A System for Creating A Single Truth
September 20, 2010
Life used to be so simple.
You wrote the prospectus for your fund in Microsoft Word. You built the charts in Excel. You had the lawyer check the wording. You had the chief financial officer check the numbers. You made the fixes. You sent the final doc to the printer.
But now comes the summary prospectus, the push to deliver any and all information in interactive formats-and a proliferation of funds in your family. Is life really that simple?
Enter electronic publishing, mutual fund-style. The key is to write that paragraph once, create that financial statement once and then re-use it as many times as needed.
A statistic and a date bear out the imperative:
The stat: There are about 8,500 mutual funds in this country. Now, there are now more than 4,300 mutual fund summary prospecti available for standalone delivery, according to New River, a repository of mutual fund documents. Soon, there'll be a summary prospectus created every time a prospectus is born.
The date: Jan. 1, 2011. You may think that the eXtensible Business Reporting Language that the Securities and Exchange Commission is pushing is meant for public companies. These are the folks who want firms to tag every piece of their reports to shareholders in a form that can be used effectively online, in services that interact with investors according to their needs.
But the first day of the new year is when the SEC expects mutual funds to comply with its requirements to provide fund investors with risk-return summaries in XBRL format. This is so investors can download the information directly into spreadsheets and analyze it, using off-the-shelf software, or plug it into investment models. (See http://www.sec.gov/rules/final/2009/33-9006.pdf)
One response is to take those Word documents and Excel sheets and start feeding them into an electronic library. Then, use that library as the basis for rolling out prospecti, summary prospecti and shareholder reports, onto paper or outsiders' computer screens.
Such a system has been developed by Command Financial, a New York company that started out as a full-service printer for financial firms. Its Command Automated Publishing System (CAPS) ends the "one-off" approach to printing a prospectus, replacing it with a system that re-uses every piece of information possible, multiple times, to creating a single truth about a fund, in all forms of output. Printing is just one option, according to President Steve Penders.
The technology was developed six years ago, as it became clear the production of prospecti was going to get more complex. Printing and mailing costs also have driven the changeover from paper to more and more digital files.
Focus groups and one-on-one interviews with mutual fund administrators led to its design. And the development has been in great part overseen by a house lawyer schooled in the Investment Act of 1940 and its requirements. This vice president, Christine Carr, is responsible for creating, developing and implementing instances of the application at client sites.
"The meaningful elements of having a '40 Act attorney on staff is our products have really been developed from a client perspective," said Penders. "They have a sense that somebody who knows how they work has designed the tool."
The core of the system boils down to two components: a language library, which stores pre-vetted statements on the fund's goals, strategies, risks, fees, expenses and past performance; and, a data library, which stores re-usable tables of returns, net asset values and other financial highlights. Financial information on holdings also can be used for annual reports from a fund or fund company. These create building blocks, such as exact wording needed on foreign currency risk. The building blocks can be used not just for documents, but content presented on websites presenting details about the funds.
The application is updated to meet new SEC requirements and user requests. And is used to encourage collaborative editing of documents and routing of drafts in working groups.
"This is not at all a static application," said Bruce Bezpa, vice president of marketing.
The work flow is built around convention. Users prepare the content for the libraries in Word and Excel. "This cuts times down tremendously, in getting the system up and running for people," said Penders.
The system takes in the paragraphs and pages of data and provides "full blacklining" of any changes, in his term. In effect, any changes inside the system become part of an official audit trail.
The system also is designed to enforce SEC rules and confirm exceptions. If, for instance, 10 years of results are needed and the fund only has eight, a manager must sign off on that exception in the system. And give an explanation, in the process.