XBRL for Regulatory Reporting How to do

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XBRL for Regulatory Reporting “ How to do it cost efficiently, quickly and well. ” Phil Walenga, Director of Financial Services UBmatrix Inc. Visit us at: www. ubmatrix. com UBmatrixは業界第一のXBRLソフトウェアを提供します。

Agenda • UBmatrix Solutions and Products • 5 T’s of XBRL – It is ready! • Live Demonstration • A how to do it checklist √ • How long does it take? • Results UBmatrix, Inc. (c) 2005 All rights reserved. Page 2

Solutions • Production Ready XBRL Taxonomies – Major contributor to IFRS and other Financial Reporting XBRL taxonomies, – Contributor to Belgium Bank taxonomy, Dutch Government and COREP – Developed: CRAS, FFIEC, KOSDAQ, Sumitomo Mitsui Bank – Major Contributor to XBRL Best Practices: FRTA, FRIS, Patterns Document, etc. • Production XBRL Solutions – Designed and developed XBRL regulatory system - FFIEC – Designed and developed a centralized, collaborative XBRL service - CRAS – Designed and developed XBRL analytical and publishing system KOSDAQ UBmatrix, Inc. (c) 2005 All rights reserved. Page 4

FFIEC U. S. Call Report “XBRL is the essential ingredient in the success of the FFIEC Call Report Modernization initiative. With the help of UBmatrix, FFIEC has created new XBRL Call Report Taxonomies that incorporate concepts, instructions, calculations and formulas to allow us to automate the workflow process among the three bank regulators – the FDIC, the Federal Reserve and the OCC. ” - Mike Bartell, CIO UBmatrix, Inc. (c) 2005 All rights reserved. Page 5

FFIEC Call Report Modernization UBmatrix contributed: 1. Problem definition 2. Proof of concept and prototype development 3. Requirements development 4. Taxonomy architecture and testing 5. Architecture and design consulting 6. Systems developers and development 7. Licensed software for processing XBRL and managing taxonomies UBmatrix, Inc. (c) 2005 All rights reserved. Page 6

5 T’s of XBRL 1. Technical Specification: XBRL 2. 1 is stable 2. Taxonomies are released 3. Training available for generic and customized solutions 4. Tested high performance applications 5. Tools offering end to end solution UBmatrix, Inc. (c) 2005 All rights reserved. Page 11

Regulatory Reporting Requirements • Operate More Efficiently • Produce More Timely Data • Produce More Accurate Data • Save Money • Reduce Burden • Reduce Risk All these requirements were met with the FFIEC application! UBmatrix, Inc. (c) 2005 All rights reserved. Page 13

Collect Quarterly Financial Reports from 8, 200 banks 2, 157 Line Items 396 Pages of Instructions 3, 119 Formulas Multiple errors per report Data released about 60 days after submission UBmatrix, Inc. (c) 2005 All rights reserved. ptembe 2005 – Se July 1, 30, 2005 r Error-free Reports in 2 Days or (a) Sub Prime Less Loans UBmatrix, Inc. © 2005 All rights reserved 14

Demonstration Outline • Web Based Taxonomy Development – No need for business analysts to know XBRL • Create and Update Concepts • Manage Users, Import and Export Metadata • Reportability and Data Validation Formulas – If( (Month. Of(Context. Period. End. Date) = 3), (cc: RIADXXXX[P 0] + cc: RIADXXXX[P 0]) <= (cc: RCFDXXXX[P 0] * 0. 25) + 10000, TRUE) • Instructions and Edit Explanations • Automatically Update Reporting Tools – Update in less than 1 hour UBmatrix, Inc. (c) 2005 All rights reserved. Page 15

The FFIEC system includes Administrative features as well as the core XBRL ones. System administrators are able to define users, groups, functional entitlements, user notification events and reporting cycles. Notifications are part of the automated workflow built in to the system. Reporting institutions and list of reporting entities can be managed. UBmatrix, Inc. (c) 2005 All rights reserved. Metadata can be imported and extracted.

The “Formula” box at the bottom of the screen enables the user to create and edit data validation formulas Some are complex, referencing many concepts and often spanning several reporting periods. Edit explanations are also managed. Complete testing facility built in. UBmatrix, Inc. (c) 2005 All rights reserved.

Decomposition Analysis (Decision Tree Analysis) Call Report data is used to populate the Uniform Bank Performance Report (UBPR) system that provides a comprehensive analytical tool. UBmatrix, Inc. (c) 2005 All rights reserved.

Key Steps • Learn the basics of XBRL • Select a system to model with well established metadata • Develop a pilot or proof of concept • Work with a proven solution – – Less risk and less cost • Establish working groups to communicate project – XBRL, Submitters, Other Regulators UBmatrix, Inc. (c) 2005 All rights reserved. Page 26

Checklist ü Use a server and web based system ü Include automated workflow ü User, permissions and roles management ü Taxonomy management - concepts, instructions, references, calculations, formulas and formula explanations ü Version control taxonomies ü Instance document management ü Validate data real time ü Test taxonomy and formula ü Data collection software vendor support UBmatrix, Inc. (c) 2005 All rights reserved. Page 27

Formula - Validity '"Charge-offs" on "Loans secured by real estate to non-U. S. addressees" (RI-x Part I, M. 2. , Column x) of $' & cc: RIxxxxx. P 0] & ' must be less than or equal to the sum of the components of "Charge-offs" on "Loans secured by real estate" (RI-x Part I, 1. x. through 1. f. , Column x) of $' & cc: RIADxxxx[P 0] + cc: RIADxxxx[P 0] + cc: RIADxxxx[P 0] & '. Please revise your reported data. The current balance of X must be less than or equal to the sum of Y? cc: RIADxxxx[P 0] <= (cc: RIADxxxx[P 0] + cc: RIADxxxx[P 0] + cc: RIADxxxx[P 0]) UBmatrix, Inc. (c) 2005 All rights reserved. 28

