XBRL & FEI What, Why and How

1. XBRL & FEIWhat, Why and How Colleen Sayther-Cunningham President and CEO Financial Executives International

2. Who Is FEI? • The professional association of choice for senior-level corporate financial executives • Over 15,000 members from companies both public and private, crossing all industry sectors • CFOs, VPs of Finance, Controllers, Treasurers and Tax Executives • The definitive voice of corporate finance • Advocating for the interests of our members before the SEC, FASB, IASB, PCAOB and Congress • A member-service-oriented organization • Dedicated to the professional development of our members • Peer networking, information, career planning, conferences, publications, research

3. To be the preeminent professional association of choice for the corporate financial executive by: NETWORKING: Providing forums for peer networking KNOWLEDGE: Alerting members to emerging issues ADVOCACY: Advocating the views of financial executives ETHICAL LEADERSHIP: Promoting ethical conduct FEI’s Mission

4. Financial Executives Research Foundation (FERF) • Independent non-profit research affiliate of FEI that offers in-depth objective research on relevant topics • Research publications and alerts • Ask the Researcher • Interactive Forum from peers (FELIX) • Distance learning with FERFPros • Supported by voluntary, tax-deductible contributions and subscriptions from corporations, FEI chapters and individuals

5. FEI Membership • FEI’s membership includes some of the leading CFOs in corporate finance. • Kerrii Anderson Wendy’s International • Susan Decker Yahoo! • Gary Fayard Coca-Cola Company • Robert Lumpkins Cargill, Inc. • Pedro Reinhard Dow Chemical • Jim Schneider Dell Computer • Tom Schoewe Wal-Mart Stores • David Sidwell Morgan Stanley

6. FEI Membership Publicly Traded Companies N=9995

7. FEI Membership Ownership N=9470

8. FEI NationalTechnical Committees • Benefits Finance (CBF) • Corporate Finance (CCF) • Corporate Reporting (CCR) • Finance & Information Technology (CFIT) • Government Business (CGB) • Private Companies (CPC) • Taxation (COT)

9. Transformation of Financial Reporting • Verge of a fundamental transformation of financial reporting practices • Trend towards transparency driven by increased public scrutiny, increased regulatory oversight and the emergence of new technology • Driving a need for new standards for information integrity, reporting transparency and system integration

10. What is XBRL? • Non-techie’s point of view • eXtensible Business Reporting Language • An open global electronic standard for defining financial terms consistently allowing for the exchange and dissemination of corporate reporting information • Each piece of data is assigned a unique, predefined data tag (like a barcode) identifying the information’s content and structure

11. What is XBRL? • Through tagging of data, XBRL will enable • Streamlining of financial reporting processes • Enhanced analysis of financial reports • Can facilitate the acquistion and integration of related financial information within a company’s financial reports • Communication of financial performance more effectively to analysts and investors • Tags give data an identity and context that can be understood by various software applications that allow the data to interface with databases, financial reporting systems and spreadsheets

12. What is XBRL? • Taxonomies • A Standard description and classification system for business reporting and financial data • Tags consist of specific financial data (eg, line items in financial statements) and words or labels (eg, headers in the notes to financial statements) • Taxonomy may, therefore, include a tag for the balance sheet line item “inventory” as well as tags for components (“raw materials”, etc.) disclosed in the notes

13. What XBRL is not • NOT a set of accounting standards • NOT a detailed chart of accounts • NOT a GAAP translator

14. Who is interested in XBRL? • Preparers – Financial Executives • Standard setters • Regulators • Users

15. Financial Executives • Have a critical responsibility to communicate operational results to stakeholders • Growing demand for efficient delivery in an interactive medium • Better decision making • Internal control environment enhanced through less retyping, more system integration, etc.

