XBRL vs. Custom XML NAESB eForms Subcommittee FERC – Division of Energy Market Oversight June 18, 2018

Background On April 16, 2015, the Commission issued an order announcing its intention to replace its current electronic filing format Visual FoxPro (VFP) for many of the forms submitted by the industry. VFP is no longer supported by the developer, Microsoft Corporation. In the order, the Commission stated it believed the best replacement format for VFP is XML.

Background There are two XML options available as the format for data submission: Develop a custom XML submission Develop an XBRL submission, a standard built upon the XML format The Commission seeks input on the XBRL data format.

XBRL Overview XBRL, or eXtensible Business Reporting Language, is an XML standard for tagging business and financial reports to increase the transparency and accessibility of business information by using a uniform format. The XBRL specification is developed and published by XBRL International, Inc. a non-profit consortium of more than 650 companies and agencies. All publicly listed companies are required to use XBRL to submit financial reports to the SEC.

CUSTOM XML VS. XBRL Data Preparation The FERC provides an XML schema. The filer uses the schema to create an XML document for submission. Filers can use standard XML tools to create the XML document. The FERC provides an XBRL taxonomy. The filer uses the taxonomy to create an XBRL instance document. Filers can use standard XBRL tools to create the XBRL document. XBRL pros: Data is entered once reducing time and errors, many opensource tools and off-the-shelf tools are available. XBRL Con: Filers needs to install the tool and train their staff.

CUSTOM XML VS. XBRL Data Validation Basic validations (data type validation and XML structure) can be performed with standard XML tools by the filer. Filers can perform a test submission to run validations on the FERC systems. An XBRL taxonomy provides basic validation (data type). The taxonomy can contain all other validations, allowing the filer to validate locally. Filers have the option to perform a test submission to run validations on the FERC systems. XBRL pros: taxonomy allows full local testing before beginning a submission & no manual interpretation of the validation rules from a static PDF or document posted on a webpage.

CUSTOM XML VS. XBRL Data Rendering FERC provides a PDF rendered version of the submissions. The FERC could provide the XML stylesheet (XSLT) to allow the filer to perform rendering locally. FERC provides a rendered version of the submissions in HTML or PDF. FERC could provide rendering code or an XML stylesheet (XSLT) to allow the filer to perform rendering locally. XBRL pros: Rendering info is included in taxonomy, produces both an HTML and PDF document, filer can produce the final PDF that will be in eLibrary on their own system prior to submission.

CUSTOM XML VS. XBRL Data Submission The submission process is the same. Filers can submit via the FERC website.   The website allows the user to login, select the file (XML for eForms Refresh, XBRL instance document for XBRL solution) and submit.  No significant pros/cons.

CUSTOM XML VS. XBRL Data storage and Retrieval The XML document is loaded into a SQL Server forms database. The SQL Server data is made available on the FERC website on a periodic basis. The XBRL document is loaded into a SQL Server forms database. In addition, the data can be loaded into an XBRL database. XBRL pros: automatic backward compatible for refiling previous version forms and data; the filer can at any time view their previous submission on their local system according to how the FERC system would produce the final form.

CUSTOM XML VS. XBRL Form/schedule management Form/schedules are modeled in XML schema, SQL Server and the XML stylesheet (XSLT). The XML schema is used to validate XML submissions. The XML stylesheet is used to render the XML submission into PDF. Changes need to be made by IT. Form/schedules are modeled in an XBRL taxonomy and SQL Server. Rendering information and validation rules are included as part of the taxonomy. Modeling changes in the taxonomy can be made by business users. XBRL pros: one taxonomy for all forms means standard definitions, concepts, and elements across all collections.

CUSTOM XML VS. XBRL Multiple relationships: Hierarchies & Dimensions Would only specify the relationship as part of the definition of an element in the XSD. Would require the development of custom code to accomplish this same functionality. Defines relationships between elements separately from the definition of the element itself. Makes it possible to express more than one relationship among elements. Allows the fields in a hierarchal relationship to share the same properties. XBRL pros: More efficient to manage future additions/changes to parent fields.

Hierarchy relationships: Example The Form 1 field “Total Liabilities and Stockholder Equity” is at the top of a hierarchical relationship with a total of 55 subfields. “Total Liabilities and Stockholder Equity” is the sum of these 55 subfields. XBRL enables all 55 subfields to share the same properties as the parent and an easy calculation of the total.

Shared Definitions: Example A single definition for “Assets” could then be applied to multiple fields, such as “Current Assets” as well as “Prior Years Assets.” A customized XML solution requires separate definition for each of the like fields.

Taxonomy Overview A grouping of financial concepts (known as “elements”) in which each concept is defined and can have multiple labels. The taxonomy defines relationships between the concepts within the group. Public taxonomies have been developed by market constituents and are maintained by XBRL.

Taxonomy Example A single definition for a concept could be applied to all like concepts. For example, the definition for the concept “Assets” could be applied to multiple concepts: “Current Assets” and “Prior Years Assets.” These three concepts (‘Assets’, ‘Current Assets’, and ‘Prior Years Assets’) are defined and presented in the taxonomy as elements. Each concept can have its own set of labels reflecting how the concept appears in a given form.

Benefits Summary Data is managed by business users Meta Data management is centralized Informed filers and data users Access to standardized validation rules Improved Speed of Form rollout Support for resubmissions Allows for adding, amending, and deleting defined elements and relationships without the need for filers to update software applications Makes implementing Commission revisions to reporting requirements easier to code and roll out to the public

XBRL disadvantages Filers can use existing available XBRL open source or off- the-shelf tools to create a submission file, however they need to install the tool and train their staff on the new tool. Training may be required for business users, end user data analysts, and IT staff. Implementing XBRL Solutions directly from VFP may delay the deliverable for Form 1 (but not necessarily for other forms).

Illustrative list of software providers supporting XBRL instances Software Name Web- based Advanced Computer Innovations EDGARsuite   Altova XML Spy RaptorXML Broadridge PROfile (Summit Financial Disclosure) Certent Certent Disclosure Management ✭ CompSci Resources Transform Corefiling Seahorse DataTracks Disclosure Management System Donnelly Financial Services ActiveDisclosure Ez-XBRL Integix Fujitsu Interstage XWAND [1]

Illustrative list of software providers supporting XBRL instances Software Name Web- based Merrill Merrill Bridge ✭ NovaWorks GoFiler Complete   GoFiler Online GoXBRL Oracle Enterprise Performance Reporting Cloud Hyperion Disclosure Management RDG Filings Thunderdome Document Management Portal Workiva Wdesk