International Standards Group
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KPMG’s CFO
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KPMG s CFO Financial Forum and IFRS Institute Webcast
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IASB Issues Hedge Accounting Model
September 19, 2012
Enrique Tejerina, partner, KPMG LLP
Mike Gaiso, senior manager, KPMG LLP
Department of Professional Practice
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International Standards Group
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Administrative
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International Standards Group
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Overview of IASB hedge accounting review draft
Current hedge accounting model considered complex, not reflective of risk management and excessively rules basedof risk management, and excessively rules based,
resulting in arbitrary outcomes
Review draft attempts to:
Align hedge accounting more closely with risk management
Take a more principle-based approach to hedge accounting
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Address inconsistencies and weaknesses in the existing model
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Overview of significant changes
Aligns hedge accounting more closely with risk management
■ Fair value option (FVO) for certain own-use contracts
■ FVO for certain credit exposures managed for credit risk using credit derivatives as a substitute for hedge accounting
Cash instruments may be hedging instruments in additional circumstances
Additional exposures may be hedged items:
■ Risk components of non-financial items and non-contractually specified inflation
N t iti d l t f it
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■ Net positions and layer components of items
■ Aggregated exposure
■ Equity investments at fair value through OCI (Other Comprehensive Income)
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Overview of significant changes (continued)
Effectiveness assessment:
■ Qualitative test replaces arbitrary bright lines■ Qualitative test replaces arbitrary bright lines
■ Forward looking only
Hedging relationships may require rebalancing without terminatinghedge accounting
Voluntary termination of hedging relationships prohibited
Time value of purchased options and forward element of forward contracts may be deferred or amortized
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Additional disclosure requirements regarding an entity’s risk management and hedging activities
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Objective and scope
Objective of hedge accounting
To represent in the financial statements the effect of risk management activities when financial instruments are used to manage risk
Objective of hedge accounting
activities when financial instruments are used to manage risk exposures arising from particular risks that could affect Profit or Loss
(or Other Comprehensive Income [OCI] in limited circumstances)
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Scope excludes macro hedging
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Own use contracts
NoCan the contract be settled net in cash or
another financial instrument, or by Executorycontract
Yes
Y
No
exchanging financial instruments?contract
Was the contract entered into and does it continue to be held for the entity's expected
purchase, sale or use?Derivative
Yes
Would FVTPL accounting eliminate or significantly reduce an accounting mismatch
that would otherwise occur?
Has the entity elected FVO?
Yes
No
No
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Has the entity elected FVO?
Yes
FVTPL
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FVO for certain credit exposures managed for credit risk using credit derivatives
FVO as a substitute for hedge accounting
Matching name and seniority
Elected at initial All or part of
recognition or subsequently
Revocable
Recognized (e.g., a loan) or unrecognized (e.g., a loan commitment)
All or part ofcredit exposure
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Difference reported in profit or loss
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Polling question # 1
With respect to the financial instruments project, the Boards will:
A Issue fully converged standards by June 2013A. Issue fully converged standards by June 2013
B. Issue fully converged standards but not until later than 2013
C. Not achieve their goal of issuing converged standards in theforeseeable future
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Cash hedging instruments
Qualifying non-derivative hedging instruments:
■ FVTPL financial instruments except for:■ FVTPL financial instruments except for:
– FVO liability with fair value changes due to credit risk in OCI
– Financial asset or liability designated as FVO to reduce/eliminate an accounting mismatch if designation as a hedging instrument would recreate the mismatch
■ For hedges other than foreign currency, the entire or proportion of a financial instrument must be designated
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Prohibition on designating internal instruments retained
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Additional exposures may be hedged items
■ Specifically identifiable and reliably measurable risk components
Risk components of non financial items– Risk components of non-financial items
■ Groups of items (including net positions)
■ Aggregated exposures
■ FVTOCI investments
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Prohibition on designating internal instruments retained
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Assessing risk
Hedged items – Risk components of non-financial items
Same criteria for financial and non-financial risk components
Assessing risk components for eligibility performed in the context of the particular
market Contractual vs
Separately identifiable
Reliably measurable
market structure to
which the risk relates and in
which the hedging
Contractual vs. non-contractual
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identifiable measurableactivity
takes place
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Evaluating whether a risk is separately identifiable
Is there a contract? Is the risk t l
No
Does the contract specify how the risk
is priced into
Yes
separately considered in
pricing the hedged item
based on externally
Risk not separately identifiable
(not permitted hedged risk)
No
No
is priced intothe contract?
