In my last post I pointed out that financial integrity needs to exist in financial reports whether the financial report exists in the medium of paper or in the medium of XBRL.
In this post I want to elaborate on what financial integrity is.
I want to look at defining "financial integrity" by summarizing all the different inputs I have, looking at them, and then coming up with one concise definition. These are the inputs I have.
A Broad Definition
Financial integrity can be broadly defined as making sure a financial report is correct, consistent, complete, accurate and other such overarching terms. While these terms do encompass a great deal, this definition is still too vague.
Taking an XBRL Validation Perspective
Drilling down a little more and taking more of an XBRL perspective of financial integrity, I put together a list of the different types of XBRL validation which needs to be performed in order to make sure financial information expressed in the medium XBRL is correct, consistent, complete, and accurate. Below I have provided that list, a brief explanation of the item, and reconciled the list item to the overarching terms:
- Edgar filer manual (EFM) validation. Tends to be more syntax related, meta data related, some light semantics. (Relates to: correctness, consistency, completeness)
- US GAAP Taxonomy information model validation. Tests to be sure you are creating this such as your [Table]s, [Roll Forward]s, roll ups, and hierarchies consistent with the US GAAP Taxonomy. (Relates to: consistency)
- US GAAP Taxonomy extension points and extensibility rules validation. Tests to see if where you are extending the US GAAP Taxonomy is appropriate and if you are creating logical extensions. (Relates to: consistency)
- US GAAP financial integrity validation within a [Table]. Tests to be sure that each [Table], be that [Table] explicitly defined or implied, is "internally consistent and correct". (Relates to: correctness, consistency, completeness, accuracy)
- US GAAP financial integrity validation between [Table]s. Tests to be sure that explicit/implicit [Table]s are properly related to one another. (Relates to: correctness, consistency, accuracy)
- Industry standards validation. Are industry practices being followed if the applicable industry is different than US GAAP. (Relates to: correctness, consistency, completeness)
- SEC previewer rendering validation. Test to see how the XBRL instance renders within the SEC previewer. (Relates to: consistency)
- Comparability validation. Tests to see how well an XBRL filing can be compared to a similar XBRL filing. (Relates to: consistency)
- Business rules validation. Tests to be sure all computations are expressed and work correctly including roll ups, roll forwards, dimensional aggregations, and other more complex computations. (Relates to: accuracy)
- Disclosure checklist validation. Tests to be sure that all required disclosures exist. (Relates to: completeness)
- Key performance indicators validation. Tests for wild fluctuations against internal benchmarks and industry averages. Much like an auditor's variance analysis. (Relates to: correctness, consistency, accuracy)
- Comparison to prior period filings validation. Tests to see if the current period filing beginning balances tie to the prior period filing ending balances. (Relates to: correctness, consistency, completeness, accuracy)
- Best practices validation. Other common practices. (Relates to: correctness, consistency, completeness, accuracy)
An Auditor's Perspective
I used to be an auditor long, long ago. One of the final steps in issuing a financial report is making sure all the pieces tie together. This is my short list of the types of things I would have to look for.
- Balance sheet. Does the balance sheet balance? Does everything foot? Does equity tie to the statement of changes in equity. Does cash tie to the cash flow statement?
- Income statement. Does everything foot? Does net income tie to the statement of changes in equity? Does net income tie to the cash flow statement?
- Cash flow statement. Does everything foot? Does cash tie to the balance sheet. Does net income tie to the income statement? Do the increases (decreases) in current assets and liabilities tie to the balance sheet changes?
- Statement of changes in equity. Does everything foot? Does equity tie to the balance sheet? Does net income tie to the income statement?
Again, this is a the short list, but you should get the point.
FDIC Validation Process
This may seem odd, but I think this should be included. I learned a lot about verifying financial reports from working on the XBRL implementation by the FDIC (US Federal Deposit Insurance Corporation). The FDIC has somewhere between 1800 and 3600 business rules (I have heard both numbers, not sure which is right) that every bank call report must pass before the report is even excepted by the FDIC as a submission. This is in addition to all the XBRL syntax validation and the other FDIC filing requirements. Some of these business rules are made available to filers, others are "secret" rules that the FDIC uses for regulation purposes and does not make available to filing banks. Another class of rule the FDIC has is something they call "reportability rules". Those rules are driven by the type of filer. Things like, "If you are this type of filer, then you have to report this...." and "If you report this....; then you have to report this...."
Defining Financial Integrity
OK, so this is my take on the definition of financial integrity. Sure, things need to be complete, consistent, correct, and accurate. But first you need a framework to work within. When you build a boat you start by building laying the keel. When you build a house you start by laying the foundation. If the keel of the boat is sound or the foundation of the house is sound, then you are off to a good start. But if you don't lay that keel correctly or lay a true foundation to a house, you will never be able to create a good boat or a architecturally sound house.
