Through the SEC’s ‘21st Century Disclosure Initiative‘ announced in January 2009, and their demand that Fortune 500 companies start XBRL tagging of financial statements and footnotes this year, it’s clear that greater transparency associated with financial reporting and transactions is seen as one of the steps towards improving the ability of investors and lenders to analyse and compare reports of financial performance and strategic declarations. By adopting such a standard, the SEC is seeking to provide investors and lenders with greater confidence in the results of their analysis because there is a defined taxonomy that ensures they are analysing and comparing apples to apples in all aspects of relevant financial statements.
That’s good, it’s helpful and the derived confidence will be further enhanced through the involvement of an Assurance Working Group (AWG) that is co-operating with the International Audit and Assurance Standards Board (IAASB) to develop standards around how XBRL information can be audited.
Whilst XBRL was initially designed to allow standard tagging of financial reporting, it also can be used for financial statements around transaction information, discrete projects and initiatives, etc. It would seem, therefore, that if XBRL tagging could be extended to encompass risk and control information by introducing an extended taxonomy for that, then, perhaps, a far more meaningful value could be associated with those financial statements, or the validity of them could be better trusted.
When Credit Default Swaps (CDS) were sold on, and on, and on, imagine if along with the financial details of the transaction there was a clear statement about the associated risks, along with details of what mitigation measures were in place and how effective they were likely to be. Surely, that would have allowed the prevention of them being significantly over valued or at least recognition that they were being overvalued despite their associated risks.
Ultimately the whole issue of trust is at the hub of the financial crisis we find ourselves in and, interestingly, it parallels an observation that the American economist John Kenneth Galbraith made in 1954. He observed that fraud can be easily hidden in the good times, yet it gets revealed in the bad times, which he called the ‘bezzle’. With reference to the great crash of 1929 he wrote,”In good times people are relaxed, trusting, and money is plentiful. But even though money is plentiful, there are always many people who need more. Under these circumstances the rate of embezzlement grows, the rate of discovery falls off, and the bezzle increases rapidly. In depression all this is reversed. Money is watched with a narrow, suspicious eye. The man who handles it is assumed to be dishonest until he proves himself otherwise. Audits are penetrating and meticulous. Commercial morality is enormously improved. The bezzle shrinks.” He also observed that “the bezzle is harder to hide during a tougher economic climate” because of the demand for increased scrutiny.
Applying a similar theory to our CDS example, in the good times the bezzle was large, and there were high levels of trust between the banks and asset management companies, thus, nobody really worried about the increasing risks. But now the bezzle has been revealed, trust has all but disappeared and the market has stagnated.
Hence, it is my belief that additional assurance will be required around financial reporting, particularly with specific transactions, such that a high level of trust can be regained. This will not occur through a high bezzle which exists due to positive market conditions. Rather, it will occur through qualified assurance and tangible evidence of the levels of associated risks and how effectively they are being mitigated. Taking the CDS situation as an example, if the level of associated risk and the efficacy of the control strategy accompanies the transaction the buyer will be better informed and the information will have higher trust.
In my view, therefore, the XBRL taxonomy must extend to include taxonomy around risk and control information.