www.pwc.com ISACA XBRL Considerations Sept. 29, 2011 Discussion Items - Key messages - Basics of XBRL - The SEC Mandate - Common Errors and Issues - Implementation Considerations - Who is Using XBRL - What is Going on Around the World - What can you do - Appendixes ◦ Data Aggregators vs. Company Reports ◦ Resources PwC 2 Key Messages PwC Key Messages In the short term, key messages include: • Supply Chain Standardization rather than a compliance requirement • Review company report via XBRL analytical tools rather than viewer or rendering • Build-in rather than bolt-on to enhance reporting processes and controls • Enhances reporting/review processes not just Ks & Qs • Broadcast directly to stakeholders to enhance effectiveness of communications • Enables social processes (publishing, analytical, review) • Currently in use by broad range of analysts (social analytics) • Redefines ‘convergence’ and provides economic incentives for IFRS adoption in countries around the world (SBR) PwC 4 Basics on XBRL PwC What is XBRL International supply chain standardization effort • Designed specifically to address pervasive process problems • Mandated by economics and regulators (including US SEC) • Applicable to business information, related business rules, formulas, controls, processes, resources, etc. • “Bar Code” for Business Information - Adds structure (meaning) to company disclosures - Enhances processing and reuse - Disclosure neutral - Taxonomies available for: US/IFRS GAAP, other statutory GAAP, MD&A, CSR, GRI, Proxy, Corp Actions, Legers/subledgers, other non-financial • Process enhancements are available and being realized • Examples: Traditional Rendered XBRL http: //www.xbrl.org and http: //xbrl.us PwC Raw XBRL From proprietary to infrastructure Match the proprietary ‘technology’ to the standard that transformed it to ‘infrastructure’. 1. Rail Road A. RJ 11 2. Telegraph B. 40’ x 8.5’ x 8’ 3. Electricity C. UPC 4. Telephone D. HTML / SOAP / Web Services 5. Shipping E. 4’ 8.5” 6. Products F. RJ 45 7. G. Rosettanet, MDDL, XBRL Networking 8. Internet H. Morse Code 9. Information I. 120V, 60Hz What were once proprietary technologies were transformed into ‘infrastructure via standards. XBRL is the standard for Business Information. PwC What is XBRL? Supply Chain Standard • UPC/Bar Code for Business Information • Specifically designed to: • Enhance Information Transparency and Reuse • Improve Data Quality through source validation and analysis • Enable collaborative development and use of formulas/models/rules • Standardize presentation concepts for collaborative use • Provide standardization for broad range of business information concepts • Put Users (not IT/software) in control • Streamline business processes while lowering costs • Similar impacts to how the UPC/Bar Code has transformed the retail grocery supply chain and processes PwC What is it A structured document PwC XBRL is more than just tagging business information • Multi-dimensional business and financial data representations • Flexibility of business reporting vocabularies (i.e. taxonomies) • Mathematical relationships between concepts • Flexibility about how to present information to users PwC Definitions Related to Liquid Assets Presentation Presentations équivalents Cash & d'argent Cash Equivalents comptant et d'argent comptant Label Cash in Bank References • Stat Regulation 1.2.(a) • IFRS Bound Volume XBRL <cash>“ 200” Calculations Cash = Currency + Deposits with others Contexts US $X FYE 2009 Budgeted Formulas Cash ≥ 0 Where is it relevant All along the supply chain The business reporting supply chain Transaction layer Internal business reporting Business operations Processes • • • • • Rosettanet ACORD MISMO FPML Others XBRL Global ledger • • • • • SCOA Payables Ledger Receivables Ledger Fixed Asset Ledger Others XBRL external reporting External business reporting Investment, lending, regulation • • • • • Economic policymaking Local GAAP IFRS GRI G3 WICI KPI’s Others include: Corporate Actions, Mortgage Backed Securities, Risk & Return, Governance/Risk & Compliance, etc. PwC The SEC Mandate PwC The SEC Mandate – SEC Resources Page PwC Basics on XBRL and the SEC Mandate US SEC Mandate summary Improving transparency and reuse • XBRL Mandate impacting all public registrants including US GAAP/IFRS filers - Companies = GAAP F/S - Mutual Funds = Risk & Return Disclosures • 3 year phase-in commencing for periods ending after June 15, 2009 - Year 1 = basic f/s and notes as ‘block text’ - Year 2 = basic f/s and note