On Tuesday of last week XBRL-US sponsored a set of presentations in Washington, D.C. focused on “XBRL in Government and Industry.” The conference was hosted by the Federal Deposit Insurance Corporation (FDIC), which was appropriate since it was the FDIC that was the source of some of the most significant XBRL activity announced at the conference.
Here is the news: By October 1 of this year, the more than 8300 banks submitting Call Report data to the FDIC, the Federal Reserve System, and the Office of the Comptroller of the Currency will be required to do so using XBRL. Because most banks submit these reports through use of software and services supplied by a handful of vendors, this requirement will not bring about changes in the internal operations of most banks. The initiative does, however, represent a significant application of XBRL, and opens the door to greater reuse of data and simplification of workflows for other regulatory reporting requirements. It is also a good example of the kinds of broad improvement in financial information communication and processing that XBRL enables.
Under the current system, Call Reports are submitted in a number of formats, including physical transfer of magnetic media. The agencies currently spend a substantial amount of time converting these data. Data checking and validation is done only at the tail end of the process, within the government agencies, which means that when errors or omissions turn up, they must be communicated back to the banks so that corrections can be made. In the current operating model, the major component of the regulator’s investment in collecting and analyzing these data is spent in the conversion and validation process, leaving much less time for actual analysis.
The new system, implemented as part of an interagency consortium called the Federal Financial Institutions Examination Council (FFIEC), will allow the three agencies to share a single secure information repository. Each agency will use XBRL’s ability to provide a unique semantic identity for each incoming data element to enable the agency to extract the information it needs from the repository, in the form that it needs it.
Just as important, the use of XBRL coupled with Internet-based report submission allows the agencies to specify validation suites that can be run by the banks producing the information. The validation semantics are all expressed in XBRL, and so can be communicated in a reliable, standard way to the vendors, ensuring uniform performance across vendors and allowing the agencies to extend or improve validation without having to rely on the vendors. This is the kind of thing that XBRL excels at, and it plays an important role here. Moving validation closer to the source of the information will allow banks to catch their own errors, decreasing the time investment made by all parties in the submission process. The regulatory agencies will be able to spend less time on conversion, validation, and clean up and more time on analysis, all while reducing the cost of government operations.
This matter of the cost of data collection was a consistent theme across the presentations by government agencies at the conference. In general, financial and statistical information is currently heterogeneous in format, often with the added problem of having low information value. The numbers are all present in a report, but before the advent of XBRL there has been no easy, consistent, reliable way to enable a machine to know what the numbers represent. As one example of the cost of the current way of doing business, Mark Carney of the Commodities and Futures Trading Commission spoke in terms of spending over 80 cents of every dollar invested in data collection on conversion. This is precisely the kind of problem that XBRL is designed to solve.
For more information on the FFIEC’s Call Report Modernization program and about the creation and operation of this Central Data Repository, see www.ffiec.gov/find/.
In my view, there are a number of interesting facts and associated implications about this Call Report initiative. The first is that this is a mandatory initiative. XBRL is not an option, it is a requirement. XBRL has reached a level of maturity and universality sufficient to allow a set of government agencies to make it the required standard for an important application.
A related observation is that this maturity and universality has developed outside the U.S., and is only now coming back into this country of XBRL’s origin. Mike Bartell, CIO for the FDIC, made the point this way: “If we are truly serious about disclosure and transparency, we need to move aggressively toward the adoption of XBRL. The U.S. has not been a leader in this area. It is time to step up the pace. We are buried in data, and we are not making better decisions because of that.”
It is also important to note that this early, significant development in the marketplace for XBRL tools and services is the kind of “early majority,” “pragmatist” application that Geoffrey Moore described so well in his classic marketing text, Crossing the Chasm. The pragmatists are the first technology adopters on the right side of the chasm, after crossing it. They seek narrowly focused solutions that solve specific, pressing problems, adopting a new technology when it is the only thing that will do the job. The payoff must be clear and substantial–no pie in the sky or grand visions here–and the costs must be easily contained. Pragmatists adopt new technology because it will be a sure win for a particular problem, not because it will change the world.
In this case, where the actual XBRL will produced by a handful of vendors, it is easy to see how to contain the costs associated with XBRL production. Most banks won’t know and won’t care that the call reports are being submitted in XBRL. Further, the payoff, in terms of reduced conversion and validation costs, is clear and compelling. The fact that XBRL is an open, international standard adds to its pragmatist appeal. It is exactly the right tool for this niche application.
Getting an application across the chasm–away from the early adopters and technology aficionados and over on the other side, where the mainstream applications live–is a big step. This is real evidence of the utility and potential impact of XBRL. It is also important to remember that such early leaps across the chasm are always, of necessity, narrow, tailored, niche applications. It is the narrow applications that get across first. This is an important one. What comes next?