Formula - Reportability 041 - Reporting Status = Agricultural-Small (Existing. Of(cc: RCONxxxx[P 0], false) = false AND (Existing. Of(cc: RCONxxxx[-P 1 Y/-06 -end], 0) > 0. 05 * Existing. Of(cc: RCONxxxx[-P 1 Y/-06 -end], 0) OR Existing. Of(cc: RCFDxxxx[P 1 Y/-06 -end], 0) > 0. 05 * Existing. Of(cc: RCFDxxxx[-P 1 Y/-06 -end], 0)) OR (Existing. Of(cc: RCONxxxx[P 0], false) = true AND Existing. Of(cc: RCONxxxx[P 0], 0) > 0. 05 * Existing. Of(cc: RCONxxxx[P 0], 0))) Each concept is checked against set of questions to confirm institution is submitting correct set of data. UBmatrix, Inc. (c) 2005 All rights reserved. 29

Formula - Quality 'Your bank`s "Charge-offs and recoveries on Credit card receivables" included in the ownership interests carried as securities (RC-S 8. a. + 8. b. , Column C, current minus previous) of $' & (cc: RIADxxxx[P 0] + cc: RIADxxxx[P 0]) - (cc: RIADxxxx[-P 1 Q] + cc: RIADxxxx[-P 1 Q]) & ' seem high when compared to the related balance (RC-S 6. a. , Column C) of $' & cc: RCFDxxxx[P 0] & '. Currently, the sum of the charge-offs and recoveries is ' & ((cc: RIADxxxx[P 0] + cc: RIADxxxx[P 0]) - (cc: RIADxxxx[P 1 Q] + cc: RIADxxxx[-P 1 Q])) / cc: RCFDxxxx[P 0] * 100 & '% of the ownership interests, which exceeds our tolerance of 25%. Please review your reported data, and explain or revise as appropriate. ' Is the outstanding balance reasonable value compared to other time periods? If( (Month. Of(Context. Period. End. Date) <> 3), (cc: RIADxxxx[P 0] +cc: RIADxxxx[P 0]) - (cc: RIADxxxx[-P 1 Q] + cc: RIADxxxx[-P 1 Q]) <= (cc: RCFDxxxx[P 0] * 0. 25) + 10000, TRUE) UBmatrix, Inc. (c) 2005 All rights reserved. 30

Formula - Distribution • New concept • Distribute metadata such as formulas, instructions, etc. based on certain criteria like financial condition. If Financial. Institution<=2, Formulas. High. Rating, Formulas. Low. Rating UBmatrix, Inc. (c) 2005 All rights reserved. 31

Data Collection Tools • Web based – Small amount of data to collect • Desktop tools – Generate. xls from taxonomy and enter data – Submit. xls or. doc and convert to instance document • Create or use SW vendor application – Update accurately and quickly – Map from submitter systems or hand enter data • Submitters systems vendors use taxonomy to generate instance document – Submitter transform into format to visually verify data • Use formulas to validate data UBmatrix, Inc. (c) 2005 All rights reserved. 32

It Depends on……. • High or low data volume processor • Extent, sophistication and pre and/or post data validation • Frequency of reporting • Frequency and volume of changes to requirements – Version control • • Number of analysts and their location Commitment to adopt XBRL for many or few purposes Complexity of application Number of regulators involved UBmatrix, Inc. (c) 2005 All rights reserved. 34

FFIEC Call Report Timeline 9 -2000 1 -2001 12 -2001 2 -2002 8 -2002 6 -2003 6 -2005 7 -2005 8 -2005 10 -2005 Research Join XML Alternatives XBRL US Develop Demonstrate Issue Award Test Enroll Test Process Develop demonstration/feasibility product Senior Executives Request for Proposal Contract to UBmatrix and Unisys End to end test & application accepted All 8, 200 banks into system 100 Bank test 8, 200 Banks UBmatrix, Inc. (c) 2005 All rights reserved. Page 35

Include in timeline • • • Existing metadata conversion to Taxonomy Existing data conversion for sample test data Custom data mappings Custom web UI for Taxonomy Maintenance Custom web UI for Instance document display and management • Custom Instance document validation workflows • Custom desktop clients • Custom ETL for a Data Warehouse or analysis package UBmatrix, Inc. (c) 2005 All rights reserved. 37

FFIEC Performance Metrics • Process 8, 200 banks, 114, 800, 000 data elements • 15 Seconds - XBRL and data validate per bank instance document – 14, 000 to 15, 000 data elements per validation pass • Seven quarters data for every bank reports with 2, 000 data elements – Execute 7, 000 formulas – Report – Approve, Review or Reject • Clean rate of 90% versus 70% UBmatrix, Inc. (c) 2005 All rights reserved. Page 39

XBRL Call Report Benefits • Cost Savings: $26 million over 10 years • Timely Data: 2 days versus 60 days • Accurate Data: validate prior to submission • Independence: business analysts manage the reports – no need to know XBRL • Efficiency: update systems automatically versus manual entry • Burden Reduction: validate data real time, update software from web, reuse data for other regulatory requirements UBmatrix, Inc. (c) 2005 All rights reserved. Page 40

Solutions www. UBmatrix. com See us at our booth or suite for more demonstrations Phil Walenga, Director Financial Services, UBmatrix. Inc. Phil. [email protected] com 1 -989 -837 -5959 Work UBmatrix, Inc. (c) 2005 All rights reserved. 1 -989 -600 -8525 Cell Page