disclosures in detail • 30 day grace period for initial submission in first two years • Mandatory web site posting • Limited Liability Provisions for first 2 years • Mandate specifically excludes audit; voluntary AUPs are occurring PwC US SEC Mandate summary June 30, 2009 Large Accelerated Filers (~500 Companies) >$5B public float All Other Large Accelerated Filers (~1,200 Companies) All Remaining Filers (~7,200 Companies) PwC June 30, 2010 June 30, 2011 June 30, 2012 June 30, 2013 Detailed Tagging of financials Block tagging of notes/schedules Detail & block tagging of notes/schedules Liability “As Furnished” Liability “As Furnished” Liability “As Filed” Detailed Tagging of financials Block tagging of notes/schedules Detail & block tagging of notes/schedules Liability “As Furnished” Liability “As Furnished” Liability “As Filed” Detailed Tagging of financials Block tagging of notes/schedules Detail & block tagging of notes/schedules Liability “As Furnished” Liability “As Furnished” Liability “As Filed” Basics on XBRL and the SEC Mandate Key learning's & observations on initial XBRL submissions Compliance with the Edgar Filer Manual • 200+ fairly complex technical rules; some require financial reporting judgments • Some validation rules are included within the SEC filing processes Preparation and review processes and controls • Start early and consider a ‘test’ run submission • Knowledge of company financial statements more relevant than XBRL expertise • Adjust reporting timeline to accommodate XBRL submission process • Focus early on company specific taxonomy extension(s) to USGT • Consider assessment of EDGAR Filer Manual rule compliance • Internal reporting validation and analytical rules and controls Consider SEC test filing to assess ‘some’ validation rules Consider SEC Previewer to assess presentation views PwC Basics on XBRL and the SEC Mandate Key learning's & observations on initial XBRL submissions (continued) • Process implications of concurrent submission of the XBRL Exhibit - Compression that exists in many companies reporting timetables - Manual nature of such processes - Is your current process sustainable, especially in the context of the detailed tagging required in 'Year 2'? - Validation rules can be applied by companies and their constituents, including regulators and potentially used to: ◦ Enhance the quality of reported disclosures ◦ Enhance the quality of analysis of reported disclosures by third parties PwC Insights on 2011 USGT • 2011 USGT available from FASB on January 18, 2011 http://www.fasb.org/jsp/FASB/Page/SectionPage&cid=1176157088011 • SEC Approved 2011 USGT effective February 28, 2011 http://www.sec.gov/info/edgar/edgartaxonomies.shtml “The SEC staff strongly encourages companies to use the most recent version of the US GAAP taxonomy release for their Interactive Data submissions to take advantage of the most up to date tags related to new accounting standards and other improvements. However, due to the timing of the release of the US GAAP 2011 taxonomy in conjunction with the phase-in of the Rule, companies will be permitted to continue to use the US GAAP 2009 taxonomy.” • Fiscal year-end transition may facilitate comparative analysis • Additional elements may reduce some company specific extensions PwC Scope of Disclosure Tagging How granular is XBRL taxonomy mapping applied? PwC Scope of Disclosure Tagging How granular is XBRL taxonomy mapping applied? Examples of Amounts NOT Required to be tagged: - A footnote number itself - 1% fat milk - A meal of less than 500 calories - At an altitude of 27,000 feet - Depreciated using Section 179 - No help was available within 2 miles - $1.99 pancake special - Docket no. 34-4589 - 21nd district court FASB ASC 605-40-15 Drilling 700 feet Open new stores no less than 2 miles from existing stores Founded a new subsidiary in 2009 At least 20 entries under 250 calories Source: March 23 SEC webcast PwC Common Errors and Issues PwC 21 SEC Staff Observations on XBRL submissions SEC Staff Observations (from June 15, 2011) Observations for filers tagging the face of the financial statements • Format of the statements • Negative Values • Extended elements • Completeness of tagging Additional Observations for Detail Tagged Filings: • Modeling of Level 4 tagging • Negative Values • Units • Other observations from certain filings include: monetary values, Article 12 schedules, footnotes, and calculation links. PwC 22 SEC Staff Observations on XBRL submissions SEC Staff Observations (from November 1, 