Feedback on FIN.REP. Implementation by the Industry

Feedback on FIN.REP. Implementation by the Industry November 2007

Main Comments • FIN.REP. should not be made mandatory • Reporting formats differ relating to the XBRL Taxonomy • National Regulators introduce changes and breakdowns which are not compatible with the FIN. REP. Framework • Inconsistency of the FIN.REP. model with IFRS-Rules • National Regulators give interpretations on IFRS- Rules

Harmonized Versioning Policy Proposal November 2007 Proposal from EGFI Panagioti Voulgaris Bank of Greece pvoulgaris@bankofgreece.gr

Harmonized Versioning Policy • Updating Reporting Frameworks • Management of XBRL Taxonomy Editions

Updating Reporting Frameworks • Based on the assumptions: • Maximum once per year changes • Changes will be approved 12 months in advance of first implementation • Changes will be applied by members at the same time • Promotion of stability in the Guidelines • Feedback from the industry at any point • Two types of processes from major and minor changes

Updating Reporting Frameworks GENERAL TIMELINE Public consultation (6 months) Preparation of amendment (5 months) Time for national implementations (12 months) TIMELINE FOR DRAFTING AMENDMENTS Drafting changes (2.5 months) Preparation of amendment (5 months) Time for national implementations (13 months)

Management of XBRL Taxonomy Editions • Edition Numbering • Namespace Naming • Identifying Releases • Taxonomy Physical Location • Process of Publishing New Editions

Edition Numbering Changes based on the degree of impact • In cases where the instance documents are not affected go e.g. from 1.2.5 to 1.2.6 • Other cases go e.g. from 1.2.5 to 1.3.0 or from 1.2.5 to 2.0.0 Case A: Major functional changes will modify first level number Case B: Minor functional changes will modify second level number Case C: Non functional changes will modify third level number

Namespace Naming Case C: Maintain same namespace Cases A and B: New namespaces * Note that versions 1.2.0 through 1.2.6 share the same namespace

Identifying Releases This instruction will be placed at the very beginning of each file which belongs to a COREP or FINREP taxonomy (schema, linkbase or any other XML file): <?taxonomy-version 9.9.9?>

Taxonomy Physical Location Any taxonomy released will be available on the official website of the COREP and FINREP projects. Each file associated with a taxonomy release will be located at a new URL according to the following schema: http://functional_version_base_location/release/file “http://functional_version_base_location” is a common URL for each maintenance release of the same functional version, and "release" is the prefix "vr" followed by three integers separated by points. E.g. the file “t-ca-2006-07-01.xsd” of version 1.2.5 will be addressable at the URL: http://www.c-ebs.org/eu/fr/esrs/corep/2006-07-01/vr1.2.5/t-ca-2006-07-01.xsd

Taxonomy Physical Location For each functional version, the last maintenance release will be available at a fixed URL according the following schema: http://functional_version_base_location/file E.g. the file “t-ca-2006-07-01.xsd” of the last maintenance release of the functional version 1.2.x will be addressable at the URL: http://www.c-ebs.org/eu/fr/esrs/corep/2006-07-01/t-ca-2006-07-01.xsd Note that, as opposed to the former URL, this one does not include the release number.

Process of Publishing New Editions Each new edition includes: • List of changes to previous editions • Text document with description of changes • A visual comparison • Printouts of the link bases

Feedback on FIN.REP. Implementation by the Industry