16. Standard Setters FASB established an XBRL fellow position in 2003 FASB created the XBRL fellowship to investigate ways XBRL and related technologies can be used to improve corporate financial reporting and to develop policy recommendations on XBRL's role in FASB's standards-setting activities. IASB also a supporter of XBRL – in fact, it seems to be getting more traction internationally

17. Regulators • SEC announced in July 2004 an initiative to assess the benefits of tagged data and its potential for improving the timeliness, accuracy and analysis

18. Users • Reduces research costs • Enables improved modeling and comparison

19. SEC Voluntary XBRL Proposal • 2 documents issued Monday (9/27/04) • Proposed Rule that would establish Voluntary XBRL reporting • Concept Release on XBRL

20. SEC Proposed Rule – Voluntary Reporting • Establish a voluntary program allowing registrants to file supplemental financial information using XBRL • Filed via an exhibit to specified SEC filings • Would begin with 2004 calendar year-end reporting • Comment deadline is 30 days after publication in Federal Register

21. SEC Proposed Rule – Voluntary Reporting • SEC would like to study: • Search capability of EDGAR database • Capability to perform financial comparisons amongst registrants • Ability to perform financial analysis (ratios, etc.) • Impact on staff’s ability to review filings more timely and efficiently • Use of tagged data for risk assessment • Compatibility of XBRL with other Commission requirements

22. SEC Concept Release on XBRL • Seeking public comment on: • Benefits of tagging data to improve reporting quality and efficiency • Implications of tagging data for filers, investors, the Commission and other market participants • Adequacy and efficacy of XBRL as a format for reporting financial information • Comment deadline is 45 days after publication in Federal Register

23. SEC Concept Release on XBRL • Essential Elements of Data Tagging • Technology to administer the tags • Standard definitions to describe the tages • A means of presenting and analyzing the tagged data – software, etc.

24. [Release Nos. 33-8496, 34-50453, 35-27894, 39-2498, IC-26622; File Number S7-35-04] XBRL VOLUNTARY FINANCIAL REPORTING PROGRAM ON THE EDGAR SYSTEM AGENCY:   Securities and Exchange Commission. ACTION:   Proposed rule. SUMMARY:   We are proposing rule amendments to enable registrants to submit voluntarily supplemental tagged financial information using the eXtensible Business Reporting Language (XBRL) format as exhibits to specified EDGAR filings under the Securities Exchange Act of 1934 and the Investment Company Act of 1940. Registrants choosing to participate in the voluntary program, expected to begin in early 2005, also would continue to file their financial information in HTML or ASCII format, as currently required. The voluntary program is intended to help us evaluate the usefulness of data tagging in general, and XBRL in particular, to registrants, investors, the Commission and the marketplace generally. A companion concept release also being issued today provides additional information on tagged data and solicits comment on the development of data tagging. BACKGROUND:  All registrants who file with the Commission are now generally required to file electronically on the Commission's Electronic Data Gathering, Analysis and Retrieval System ("EDGAR")…… As discussed in the accompanying concept release, we are evaluating whether tagged data in Commission filings would provide a better means to provide and obtain necessary information and, if so, whether we should permit or require XBRL tagged data in Commission filings.22 The Division of Corporation Finance, Office of the Chief Accountant, Division of Investment Management, and Office of Information Technology have formed a task force to assess the implications of tagged data for filers, investors, the Commission and other market participants.23 In order to test and evaluate data tagging, we propose to allow registrants to supplement their Commission filings by furnishing financial data on EDGAR as an exhibit using eXtensible Business Reporting Language ("XBRL"), beginning with the 2004 calendar year-end reporting season. We currently expect to permit participation by any registrant without pre-approval merely by submitting the exhibit in the required manner. … “we are evaluating whether tagged data in Commission filings would provide a better means to provide and obtain necessary information and, if so, whether we should permit or require XBRL tagged data in Commission filings”.…

25. XBRL: Cheaper, Better, Faster • Reduces the cost of preparing, publishing and analyzing information (CHEAPER) • Increases efficiency of business decisions, real-time reporting, deeper analysis capability, reduces margin for human error, more accessible and easier to use, enhances comparability (BETTER) • Automates the migration of information from systems to financial statements, increases the speed of data use and related decisions, easier to transfer data (FASTER)

26. Key issues in Business & Finance

27. Current Issues impacting financial reporting • Transparency • Timeliness of reporting • Section 404/Internal controls • Fair value accounting • Convergence • Principles-based accounting standard setting

28. How linked to XBRL initiative? • Move towards transparency • If items were tagged and identified more information could be made available for investors and analysts to analyze in the manner that chose to do so • Enhances information acquisition, evaluation and combination • Improves transparency without additional disclosures • Newfound discovery capabilities • Can benefit nonprofessional users

29. “The annual report of the 21st century will not be annual and it will not be a report: it will be an up to date, informative dialogue” - Alan Benjamin in the 21st Century Annual Report (2000)