2010) • Negative Values - Errors in positive and negative signs. (50% of errors) • Extending for an element where an existing US GAAP Taxonomy element is appropriate • Inappropriate Axis and Member use • Lack of use of the US GAAP modeling for Axis and Members • Tagging completeness — Parenthetical Amounts PwC 23 Other Observations on XBRL Submissions • Company and period specific information in elements • Calculation errors and anomalies, particularly in tables in the notes to the financial statements • Supplemental Schedules omitted • Company specific extensions created but unused • Problems with dimensions and scenarios • Errors in the use of decimals. (e.g., 0 rounded to the nearest 1,000,000) • Tagging same number twice with multiple tags • Failure to tag a number (as defined by the SEC) • Failure to structure all footnotes included in the notes to the financial statements • Mistakes in the unit of measure (e.g., incorrect use of “pure”) • Use of future date contexts (e.g., future debt payments) PwC 24 Common Causes • Company review based on Excel reports and not the underlying XBRL instance. Lack of tools used by management to adequately review the taxonomy/instances • Tagging performed by individuals without full understanding of Company's financial reporting • Tagging performed by individuals without a full understanding of XBRL and the SEC EDGAR Filer Manual • Common and pervasive misunderstandings by service providers • Focus on speed and lower cost over accuracy and completeness in tagging • Time crunch required by outsourcing solution and limited turn-around time • Lack of a defined process and timeline • Focus on rendering rather than the structure of the disclosures • Expectation gap of financial printers (lack of GAAP reporting expertise) • Not a management priority related to liability protection for a 2 year period PwC 25 Modified Liability Provisions Modified liability provisions – what does it mean? • Submissions are subject to the federal securities laws in a modified manner when filed within 24-months of the first required filing but no later than October 31, 2014, provided: • Good faith attempt • Prompt correction • Voluntary filings do not count towards the 24-month period • The 24-month period is exclusive of a grace period • Group 1 companies– be sensitive to the expiration of the modified liability provisions • No change to external auditor involvement PwC 26 When does the Modified Liability Provisions end? Question: When does the SEC's Interactive Data Modified Liability Period end for companies currently submitting their XBRL Exhibits? Answer: Guidance is provided within the SEC final rule here in section 232.406T which states: "(d) Temporary section. Section 232.406T is a temporary section that applies to an Interactive Data File submitted to the Commission less than 24 months after the electronic filer first was required to submit an Interactive Data File to the Commission pursuant to § 232.405, not taking into account any grace period, but no later than October 31, 2014.“ Further, footnote 231 of the final rule provides additional guidance: "For example, a large accelerated filer first required to submit interactive data for financial statements in a Form 10-Q for the fiscal period ended June 30, 2009, would be required to submit the interactive data by 30 days after the Form 10-Q's August 10, 2009 due date but its 24-month period would end August 10, 2011”. PwC 27 Implementation Considerations PwC 28 Implementation Options Implementation options Some potential vendors “Bolt-On” – Outsourcing Bowne, RR Donnelley, Merrill, EDGARizerX, BusinessWire, etc. “Bolt-On” – In-house Rivet Software Crossfire, Fujitsu, Corefilings, etc. “Built-in” – Report writer/consolidation Clarity Systems FSR, Trintech Unity, SAP Disclosure Management, Oracle Disclosure Management, Tagetik, Rivet Software Crossfire, Webfilings, etc. “Embedded” – Ledgers & Sub-ledgers Altova (MapForce), Stylus (Studio), Fujitsu (XWand), Hitachi, Rivet Software, all ERP vendors, etc. http://xbrl.us/Learn/Pages/catalog2.aspx http://xbrl.us/Learn/Pages/ToolsAndServices.aspx http://www.xbrl.org/tools/ PwC 29 Outsourcing Expectations - Capacity during peak filing periods given scale of market requirements - Turnaround times (48 to 72+ hours) - Service Level Agreements – turn-around time and ‘hand-offs’ - Confidentiality of data and transmissions, and ‘portability’ of work product Quality control - Review of XBRL report (vs. Excel mapping table, viewer rendering) - Validation (EFM objective and