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
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 receivenotifications 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: dont call us, well 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
