Minutes May 15th 2014

1.     EBA news. 

Incorrect validation rules. (recapitulation of past conference calls)

The European Banking Authority (EBA) issued a list of incorrect validation rules found in its Implementing Technical Standards (ITS) on supervisory reporting. See the press release at 16 April 2014 (and a further revised list dated 19 May 2014).

From an XBRL point of view, there are several roughly factors involved in the issue, factors analyzed in the Eurofiling Workshops as, among others:

Lack of realistic test cases. The reporting framework is so large than prepare ex-ante   realistic test cases never has been a practical option. Even worst, as the actual reports are confidential, no public “realistic conformance suite” would be made available.

Testing procedures: It is common that early-birds reporting entities send draft reports to NCAs, which in turn feeds the EBA with such draft reports.

Taxonomies are “data centric” while validations rules are “from centric”. The taxonomy development is based in the Data Point Modelling methodology, data centric by nature. However, the validation rules are designed by the business experts in a positional Excel-like notation. Positional validation rules are more prone to be affected than data centric ones by minor updates (i.e. creation of new financial instruments)   The “user friendly validation notation” is a recurrent (but yet unsolved) topic in Eurofiling.

Legal complexities: as the validation rules are part of the Implementing Technical Standards (ITS) on supervisory reporting which has legal effects, fixing bugs is more complex than in the traditional software change management. Due to the lack of practical methods of Formal Validation of software, a classical programmers’ aphorism is “each program has at least one bug” with the corollary “when the detected bug is fixed, other hidden bug will appear”.

As good news, the data container (primary items plus dimensions) proved to be stable.

2.     EIOPA news. 

Working in two “Tools for Undertakings” T4U  oriented respectively to Supervisors and Reporting Entities.

3.     ESMA’s ESEF (European Single Electronic Format). 

4.     CEN WS XBRL Project and Standards/Practices.

Eric Jarry & Ignacio Boixo in the slot of Best Practices Board in the XII Conference (Orlando).

5.     Events and AOB.

13 XBRL EU Day & 19 Eurofiling . Presentations published.

Eurofiling recognition & carving to Claudio Bodini.

XBRL Europe recognition & carving to Noemi Di Segni.

[2014-06-09 & 11] 26th International XBRL Conference Orlando (Florida)

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