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30working days until first submission of REP via GABRIEL in XBRL format.There are four points to nsider leading up to REP;Are you in spe?Are there any delays to the REP submission date?What’s involved in REP submissions?Changes in validations and what’s yet to me.
By now,all but the largest firms will typically be in one of three situations as the first submission date for REP approaches.They will be:
Using a simple system internally,or having outsourced mpletely
Exploring their options (better hurry up)
Aren’t aware of the imminent REP submission dates (ouch)
Here are 4key points to nsider:
(1)Are you in-spe?
A uple of things to make clear to firms:Whether they are in-spe for the upming REP deadline and,if they are,details of the submissions.
For Investment Firms,the introduction of REP has meant a new classification of what were BIPRU firms;those that are now IFPRU firms are subject to REP reporting.
The classifications are:Full-Spe IFPRU firms,Limited Activity IFPRU firms,Limited License IFPRU firms,and those holding client money.
There are a few exceptions -those firms who do execution only,portfolio management and/or don’t hold client money –which aren’t affected by REP for the time being.
(2)Are there any delays to the REP submission dates?
No delays -unlike many previous regulatory deadlines,the first REP submission date has not been delayed.The deadline to submit GABRIEL returns via XBRL is Friday 30th May 2014–although some firms may have been granted an extension over the weekend,making their final submission date Monday 2nd June.
At this late stage,firms who have yet to identify how they will reach these deadlines to make their XBRL report submissions will have to either:
(1)Appoint an acuntancy or advisory firm with some form of XBRL nversion tool to mplete the reports on their behalf OR
(2)Select a system to use themselves.
(3)What’s involved in making REP submissions?
Understanding the existing changes and new regulatory reporting requirements especially the level of granularity and the quantity of data that is required –as well as significant template changes between for example the disntinued FSA003and the new REP CA1-5(and note you won’t be able to mplete a REP on GABRIEL!)
llecting the data (which may me from IT/acunting systems or from a 3rd party and/or external acuntant)
nverting the reports into XBRL format.Is the XBRL right?Is the data valid?Is it in the rrect format?Firms should be aiming for at least the start of May to llect and allocate all the data.
(4)Changes in validations
Right now,as the validations provided by the European Banking Authority (EBA)include some that do not work,it is imperative that the solution chosen,whether external or manually built in-house,allows transmission in XBRL format despite any validation failures (where EBA ntradictory validations cannot be passed).
It is also important that the solution highlights clearly which validations have failed.Recent validations have been downgraded from a ‘critical’level to ‘warning’level by the regulators,who have declared it is important that firms attempt to pass as many validations as possible to the best of their ability.
(5)What’s yet to me –there’s more!
The amount and mplexity of work needed for firms to report on a Business As Usual (BAU)basis has increased significantly with REP and is ntinuing to do so as new parts of the EBA regime me into spe (e.g.FINREP at the end of September 2014,then Asset Encumbrance,and in 2015“LIQREP”i.e.Liquidity verage RATIO and Additional Liquidity Monitoring Metrics ALMM).
As well as the preparation and submission of the reports,there is also the need to run prior period sign-offs in parallel with new report preparation,which is best achieved when there is a high level of nfidence in the quality of the originating data and minimum manual intervention has taken place.
With the increased mplexity,quantity and granularity of financial reporting brought about by harmonisation across the EU,perhaps firms will look to automate more of their financial reporting.
中文新闻:http://www.xbrl-cn.org/2014/0523/102363.shtml |