subjective rules) - Review and validation tools - Issuer review and approval process - Knowledge of F/S and financial reporting – company-specific extensions - XBRL expertise and instance document preparation experience Other - Ownership of mapping IP and company specific extensions - Process implications, including detailed tagging in ‘Year 2’ PwC 30 Beyond compliance with the SEC’s XBRL Mandate Adoption alternatives pros and cons Standardize to Streamline Compliance Processes Implementation options Year 1 Year 2 Mapping of 300 disclosure elements Mapping of 3,000+ disclosure elements “Bolt-On” - mapping done subsequent to report completion and repeated for each report. Pros Pros • Convenient mapping • Limited impact on existing process • Low impact implementation Cons Cons • Repetitive mapping • Incremental Cost & Time • Incremental Cost & Time • Manual Controls • Manual Controls • Compresses reporting timeline • Compresses reporting timeline Pros Pros • Lower Cost & Time • Lower Cost & Time • Automates Controls • Automates Controls • Streamlines assembly & review processes • Streamlines assembly & review processes Cons • Platform for enhanced BI • One-time implementation effort Cons “Built-in” - mapping done within reporting application and available for all subsequent reports. • n/a PwC Current Manual Assembly/Review Processes Common Year 1 ‘Bolt-on’ approach adds cost/time ← Largely unaffected | Affected → 4 5 Supplemental Data ERP 1 3 ERP ERP 1. 2. 3. 4. 5. Consolidation 2 10-Q in Word Review and Check Linear Document Review Distributed Document Review Manual Assembly via two processes Manual Spreadsheet Aggregation Manual Queries of sub-ledgers 10-Q in HTML Review and Check 10-Q in XBRL Edgar Outsourced and Bolt-on approaches PwC 32 Built-in Enables Enhanced Processes Applying standards earlier enables streamlined processes 25% to 50%+ cost/time enhancements 5 1 3 ERP 10-Q in XBRL, Word, PDF Report Writer ERP 2 Consolidation ERP 1. Contextual Review 2. Collaborative Review 3. Automated Assembly via a single process 4. Automated Aggregation 5. Automated Queries of sub-ledgers PwC Supplemental Data 4 Edgar 33 Benefits Beyond Compliance Assembly process manual automated centralized decentralized Review process linear contextual distributed collaborative Controls manual streamlined/automated Streamlined reports (not just 10K/10Q) • Board of Directors Package / Audit Committee Package • Press Releases, Quarterly Statistical Summary, Proxy • Significant Accounting Issues Memo, Emerging Accounting Issues, Rep Letters • Tax Returns, Statutory Financial Reports, Business Registration Documents • Others PwC 34 US Registrants Using Built-In Solutions Companies PwC 35 Some Relevant Vendors and Tools “Built-in” • Altova MapForce • Clarity FSR • Corefilings Seahorse • Oracle Disclosure Manager • Rivet Crossfire Controller • SAP Disclosure Management • Tagetik • Trintech XFR • Webfilings “Bolt-on” • AltovXML Spy • EdgarizerX • Fujitsu XWand • Rivet Crossfire Compliance Analytical • Altova StyleVision • Arelle • Corefiling Magnify • Fujitsu Interstage XWand • XBRLCloud • XBRL US Consistency Suite http://xbrl.us/Learn/Pages/catalog2.aspx and http://xbrl.us/Learn/Pages/ToolsAndServices.aspx PwC 36 Software Considerations • Nature (client server vs. SAAS) • Pricing (size, volume, duration based) • User-friendly features (US GAAP Taxonomy views, mapping, validation) • • - Facilitate company-specific extensions - Validate SEC public validation rules, EFM, and other ‘rules’ - Import, view and manage multiple taxonomies - Wizard based taxonomy mapping features for tables, multiple elements Workflow and Controls - Adequate Workflow and Control Administration - Extensibility to broad domain of reporting participants - Validation and analytical capabilities Technical Capabilities - Compliance with XBRL Technical Specifications and relevant taxonomies - Interoperability with existing company software applications - Produce AND Consume XBRL (including iXBRL) - Timeliness of support (access and responsiveness; 2011 USFRT; EFM versions; etc.) Refer to “Appendix 1: XBRL Tool Considerations” for a list of questions to ask the vendors. PwC 37 XBRL Tool Considerations Some key questions to ask the vendors 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. Is the tool simply a bolt on that creates XBRL documents, or does it support the full creation of financial statements? Does the tool allow for conditional assembly of the financial statements (e.g. automatically include certain MD&A