IBM Software recently held a user group conference called Vision 2011 that focused on its Clarity Systems acquisition’s users but also covered broader finance department topics. For me, the highlight of the show was the continued evolution and enrichment of the Clarity FSR external reporting application designed to automate the close-to-report cycle. This process is commonly referred to as “the last mile of finance,” a term coined by a now-defunct company, Movaris, and adopted by Gartner thought not too important as they service IT and not finance departments.
Finance departments have long needed to automate the assembly of periodic documents that combine words and numbers. These documents include the quarterly and annual reports public corporations are required to submit to the United States Securities and Exchange Commission (SEC), the Canadian Securities Administrators, the United Kingdom’s Financial Services Authority (FSA) and other agencies. Historically, companies have cobbled together these filings from bits of text created by a variety of people in several departments (chiefly finance and legal), using numbers that come from a range of sources. These sources include accounting data from a consolidation system, other enterprise systems, data warehouses and spreadsheets that track headcount, leased premises, stock performance, advertising expense and executive compensation, to name just five.
FSR automates the document creation process, eliminating the need to perform repetitive, mechanical functions and reducing the time needed to ensure accuracy and the time spent managing the process. Manually assembling this information into a document has always been a chore, even after word processing and spreadsheets were adapted to this purpose decades ago. These filings are legal documents that must be completely accurate and conform to mandated presentation styles. They require careful review to ensure accuracy and completeness. Complicating this effort recently are increasingly stringent deadlines, especially in the U.S. Anyone who has been a party to these efforts knows that there can be frequent changes in the numbers as they are reviewed by different parties, and those responsible need to ensure that any change to a number that occurs (such as the depreciation and amortization figure) is automatically reflected everywhere that amount is cited in the document (in this example, that would include the statement of cash flows, income statement, the text of the management discussion and analysis and the text or tables of one or more footnotes). Those managing the process spend a great deal of energy simply checking the document to ensure that the various sections include the latest wording, that the numbers are consistent in the tables and text, that amounts have been rounded properly (which can be really complicated) and that the right people have signed off on each and every part of the filing. FSR workflow-enables the process, meaning that handoffs are automated, participants get alerts if they haven’t completed their steps in timely fashion, and administrators can keep track of where everyone is in the process.
Despite the fact that technology (specifically document management systems) has been widely available to automate the close-to-file process for a couple of decades, it was not widely adopted by finance departments. Some of this reflected the cost and effort required to deploy these heavy-duty systems and some was the usual “we’ve always done it this way” resistance to change. To be fair, about 50 years ago the SEC’s 10-K (annual report) and 10-Q filings were rather sparse and there wasn’t much to check. They have only gradually become the data- and disclaimer-rich documents we know today. Companies would have kept pulling these reports together manually except that the SEC mandated tagging that they use eXtensible Business Reporting Language (XBRL). This represented a tipping point in the workload because although tagging the basic financial statements is not labor-intensive, the broader requirement for tagging footnotes is. This has been enough for many companies to adopt tools like Clarity FSR.
FSR, built on Microsoft software components, takes advantage of a wide familiarity with Excel and Word to reduce the amount of training required of end users. The time required to prepare the document is reduced, since once a company has configured its system to establish, in effect, a template, it’s relatively easy to create each quarterly or annual XBRL-tagged filing for the SEC. IBM Clarity has continued to incorporate new techniques in FSR for simplifying and further automating the creation and tagging processes.
The users conference included a presentation by Time Warner, which was an early adopter of FSR. Its reasons for using the software to do the work, rather than relying on a third party (such as a financial printer or service provider), seem sound to me. Namely, it saves time and reduces the effort required to produce an accurate and complete document. Moreover (and personally I think this is extremely important), it gives those responsible for external financial reporting, the legal department and the company as a whole greater control over the process. Corporations can have more time (even a crucial day or two) to review what is in the document and concentrate more on what the document should contain rather than defaulting to what’s practical in the time allotted. (As they like to say in auditing, the threshold of materiality rises exponentially as deadlines near.)
Although FSR was designed specifically for the SEC’s XBRL mandate, once FSR is in place, it can be used in many other ways. For example, Time Warner is using it to file statutory reports in the U.K. The number of jurisdictions that require XBRL-tagged filings is increasing worldwide, and not just for periodic corporate financials. This is especially true for financial services companies engaged in banking and insurance. Companies can and should also offer their financial press releases in a tagged format to make them easier for analysts and investors to incorporate these numbers in their models at the time earnings are announced. (This was one of the reasons why XBRL was created.)
Beyond external financial reporting, FSR can be used by finance organizations to create any periodic document (even ones simply for internal consumption) that combines words and numbers. This would be especially useful where multiple people must collaborate to produce narratives and collect data from multiple sources. It can cut the amount of time and effort required to produce them and it gives whoever is responsible a valuable administrative tool for automating workflows and monitoring the status of each component.
FSR has evolved from its original release, with ongoing improvements that have increased the efficiency of the process. I think finance departments in midsize and larger corporations, especially public companies, can benefit from utilizing a tool such as FSR. I also believe most companies that are outsourcing the tagging process and have avoided automating their document assembly are making a strategic mistake. The benefits of automation are greater and the net cost of using this sort of tool is much lower than they probably realize. I recommend that companies that are considering a tool for automating their periodic external filing include IBM Clarity FSR in their software evaluation list.
Robert Kugel – SVP Research