Yes
Risk is separately identifiable (permitted hedged
Yes
yavailable
information?
hedged risk)
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risk if also ‘reliably measurable’)
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Evaluating whether a risk is reliably measurable
Are the inputs to measuring the
effect of the risk observable based
on externally
Are the unobservable
inputs insignificant to the
Risk not reliably measurable
(not permitted
No No
on externally available
information?
insignificant to the measurement? hedged risk)
Yes Yes
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Risk is reliably measurable(permitted hedged risk)
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Polling question # 2
I understand the current IFRS hedge accounting rules:
A Well or very wellA. Well or very well
B. In general, but not in detail
C. Very little or not at all
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Hedged items – Groups
Eligibility criteria of a group of items (including net positions) as the hedged item
■ Consists of (components of) items that would individually be eligible hedged items
■ Items in the group are managed on a group basis for risk management purposes
■ For a cash flow hedge of a group of items whose variability in cash flows are not expected to be approximately proportional to the overall variability in cash flows so that an offsetting risk position arises:
– Hedged risk must be FX risk, and
D i ti t if h th f t t ti t d t ff t P&L– Designation must specify when the forecast transactions are expected to affect P&L as well as their nature and volume
For a net position to be eligible for hedge accounting, all of the individual items comprising the net position must be designated. For example, if an entity has a group of firm sale commitments in 9 months’ time for 100 FC and a group of firm purchase commitments in 18 months’ time for 120 FC it could not achieve hedge accounting by
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commitments in 18 months time for 120 FC, it could not achieve hedge accounting by designating a net position amount of 20 FC. Instead, it would have to designate a gross amount of purchases and a gross amount of sales that together comprisethe net position.
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Hedged items – Groups (continued)
Requirements for designating a component of a nominalamount in a groupg p
■ Designating a percentage or layer component of an eligible group of items must be consistent with the entity’s risk management objective
■ For a layer component of a group of items:
– Layer must be separately identifiable and reliably measurable
– All items in the group would have to be exposed to thesame hedged risk
– Entity can identify and track the group of items
– Change in fair value of the hedged layer in a fair value hedge must consider the effect of any prepayment options of the individual items
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consider the effect of any prepayment options of the individual items that comprise the group
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Polling question # 3
I believe that the current hedge accounting requirements under both U.S. GAAP and IFRS:
A. Are unnecessarily complex under both U.S. GAAP and IFRS
B. Reflect the complexity of the subject and are therefore necessary to ensure comparability of reporting
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Hedged items – Aggregated exposures
Aggregated exposure = non-derivative exposure + derivative
Effectiveness Assessment
Derivative
Nonderivative exposure
Effectiveness assessment and ineffectiveness measurement
Ineffectiveness Measurement
Derivative hedging
instrumentDerivative
vs.
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If aggregate exposure is a hedging relationship, assessment and measurement would be performed at that level
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Hedged items – Aggregated exposures (continued)
Example of an aggregated exposure:
Hedged itemAggregated exposure
10-year variable rate debt indomestic currency
10-year fixed rate debt in a foreign currency
+
10-year fixed tovariable CCIRS
Hedging instrument5-year domestic variable to fixed IRS
variable CCIRS
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An aggregated exposure may or may not be a hedging relationship depending on risk management
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Accounting for qualifying hedges – FVTOCI investments
FVTOCI hedged item – changes in fair value in OCI
Hedging instrument – changes in fair value in OCI
g g
Ineffectiveness in OCI
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Amounts never reclassified from AOCI to profit or loss
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Hedge effectiveness assessment
1) Economic relationship between the hedged item and hedginginstrument must exist
2) Credit risk does not dominate the value changes that result from the economic relationship
3) Hedge ratio used for hedge accounting must equal that actually used for risk management
H d ti t t b i t ti ll i ht d t t h d– Hedge ratio must not be intentionally weighted to create hedge ineffectiveness to achieve an accounting outcome inconsistent with the purpose of hedge accounting
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Although not explicit in Review Draft, link between hedging relationships and risk management objectives will need to be established.
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Hedge effectiveness assessment (continued)
Qualitative or quantitative?
■ At the inception of the hedge relationship and
Must capture the relevant characteristics of the hedge relationship includingsources of hedge ineffectiveness
■ At the inception of the hedge relationship and
■ On an ongoing basis at least upon:
– Each reporting date, or
– A significant change in the circumstances affecting the hedge effectiveness requirements
sources of hedge ineffectiveness
Qualitative or quantitative?
■ Depends on facts and circumstances
■ Derivative in or out of the money is not determinative
■ Qualitative assessment may be appropriate if critical terms of hedging instrument and hedged item match l l li
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or closely align
■ An entity’s risk management is the main source of information to perform the effectiveness assessment
■ May need to change methods if relevant characteristics or sources of ineffectiveness change
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Polling question # 4
I believe that the IASB hedge accounting exposure draft will:
A Affect the FASB’s deliberation process for its hedge accountingA. Affect the FASB s deliberation process for its hedge accounting exposure draft and ultimately affect U.S. GAAP
B. Be ignored by the FASB
C. Be withdrawn by the IASB
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Rebalancing and discontinuation of hedge accounting
■ Rebalancing – Adjustments to the quantities of the hedged item and/or hedging instrument to maintain a hedge ratio that complies with the g g g phedge effectiveness requirements
■ Rebalancing allows hedge accounting to continue in situations in which the change in the relationship of the hedging instrument and hedged item can be compensated for by adjusting the hedge ratio
– Ineffectiveness is recognized in P&LIneffectiveness is recognized in P&L
■ Risk management strategy vs. risk management objective
■ Rebalancing hedging relationships can be complex
■ Hedge documentation including expected sources of ineffectiveness is updated upon rebalancing
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■ Voluntary discontinuation prohibited
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Rebalancing and discontinuation of hedge accounting (continued)
Risk management objectiveDiscontinue
hedge
Nog j
still the same?hedge
accounting
Yes
Have the hedging instrument/hedged item
amounts actuallyused changed?