sections based on performance)? Can you extend the taxonomy using the tool itself, or do you need an external taxonomy editor? Does the tool allow you to tag the same data with multiple taxonomies (e.g. IFRS and US GAAP)? Does the tool currently support iXBRL? Are there plans for future support? Does the tool allow you to quickly compare taxonomies (US GAAP 2009 versus 2011) and identify the impact on your instance document? Does the tool suggest tags for the various concepts in the report? Is the search tool for tags easy to use? Is there taxonomy mapping wizard functionality? If so, how robust are its capabilities? How does the tool allow you to rollforward from one period to the next? Does the tool have appropriate security controls (segregation of duties, login and access by user, role, etc.)? Does the tool enable workflow processes around the creation, maintenance and review of company reports? Does the work flow functionality align to your company's demands? Does it enable decentralized mapping to source systems as well as to the relevant taxonomies? Can the tool interface with your consolidation software? Can the tool import XBRL GL data? Can the application consume XBRL from internal and/or external sources via Web Service and/or RSS feed? PwC 14. Can the tool interface with your document management system (e.g. Documentum)? 15. Can the tool create units on the fly? Does the tool support link:footnotes? 16. Does it make HTML/XBRL GL a true transparent and parallel process? Does changing the presentation order update the presentation linkbase? 17. What kind of validations does the tool allow you to perform on the XBRL instance document? Most tools validate that the instance document will be accepted by the SEC. Are there validations built in that check more sections of the Edgar Filer Manual? Does the tool allow you to write and check for your own validation rules? 18. Does the tool interoperable with the XBRL US Consistency Suite to enable taxonomy mapping and consistency validation assessments? 19. Does the tool allow you to easily check for calculation inconsistencies and easily identify all calculation relationships in the document? 20. Does the tool allow you to easily identify the attributes of each fact (e.g. data type, unit, decimals, balance, etc.) in a standard report? 21. Does the tool enable EDGARization of company reports and submission directly to Edgar? Does it facilitate corporate website posting? 22. Does the tool allow you to run comparative analysis on your peers of both numerical and narrative disclosures? 23. How quickly does the vendor respond and provide updates related to new issuances of the US GAAP taxonomy and the Edgar Filer Manual? 24. Does the tool fit within your IT infrastructure (e.g. client server) or is it deployed via a Cloud implementation? 38 Project Planning Project team: - Core group to include supporting accounting teams - Assess group and/or individuals in charge of tagging efforts - Train team on Taxonomy mapping and extension process ◦ Need an efficient means of building/managing taxonomy components Workflows: - Define workflow for mapping and review efforts (divisional teams, topical groups, etc.) - Develop validation processes and acquire relevant tools - Assess process and control modifications and ICFR implications Policy Matters: - Modified liability provision timeline for company - Company specific extensions (documentation support) Timeline: - Mandated compliance reports - Priorities for other relevant reports, materials and risk assessments PwC 39 Taxonomy Considerations • US GAAP Taxonomy – SEC Approved Taxonomies - 2009 Taxonomy - 2011 Taxonomy “The SEC staff strongly encourages companies to use the most recent version of the US GAAP taxonomy release for their Interactive Data submissions to take advantage of the most up to date tags related to new accounting standards and other improvements.” • Hierarchical structure = Conceptual Accounting Framework • Commercial & Industrial Taxonomy view - Browse - Search - Definitions - References - Calculations • IFRS Taxonomy • Corporate Actions Taxonomy PwC 40 Compliance Process Considerations Bolt-on / Outsourcing solutions are simply not scalable or sustainable Transition to Built-in approach to streamline and automate current manual report assembly and review process steps as well as lay a foundation for other efficiencies Anticipate SBR styled compliance environment in the next 3 to 5 years IFRS relevant to compliance reporting across broad range of countries Leverage