Collaboration in CDR Erik Brown Unisys Corporation September 19, 2006

The Central Data Repository (CDR) Requested by FFIEC Agencies in 2002 FFIEC: Federal Financial Institutions Examination Council Participating Agencies: -Federal Deposit Insurance Corporation (FDIC) -Federal Reserve Board (FRB) -Office of the Comptroller of the Currency (OCC) Vision A Web-based solution that improved the definition, analysis, and management of financial data collected by the FFIEC agencies, using XBRL and Microsoft.NET technologies. Initial Implementation Targeted Call Report Data Entered Production in September 2005

Why Build CDR? Agencies are tasked with regulating Financial Institutions Regulations require reporting of data Reporting requirements are forms which may change Institutions send completed forms to FFIEC agencies CDR goal is to automate this process

Legacy View of Data Public did not have good insight into exactly how data was evaluated Each agency had different view of data

CDR System Requirements What is required to receive and process regulatory data?

CDR System Requirements Financial Institutions have data

CDR System Requirements 1. Electronic method for submitting data

CDR System Requirements 2. Mechanism for creating a shared data definition

CDR System Requirements 3. Use shared data definition in submission software

CDR System Requirements 4. Use shared data definition to validate submitted data

CDR System Requirements 5. Use data definition to present data to agency analysts

CDR System Requirements 6. Call it CDR and utilize XBRL for data interactions

Collaboration in CDR

What is Collaboration? “processes wherein people work together — applying both to the work of individuals as well as larger collectives and societies” - from

CDR Collaboration Areas Individuals Metadata Administrators FI User (Filers) Vendor User Agency Analysts Collectives (organizations) FDIC, FRB, and OCC Software Vendors Financial Institutions Society The Public

Individual Collaboration Metadata Administrators FI User (Filers) Vendor User Agency Analysts

Metadata Administrators Problem: Metadata Management Staff from three agencies need to collaborate to produce a shared Call Report definition (XBRL Taxonomy) that can be provided to agency staff and vendor users Solution: Web UI Web UI allows all staff to share a common view of the metadata and collaborate to evaluate changes and publish final versions.

Metadata Admins and FI Users Problem: Data Quality and Validation Agencies need to electronically communicate the reporting requirements to financial institutions. This includes both what data is required (concepts), required relationships for the data (data validity), and what criteria is used to evaluate the data (data quality) Solution: XBRL Formula Linkbase Extend XBRL to allow agencies to specify edits (formulas) to indicate required data relationships as well as evaluation criteria for the resulting values. Vendors incorporate these edits into their software.

XBRL Formula Linkbase A Collection of Business Rules (Edits) Ensure valid data and quality data Each edit evaluates to True or False (pass or fail) Validity Edits – failure results in rejection Example: sum of values in a column must equal the value reported as the total for this column. Wages + Tips + Dividends = Total_Income Quality Edits – failure results in analyst query Example: total deposits for the current quarter should be greater than the total deposits in the prior quarter. The formula language permits inclusion of prior period data for the associated financial institution. Total_Deposits[P0] >= Total_Deposits[-P1Q]

Metadata Admins and Vendor Users Problem: Taxonomy Validation Changes to the Call Report form must be represented in the CDR system, communicated to software vendors, and verified for use in vendor software and by legacy systems. Solution 1: Notifications Users receive notifications as a result of various events related to taxonomy development. Solution 2: Taxonomy Publication Workflow Generated taxonomies are made available to vendors and agency users for validation and verification before they are published for official use and distribution.

FI Users (Filers) Problem: Reporting Requirements FI Users need to understand reporting requirements before filing their data. After filing, FI Users need to determine the status of their submission without agency intervention. Solution 1: Taxonomy Publication Workflow Vendors incorporate edits into their software, allowing filers to correct reporting errors or validation failures before filing. Solution 2: Notifications The system sends a notification to filers on the status of their submission, including detailed descriptions of edit failures which incorporate filer data values into the explanation.

Two Types of Filer Notifications Pending Notification CDR received it: don’t call us, we’ll call you Rejection Notification Submission was rejected, you need to resubmit Notification includes list and description of each edit failure Failed Validity Edits are always rejected Failed Quality Edits without an explanation are rejected

Sample Quality Edit (R ) Formula If ( (MonthOf(Context.Period.EndDate) <> 3) And (cc:RIAD9106[P0] = 0), cc:RIADA518[P0] >= (cc:RIADA518[-P1Q] ), TRUE) Edit Message for Rejection Notification Income statement items are reported on a calendar year-to- date basis. Therefore, the $ RIADA518[0] your bank reported this quarter for "Interest expense on Time deposits of less than $100,000 in Nontransaction accounts" (RI 2.a.(2)(c)) should be greater than or equal to the $ RIADA518[-1] reported in the previous quarter. Please review your reported data, and explain or revise as appropriate. $1,234,567 $2,345,678

FI Users and Agency Analysts Problem: Data Discrepancies While institutions can ensure that data is reported correctly, the expected validation criteria cannot always be met. As a result, filers require an electronic mechanism for detecting and explaining validation failures in the provided data. Solution 1: Quality Edits Solution 2: Required Edit Explanations The taxonomy requires filers to provide textual explanations for quality edit failures. Agency analysts review these explanations when reviewing submitted data.

Agency Analysts Problem: Submission Review Agencies must verify over 8000 filings in a short timeframe (most in less two weeks). Solution 1: Analyst Assignment Agencies can designate which analysts are to review which institutions (up to 500+ per analyst) Solution 2: Automated Edit Processing Filers are forced to meet all validity edits during submission. Quality edits capture business rules as formulas. CDR applies these rules consistently across all filers. Since system identifies problem reports, analysts can prioritize their time to resolve (not identify) issues.

Collective and Society Collaboration FDIC, FRB, and OCC Software Vendors Financial Institutions The Public

Legacy View of Data Public did not have good insight into exactly how data was evaluated Each agency had different view of data

Collective & Society Collaboration Agencies share a common definition of the data and evaluation criteria Public can view data values and validation criteria

Questions Erik Brown Unisys Corporation