Rebalance
No
Yes
Outcome must not be
inconsistent with the purpose of
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Continue hedge accounting
hedge accounting
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Accounting for time value of purchased options – Option intrinsic value as hedging instrument
Fair value hedges and cash flow hedges
■ Change in fair value of the time value of a purchased option would be■ Change in fair value of the time value of a purchased option would be recognized in OCI to the extent that it relates to the hedged item
■ Reclassification to P&L depends on whether the hedged item is:
– Transaction-related: nature of hedged item is that of transaction costs
■ For example, hedged purchases and salesp , g p
– Time period-related: nature of hedged item is that of the cost for obtaining protection against a risk over a particular time period
■ For example, hedged inventory for six months
■ Applies to zero cost dollars
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■ Less P&L volatility but more OCI volatility
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Accounting for the forward element of a forward contract –Spot element as hedging instrument
Fair value hedges and cash flow hedges
■ Change in fair value of the forward element of a forward contract would■ Change in fair value of the forward element of a forward contract would be recognized in OCI to the extent that it relates to the hedged item
■ Less P&L volatility but more OCI volatility
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■ Original forward element – amortized to P&L on a rational basis over the period to which the forward element relates
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Effective date and transition
Effective date
■ Annual periods beginning on or after January 1 2015 – consistent with■ Annual periods beginning on or after January 1, 2015 – consistent with the Amendments to IFRS 9
■ Early adoption permitted if all existing IFRS 9 requirements simultaneously or previously adopted
Transition
G ll i■ Generally prospective
– Retrospective application:
■ Required for the time value of purchased options for all hedging relationships where an option’s intrinsic value was the hedging instrument under IAS 39
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■ Permitted for hedging relationships where the spot element of a forward contract was the hedging instrument under IAS 39
– Election must be applied consistently
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Polling question # 5
Overall, do you believe the SEC will decide in 2013 to incorporate IFRS in the financial reporting system for U.S. issuers?p g y
A. Yes
B. No
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Comparison of IASB review draft and FASB ED
IASB Review Draft
■ Comprehensive change
FASB ED
■ Focuses on select key changes■ Comprehensive change
■ Non-derivative financial instruments eligible as hedging instrument in a hedge of FX risk under anyhedging model
■ Focuses on select key changes
■ Non-derivative financial instruments eligible as hedging instrument in a hedge of FX risk in a fair value hedge of a firm commitment or a net investment in a foreign operation
■ Non-derivative financial instruments measured at FV-NI eligible as hedging instrument
■ Hedging risk components of a non-financial item – Eligible if the i k i ifi ll id tifi bl d
■ Non-derivative financial instruments measured at FV-NI prohibited as hedging instrument
■ Hedging risk components of a non-financial item – Prohibited except for FX risk
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risk is specifically identifiable and reliably measurable
except for FX risk
No substantive change from existing practice
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Comparison of IASB review draft and FASB ED (continued)
IASB Review Draft
■ Revocable FVO for certain credit
FASB ED
■ No change in hedging credit risk or■ Revocable FVO for certain credit exposures managed for credit risk using credit derivatives
■ Hedging gross positions – no additional qualifying criteria
■ Hedging net positions, including
■ No change in hedging credit risk or the use of the general FVO
■ Hedging gross positions –similarity test
■ Hedging net positions,nil – eligible if criteria are met
■ Hedging aggregatedexposures – eligible
■ Hedging layer in a fair valuehedge – Eligible
including nil – prohibited
■ Hedging aggregatedexposures – Prohibited
■ Hedging a layer in a fair valuehedge – Prohibited
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■ Effectiveness assessment – Hedge must pass a qualitative test; ongoing testing required
■ Effectiveness assessment – Hedge must be reasonably effective; ongoing testing only required under certain circumstancesNo substantive change from existing practice
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Comparison of IASB review draft and FASB ED (continued)
IASB Review Draft
■ No assumption of
FASB ED
■ No assumption of■ No assumption ofperfective effectiveness
■ Cash flow hedge – retainsthe lower of test
■ Changes accounting for the time value of purchased option and
■ No assumption ofperfective effectiveness
■ Cash flow hedge – no lower of test
■ No change in the accounting for the time value of purchased options or
forward element of forward contracts
■ Rebalancing required in certain cases and allows hedgeaccounting to continue
■ Voluntary discontinuation prohibited
forward element of forward contracts
■ Rebalancing never required and would require hedgeaccounting to terminate
■ Voluntary discontinuation generally hibit d ( ff ti t i ti OK)
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prohibited (effective termination OK)
No substantive change from existing practice
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Questions and answers
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Presenter’s contact details
Enrique TejerinaPhone: [email protected]
Mike GaisoPhone: 212-909-5397mgaiso@kpmg [email protected]
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to
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The information contained herein is of a general nature and is not intended to address the specific circumstances of any individual or entity.
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