This is the foundation of a financial report (this is for US GAAP):
- Balance sheet. The balance sheet always has the concepts "Assets" and "Liabilities and Equity". The value of both of those concepts MUST have the same value (i.e. the balance sheet balances.). Depending on the industry you might have "Current Assets" and "Current Liabilities" (i.e. a classified balance sheet). The computations for "Assets" and "Liabilities and Equity" foot. (In XBRL terms, you have XBRL calculations which prove that the balance sheet computations add up correctly, things roll up.) One could hang other things off the "Assets" and "Liabilities and Equity"; but you definitely have those two concepts and anything that does hang off those concepts adds up correctly.
- Income statement. It seems that there are two concepts what every company will always have: (1) "Income (Loss) from Continuing Operations before Equity Method Investments, Income Taxes, Extraordinary Items, Cumulative Effects of Changes in Accounting Principles, Noncontrolling Interest", (2) "Earnings Per Share, Basic". There is a "step down" in the income statement, companies only have the steps if they have that component. The components are: Income from Equity Method Investments, Discontinued Operations, Extraordinary Items, Cumulative Effect of Change in Accounting Principle. If you have a noncontrolling interest, then net income is also broken down by what goes to the parent and what goes to the noncontrolling interest. If you have preferred dividends you need to break those out. You may, or may not, break Income from Continuing Operations out for Gross Profit. But, it seems that (a) one always has Income from Continuing Operations (i.e. if they don't, are they a viable business?), (b) some easy to figure out step down of net income, and (c) earnings per basic share. (If I am wrong on this, this is the statement where I am probably making a mistake. There may be a better way of explaining this.)
- Cash flow statement. Every company has the concept "Cash and Cash Equivalents, Period Increase (Decrease)" (per the US GAAP Taxonomy) or I call it "Net Cash Flows". That concept can be broken down into three other concepts: Net cash flows from operating activities, Net cash flows from investing activities, and Net Cash Flows from Financing Activities. Companies will highly likely have operating cash flows, it could be that they have no financing or investing cash flows. It is conceivable that they don't have operating cash flows because they are not operating companies. There are two other things which could be included in "Net Cash Flows": Effect of exchange rate on Cash and Net Cash Flows from discontinued operations. Now, discontinued operations could be configured in a number of different ways, but it is always a part of "Net Cash Flows". Effect of exchange rate on cash is a different story, I am getting two different messages. Fine, one must be true. Either it is ALWAYS part of "Net Cash Flows" (this is what I see in 99% of filings) or it could be part of the reconciliation of cash (i.e. not part of "Net Cash Flow"). Whatever concept is used for "cash" in the cash flow statement must be the same concept used on the balance sheet. This business rule is ALWAYS true: "Beginning Cash + Net Cash Flows = Ending Cash". (Or, alternatively, if exchange gain is NOT part of "Net Cash Flows"; then: "Beginning Cash + Net Cash Flows + Effect of Exchange Rate on Cash = Ending Cash")
- Statement of Changes in Equity. The beginning and ending balances tie to the balance sheet. Net income shown in this roll forward ties to the income statement. (All the statement of changes in equity is, is a bunch of [Roll Forward]s. There is a [Roll Forward] for every equity account and shares and there is a [Roll Forward] for all the periods shown on the balance sheet.
- Policies. Some policies relate to financial statement line items. Some don't. If they do tie to a line item, the fact that it does tie should be expressed.
- Disclosures. Some disclosures relate to financial statement line items. Some don't. The ones that do tie to those line items (i.e. they are the same XBRL concept in the statement and in the disclosure). If the disclosure is supposed to foot, some business rule exists to show that (either an XBRL calculation or an XBRL formula). Things that should be tied together are tied together, be they because they relate to the same class of stock, same entity, same class of some other line item, or in some other thing which should be tied together.
So that is the "keel" or "foundation" of a financial report, be that report expressed in the medium "paper" or in the medium "XBRL". Clearly, whatever medium is used, XBRL or paper, the information communicated must be interpreted the same by the user of the information because it is the same information. If that cannot happen, XBRL will never be able to replace paper and therefore paper will always need to exist.
Maybe I don't have the foundation properly expressed or 100% adequately expressed. That is not really the point here. If I don't have it right or adequate, fine, define it correctly and define it adequately and let that be the foundation. If there is no foundation, comparability will never happen. And if comparability cannot happen, what is the point of tagging all this information in XBRL? Seems to me that is the goal here, to enable easier comparability at some level. I am not really trying to define the level of comparability. The marketplace will do that. But, it seems to me that this base is pretty hard to dispute. This is pretty much meat and potatoes, it seems to me.
If I am wrong and US GAAP is not even comparability at this level, then it seems we have other issues to deal with.
So that is what I see. What are your thoughts? Do you have a better definition of financial integrity or believe that financial integrity is not important? Post a comment.