussion (0.1) published on the
Banque de France website on 26 october 2006
- version 0.2
15 january 2007
- approved version 1.0 : 5 february 2007
http://inbdf/fr/supervi/supervi_banc/reporting/finrep.htm
 COREP => version for discussion (0.1) published on 1st
december 2006
- version 0.2
15 january 2007
- approved version 1.0 : 5 february 2007
http://inbdf/fr/supervi/supervi_banc/reporting/corep.htm
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3 • Challenge : managing complex taxonomies
French taxonomy
definitions
Launch
T
A
Taxonomy editing tool
delivery, getting started
and training
Taxonomy extensions
Professional’s
Feed back
Validated
taxonomies
Taxonomy finalization
X
O
N
O
Project management and supervision
M
Y
02/2007
First draft
European
taxonomies
01/2006
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Final version european
Taxonomies & Beginning
of French taxonomies
09/2006
Taxonomies
available for the
professional public
10/2006
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4. The Banking Commission COFINREP project
SCOPE
– French taxonomies management (VERSIONING)
P
O
R
T
A
L
– Data reception management
– Digital signature of the instance documents
– Authorisations and reference data management
– Controls of received instances
V
1
P
O
R
T
A
L
– Reminders in case of anomalies or late data transmission
V
2
– Automatisation of the processes
SGCB
– Synthesis and reporting according to the needs of the supervisors
– Interface with the others systems of BDF
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COREP - FINREP - XBRL
4. The Banking Commission COFINREP project
Launch
P
Validation
Go live
Portal V1
Go live
Portal V2
Global
conception
O
Portal V.1
R
T
Portal V.2
A
L
06/2006
07/2006
06/2007
01/2008
Project management and supervision
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4. The Banking Commission COFINREP project
• Choice of a generic software :
– very short deadlines
– use XBRL as far as possible
• Legal process for open tender :
– Open tender : 7 december 2005
– Emission of specifications : 3 february 2006
– Choice of solution : may 2006
• Chosen software meets 60% of users’ requirements in
the basic version
• 40% of specific developments taken in charge by the
supplier
• Supplier team (5 to 10 people), internal IT team (4 to 6)
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4. The Banking Commission COFINREP project
Main challenges
• Dealing with very complex taxonomies, using dimensions
extensively (new standard 1.0 created for COREP)
• Lack of maturity of existing softwares, in particular taxonomy
editors, not always compatible
• Training offer is still very limited
• Lack of formulae standard, which makes it compulsory to
develop in-house business rules
• The question of “versioning” management is urgent and
should be a priority for the months ahead
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5 • COFINREP : technical choices - XBRL learning curve
The added XML header: why?
+ To be able to sign
multiple instances
+ So that habilitation
testing are not XBRL
dependent
Electronic signature
<fichier>
< enveloppe>
<XBRL>
< enveloppe>
<XBRL>
< enveloppe>
<XBRL>
+ For better « on the fly
» performance on
instance reception
- Added consistency
tests
Note: the XML schema of the header is available at:
http://www.banque-france.fr/fr/supervi/supervi_banc/reporting/reporting.htm21
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COREP - FINREP - XBRL
5 • COFINREP : technical choices - XBRL learning curve
Focus on: Control and storage of an instance
#
Contrôle
Process stop
Production
Simulation
1
In case of a COREP instance, check that the value of the option in the header is properly set
to « consolidated » or « social »
yes
X
X
2
XBRL 2.1
yes
X
X
3
Aggregations and dimensions
yes
X
X
4
Calculation links
no
X
X
5
Uniqueness of key (entity, date, taxonomy) in instance
yes
X
X
Coherence of entity between header and instance
yes
X
X
Manual verification
X
X
Existence of date in database
yes
X
Coherence of taxonomy between header value and instane’s schemaref
yes
X
X
Validity of the taxonomy and the reported date
yes
X
X
Coherence of currency between header value and instance declaration (iso4217 only)
yes
X
Validity of currency for the entity (database).
yes
X
Manual verification
X
Manual verification
X
6
Existence of entity in database
Coherence of date between header and instance
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8
9
Is type COREP or FINREP expected for entity
COREP only: is entity authorized for the option declared in the header (consolidated, social)
COREP only: is entity authorized for the approach value in the header, and the values
present in the instance. (standard, foundation, advanced).