Built-in reporting processes for compliance requirements in all jurisdictions; minimize current territory specific manual compliance reporting shops Provide greater oversight and governance from above Greater control for reconciliation between regions, reporting requirements PwC 41 Who is using XBRL? PwC 42 Why analysts use XBRL? Enhance cost and time to access, reuse , analyze, report and act • Traditional data sources are error prone, incomplete, slow to market and expensive • Company has no control or input on third party tagging (Please see Appendix A that compares company reported disclosures and data aggregator data on the company) • Third party data aggregator parsing errors and normalization of company reported disclosures • Typically 20% to 25% error rate on primary tables • Note disclosures are limited to non-existent • XBRL enhances: Speed, Accuracy, Completeness, Cost effectiveness, analytical capabilities • Company has limited insights on analyst use of company disclosures or analytical drivers; social analytical platforms provide a collaborative model PwC 43 Examples of XBRL Enabled Analysts Applications MicroStrategy Bank Performance iPhone App BlueMatrix Analyst Suite XBRL US EDGAR Viewer PwC 44 Examples of Social Analytics Social analytics - Standards enable collaborative development and maintenance of formulas and models among authorized individuals PricewaterhouseCoopers iDP PwC 45 Analysts Reflect on Company Specific Extensions Quality of XBRL submissions is of interest to analysts Company specific extensions are often created when USGT elements are available for disclosure element. Institutional Analysts, in particular, are focused on the inappropriate use of extensions as outlined in this blog: “XBRL Usability Part 2: Checking the Extension Cord” http://institutionalrisk.blogspot.com/2011/02/xbrl-usability-part-2checking.html Also: IRA's 2011 XBRL Dynamic Renderer PwC 46 Implementation Considerations Supplement Website Posting Requirement XBRL Submission required to be posted on company website ◦ Need not be made available in a format comparable to paper-based information. No viewer necessary. ◦ Link to SEC EDGAR to satisfy the posting requirement is prohibited ◦ Many companies are providing a link to third-party services that host their SEC filings and often provide a viewer Investor Relations related considerations ◦ Virtual renderings provide efficiency opportunity (example here) ◦ Be aware of EDGAR RSS Feeds ◦ Consider Company IR RSS Feeds › Direct communication with relevant analysts / stakeholders › ‘Fact Sheet’, Press Release, Proxy, etc. ◦ Consideration of Corporation Actions Taxonomy PwC 47 RSS Feeds – html vs. XBRL Direct vs. Indirect communications RSS feeds of XBRL are actionable by software and can be analyzed immediately; while the html pages may require some degree of human intervention. The company may want to consider RSS feeds with XBRL files. XBRL html PwC 48 Company RSS Feeds - Financial There is no content in the Company RSS Feeds for Financial content. This provides an opportunity to publish relevant financial content in the XBRL structured format that is highly reusable by analysts. PwC 49 Company Earnings Press Release PwC 50 Structured IR Content Enables automation of information relationships Structured content enables automation of content development and relationships with broad range of relevant supporting content. PwC 51 What is Going on Around the World PwC 52 How many countries have migrated their regulatory reporting format to XBRL? XBRL in the G20: AR, AU, BR, CA, CN, FR, DE, IN, ID, IT, JP, MX, RS, SA, ZA, KR, TR, UK, US, EU XBRL outside of the G20: AE, BE, BM, DK, FR, HK, IE, IL, LU, NL, PL, RO, SG, TH, TW, ES, SE, CH XBRL Planet and XBRL International provide useful up to date information on country compliance projects “Convergence” redefined = “Standard Business Reporting” • Regulatory burden reduction via convergence of agencies compliance processes • Harmonisation/reduction of reported data using IFRS Taxonomy • Regulators & business sharing a common language • SBR Mandated by Dutch MoF effective 1/1/2013 Official SBR participants – AU, CA, CN, IN, JP, NL, PL, SG, TW, TH, UK PwC Key: Red = In production; Blue = In development 53 IFRS Taxonomy Collaborative development expanding to capture broadest range of common reporting disclosure concepts. PwC 54 SBR in Australia Reducing the reporting burden for business PwC 55 SBR in the Netherlands Reducing Reporting Burden PwC 56 UK HMRC iXBRL Mandate Each of the 