30. How linked to XBRL initiative? • Timeliness • Capital markets rely on timely and reliable information for the allocation of capital resources • Access information more quickly • Faster processing • Accelerated filing deadlines can be easier to accomplish

31. How linked to XBRL? • Section 404/internal controls • A reporting format such as XBRL could enable easier documentation of internal controls – less manual intervention and massaging • Can enable the integration of disparate systems to optimize the internal control process • Can be a critical tool for enabling compliance with 404 – monitoring can occur real time

32. How linked to XBRL? • Fair value accounting • A lot of concern regarding the reliability (verfiability) of determining appropriate fair value – if assumption disclosures were tagged – management’s choices would be more transparent to users and easily compared with others

33. How linked to XBRL? • Convergence • May be less important in an XBRL environment. Could adapt to country reporting regimes much more easily. • Comparability is enhanced • Complimentary toward objective of a single set of high quality, understandable and enforceable global accounting standards

34. How linked to XBRL? • Principles-based accounting standards • If information is tagged – much easier to determine judgments made by management – analysts could easily adjust for their own analysis • Comparability is enhanced across companies – makes management’s financial reporting choices more transparent – search faciliting technology

35. Now is the time for us to fundamentally enhance Business Reporting using XBRL XBRL benefits all members of the financial information supply chain.

36. What needs to change? • Manual processes for moving business information through to reporting • Need for greater accuracy, efficiency and timeliness • Lack of focus on reusability of external reporting • Deeper analysis hindered • Transparency is only as good as the content (information) provided • Opacity level remains high • Uninformed decisions are the status quo We all need to change…for the better of the capital markets

37. Reporting Internal Control Docs Achieving standards & regulatory compliance Back Office Integrated with XBRL Financial statement consumers Common Standard ERP CRM XBRL ERP External Reports Consolidation Investors Banks SEC IRS XBRL Mgmt Reports XML & Web Services Suppliers • Information service providers • Industry-based supply chain (XML + XBRL) • Internal control system ‘glue’ • Accounts • Policies • Issues Mgmt • … • Real-time auditing • Monitoring • Common structure • Auditable trail • Keys to financial & business information

38. Internal Considerations • Awareness and implementations of XBRL is limited, but growing • Confusion over XBRL as an internal and/or external reporting solution • Enabled software – many vendors have enabled software, but others are in development • Implementing will impact the internal business rules governing data and the people who use/process it • Existing business process will have to be re-examined as part of implementation for efficiencies and risk considerations • Managing and maintaining XBRL taxonomies for internal/external reporting will require an ongoing effort

39. External Considerations • Approach to collaboration • Information requirements (vs. Forms approach to date) • Structured filings • Common vocabularies (taxonomies) • Development strategy (collaborative) • Extensions, tools, archiving • Diverse e-filing methods • Crisp transitions • Communications • Other - Legal record; signatures; security; etc.

40. We are at the turning point! • Increased disclosure and transparency requirements • Need for programmable, efficient and reliable processing – not manual • Companies & auditors seek solutions that automate and reduce the cost of compliance & reporting • Industry expects effective throughput that improves analysis & comprehension of company financial statements • Regulators need similar efficiencies to better understand disclosures, compliance and “results”

41. We are at the turning point! • Key enablers: Standards, technology & connectivity • XBRL embodies both accounting and technology standard: US Financial Reporting Taxonomy • SEC concept release builds momentum for XBRL adoption • Software vendors will soon deliver XBRL-enabled applications • Service providers are converting historical financials into XBRL stores • XML and other technologies are ubiquitous • Widely available inexpensive connectivity

42. A Call to Action • SEC Program • Identify participation candidates • Work with FEI CCR & CFIT Committees to determine positions, tagging requirements and filing methodology (create sub bullets w/specific committees) • Establish a coordinated project plan, identify participant companies, coordinate resources and communicate progress • Market Adoption • Evolve the business cases for companies to improve their reporting supply chain with XBRL • Establish a technical sub-committee within XBRL to drive market enablement • Evolve MD&A taxonomy to reflect “Interpretive Guidance” that will address SEC issues • Corporate Reporting Standards • Leading the discussion on who is responsible for corporate reporting standards • Create a methodology to update standards & policies

43. Questions?