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COREP only: is the date of the reporting in the instance coherent with the entity’s status
- Mars, June, September and December for large groups
- June and December only for small groups
COREP - FINREP - XBRL
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5 • COFINREP : technical choices - XBRL learning curve
Financials institutions (submitters)
BACKEND
- Taxonomy creation
- Instance management
Instance
Document
Instance
Document
Instance
Document
Instance
Document
INTRANET
EXTRANET
- Taxonomy published
- Intances workflow
Receipt Management
Taxonomy
Reception
Management
Taxonomies
Instance
Document
Instance
Document
Databases
servers
Taxonomy
management
Taxonomy
control
Corporate Directory
Server: BAFI …
Taxonomy
Mistakes/Errors
Habilitations
Reference data management
SGCB
Reporting
synthesis
• Conception
• Reporting
calculation
Control and
storage
Amounts ctrl.
BAFI/COFINREP
Comparision
Taxonomy
Reporting
Extraction
COFINREPReporting
Errors
Reporting synthesis
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COREP - FINREP - XBRL
5 • COFINREP : technical choices - XBRL learning curve
A. The test platform: a compatibility check
The platform opened up in the beginning of March.
• Within one month we received 4 instances
• Instances were mostly FINREP
Result :
• 3 instances: 100% public taxonomy valid. The last instance failed
taxonomy validation, but was successful on the second emission
• 3 out of 4 had no CL error, but only one succeeded the private
taxonomy tests.
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5 • COFINREP : technical choices - XBRL learning curve
B. The performance test
• Done with over 800 instances.
• Instances with every fact combination filed. Not a “real life” scenario.
• Difficulty encountered: evaluate the target performance.
Processing times (minutes)
200
180
185
Corep
160
Finrep
140
Total
123
120
100
79
80
60
40
20
2
5
0
0
Step 1
Step 2
Publique taxonomy
validation
Private taxonomy
validation
CL logs parsing
Inter-instance validation
(COREP)
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5 • COFINREP : technical choices - XBRL learning curve
C. Questions to answer before building your IT
• Precision and decimals
(9453 decimal= -3 )+ (9454 decimal= -3) + (9453 decimal= -3) = 27 023 decimal=-3
We imposed decimal=0 for monetary Items and decimal=4 for pures
Need for a tolerated variation in CL, more precise than the use of decimals (needed: +- 3000)
• Units and scale
Although most existing system work with Kilo-Euros in the BDF, money scale is not part of the
XBRL.
We work with Euros, but will have to convert when exporting data to other existing application.
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5 • COFINREP : technical choices - XBRL learning curve
• Missing/duplicate facts
Missing facts can make certain Calculation Links to no be check (especially with total)
Duplicated facts will interfere with calculation links, and possibly any control or restitution
framework
This is why, it was decided that missing or duplicate fact were to be detected by COFINREP. The
financial agents will be warned of these problems, and will be asked to correct this.
• Instance’s size impact
Long item names, namespace ids, unit ids, dimension name….

increase size of instances

Increase processing time of an instance
For example: replacing all ids/names in an instance by numbers => more than 60% size gain
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5 • COFINREP : technical choices - XBRL learning curve
• Added control framework
The need of:
- inter-instance controls
- controls with other data source (data bases, flat file…)
- conditional or complex controls
- Periodic controls (A test only done a particular month or frequency)
Might require to build some configurable control mechanisms.
•Automated restitution: functional/technical barrier on data errors
Not everyone understands fact names, contexts, dimensions and hypercubes.
We need to translate, for example, a Calculation error in a way that an accounting personnel
will easily understand.
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Secrétariat général de la Commission bancaire
QUESTIONS ?
SGCB
COREP - FINREP - XBRL