1.6 million UK companies required to file a tax return is affected by HMRC's new requirement for XBRL electronic tags to both the tax computations and the statutory financial statements. The requirement takes effect for returns submitted after April 1, 2011. Companies with legal entities in the UK should consider these new requirements. Learn more here: http://www.pwc.co.uk/eng/issues/xbrl.html PwC 57 What can you do PwC 58 Agreed Upon Procedures Creation of Extensions and Use of USGT Tags Tagging of Note Disclosures Tagging is Accurately and Consistently Applied Completeness of XBRLtagged Data PwC 59 Additional Opportunities to Consider Benchmarking of tagging over USGT standard tags and extended tags to peer companies. Map existing SEC instance document to revised SEC USGAAP taxonomy. For example: US GAAP Taxonomy Transition from 2009 to 2011 PwC Training/knowledge sharing on SEC requirements, considerations and process implications, training on more detailed year 2 taxonomy mapping requirements. Assessment of readiness and/or implementation options, tools, processes, controls. In a Built - In model: Process and control assessments related to standardization of internal reporting and compliance processes. Assess compliance with certain EDGAR Filer Manual and other validation rules. 60 Appendix A – Data Aggregators vs. Company Reports PwC 61 Sample Data Aggregator Distortions Following are a few example of the distortion and omission that exists within the data that supply chain data aggregators provide to the analyst community. These are examples from the publicly available query sites. Items highlighted in the red boxes reflect disclosures that are “different” between what the company reported and what is available via data aggregator feeds available to the analyst community. Typically, the level of detail is normalized into summary concepts that tend to limit company specific disclosures. PwC 62 Company vs. Google Finance (Income) PwC 63 Company vs. Yahoo Finance (Income) PwC 64 Company vs. Google Finance (Assets) PwC 65 Company vs. Yahoo Finance (Assets) PwC 66 Company vs. Google Finance (Liabilities) PwC 67 Company vs. Yahoo Finance (Liabilities) PwC 68 Company vs. Google Finance (Cash Flow) PwC 69 Company vs. Yahoo Finance (Cash Flow) PwC 70 Appendix B - Resources PwC 71 Other ‘Built-In’ Resource Articles • ‘Standardize to Streamline’ • ‘Making Sense of XBRL in the US and the UK’ • FEI Issue Alert: “Year 2 of the SEC’s XBRL Mandate: Caution and Opportunities on Compliance Requirements” • FEI Magazine Article: “The Time is Right for Standard Business Reporting” • FEI Magazine Article: “Benefits of Comprehensive Integrated Reporting” • Breathing New Life into Old Systems with XBRL GL – Wacoal Case Study PwC 72 PwC Webinar: How to make the best out of the XBRL situation? The May 11, 2011 webinar covers: Rules: Mandatory SEC XBRL requirements, specifically, implications of the transition from year 1 to year 2 as well as the end of the modified liability provisions for XBRL submissions. Results: Reporting considerations and insights including common errors and issues, ramifications for poor quality reports, and reporting best practices. Rewards: Compliance process and control enhancements realized by companies migrating from outsourcing/bolt-on to built-in implementations. Also, a clear answer to the "Who is using XBRL?" question directly from a leader in the Research community. Rest of the World: Transition of regulatory compliance processes from paper to the Internet by governments around the world and the related company considerations. Recording Access: PwC http://event.on24.com/r.htm?e=302048&s=1&k=16042203D8FF3360662148188178923C 73 Automating the last mile The role of XBRL in streamlining financial reporting PwC webinar on “Automating the last mile: The role of XBRL in streamlining financial reporting” Recording Access: https://www302.livemeeting.com/cc/pwclivemeetingroom/view?id=4FQZP6 PwC 74 AICPA ASEC XBRL ASSURANCE TASK FORCE PROPOSED PRINCIPLES AND CRITERIA FOR XBRLFORMATTED INFORMATION COMMENTS REQUESTED BY JULY 15, 2011 Primary Criteria: Completeness Mapping Accuracy Structure PwC 75 Contact Information Michael White Michael.s.white@us.pwc.com (720) 931-7589 PwC 76 This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, [insert legal name of the PwC firm], its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. © 2011. All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers LLP which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity. 77