Does IFRS 13 Improve the Disclosure of the Fair Value Measurement?

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1 DOI./s--- GSTF Journal on Business Review (GBR) Vol.., vember Does IFRS Improve the Disclosure of the Fair Value Measurement? An empirical analysis of the real estate sector in Europe Donatella Busso Received Oct Accepted v regardless of whether that price is directly observable or estimated using a valuation technique. The objective of using a valuation technique is to estimate the price at which an orderly transaction to sell the asset or to transfer the liability would take place between market participants at the measurement date under current market conditions. IFRS identifies three widely used valuation techniques: the market approach, the cost approach and the income approach. Each valuation technique requires the use of that could be observable or not observable in active markets. IFRS establishes a fair hierarchy that categorizes the to valuation techniques used to measure fair into three levels. Level are quoted prices (unadjusted) in active markets for identical assets or liabilities. Level are other than quoted prices included within Level that are observable for the asset or liability, either directly or indirectly. Level are unobservable for the asset or liability. The fair hierarchy gives the highest priority to Level and the lowest priority to Level. Entities must categorize the fair measurement within the three categories, according to the lowest level input that is significant to the entire measurement. The new standard enhances s about fair measurement in order to help users of financial statements to assess the valuation techniques and used to develop fair measurement. IFRS par. states to be provided when fair is used on a recurring basis or on a non-recurring basis. Abstract The paper presents the results of an empirical analysis on the of the fair measurement in the real estate sector following the introduction of IFRS. Fair is an important criterion for IFRSs with many uses stated by different standards and over the years an intense debate has arisen about both the usefulness of fair and its definition. In the B issued a new standard about fair, its definition, its measurement and the related. The effective date of IFRS was st January. The introduction of IFRS is an opportunity to verify the state of art of the application of fair as a subsequent measurement. Furthermore, the paper aims at verifying whether the introduction of IFRS leads to an improvement in the reported in the notes. Focusing on investment properties, the paper aims at verifying the effects of the first application of IFRS in the real estate sector, by means of an empirical research of Italian, French and German groups listed on the. A total of, items were hand collected. The results show that the fair model is used in % of cases of real estate companies which held investment properties. Disclosures about fair measurement required by IFRS are reported by many entities, but there are still companies not compliant with the new requirements. Keywords-component: fair, investment properties, real estate, IFRS. I. fair hierarchy, INTRODUCTION Fair is an important criterion for IFRSs with many uses stated by different standards: for initial recognition (in nearly every standard), for allocation of the initial amount among its constituent parts (e.g. IFRS [], []), for subsequent measurement (e.g. [], []) and for determination of the recoverable amount (e.g. []). These standards were developed over many years: as a result, there were inconsistencies in the requirements for measuring fair and for disclosing information about fair measurement. In, the B added this topic to its agenda and, after many years of debate, in the B issued a new standard IFRS Fair measurement []. IFRS defines fair and replaces the requirement contained in individual standards, both for measuring fair and for disclosing the measurement. Entities applied IFRS for the first time for annual periods beginning on or after st January. IFRS introduces a new definition of fair that eliminates inconsistencies among different standards: according to IFRS, par., fair is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Therefore, fair is an exit price DOI:./-_.. IFRS must be applied when other standards require or permit the measurement or of the fair of assets, liabilities and own equity instruments. This standard does not specify when an entity should determine the fair, but only how to measure it and how to disclose the measurement. In particular, the requirements are more extensive when fair is used on a recurring basis, i.e. for the subsequent measurement. The standards that require or permit the use of fair for the subsequent measurement of assets and liabilities are reported in Table. TABLE. USE OF FAIR VALUE AS SUBSEQUENT MEASUREMENT IN IFRSS IFRS Use of fair IFRS, par. Investment in subsidiaries held by venture capital organizations or mutual funds, unit trusts and similar entities Measurement of items of property, plant and equipment, par. /n mandatory The Author(s). This article is published with open access by the GSTF

2 GSTF Journal on Business Review (GBR) Vol.., vember IFRS Use of fair, par., par. Measurement of plan assets of post-employment benefit plan, par., par., par., par., par. and par., par., par., par., par. Measurement of retirement benefit plan investments in the financial statement of the retirement benefit plan Measurement of investment in subsidiaries, joint ventures and associates in separate financial statements Investment in associates or joint ventures held by venture capital organizations or mutual funds, unit trusts and similar entities Measurement of intangible assets considered to be not only for properties held for capital appreciation, but also for properties held for rental. In fact, the performance of an investment property can be regarded as being made up of both rental income earned during the period and the changes in fair of future net income. As B pointed out in ( () par. BC ) the fair of an investment property can be regarded as a market-based representation of the of the future net rental income, regardless of whether the entity is likely to sell the property in the near future. The B s preference for the fair model is clear since par. states that it is highly unlikely that a change from the fair model to the cost model will result in a more relevant presentation. For these reasons, par. requires all entities to measure the fair of investment property, for the purpose of either measurement (if the entity uses the fair model) or (if it uses the cost model). Consequently, the introduction of IFRS is very important for entities that operate in the real estate sector, where investment properties could be relevant compared to the other assets and even if fair is not mandatory for the subsequent measurement, its measurement is always necessary at least for purposes. Moreover, this sector has been significantly influenced by the crisis, with obvious effects on market prices and transactions. Focusing on investment properties, the paper aims at verifying the effects of the first application of IFRS in the real estate sector, by means of an empirical research of Italian, French and German groups listed on the. The introduction of the IFRS is an opportunity to verify the state of art of the application of fair as a subsequent measurement. Furthermore, the paper aims at verifying whether the introduction of IFRS leads to an improvement of the reported in the notes. This research contributes to previous literature by providing results after the first application of the new IFRS. A wide sample of European groups was analyzed in order to contribute to the debate on the application of fair as a subsequent measurement. Furthermore, an analysis of the requested by IFRS is provided. /n mandatory But only if fair can be determined by reference to an active market Measurement of held for trading financial assets and financial liabilities, including all derivatives Measurement of available for sale financial assets Measurement of other financial assets and financial liabilities, subject to specific requirements (so-called fair option ) Measurement of investment property Measurement of biological assets Fair is not used for investments in equity instruments (and derivatives that are linked to them) that do not have a quoted market price in an active market and whose fair cannot be reliably measured Fair is not used if the fair cannot be measured reliably Measurement of agricultural produce harvested for entity s biological assets The remainder of the paper is the following. Section II analyzes the background and defines the research questions. Section III presents the data and methodology of the research, Section IV shows the results of the analysis and finally some conclusions are reported. Except for financial instruments, plan assets of a postemployment defined benefit plan and biological assets, fair as a criterion for the subsequent measurement is always an option. Some options are eligible only in the separate financial statements, but many countries do not allow or do permit separate financial statements to be presented in accordance with IFRSs. In the consolidated financial statements, the use of fair as an option for subsequent measurement is possible only for tangible assets ( []), intangible assets ( []) and investment properties ( []). However, many studies have demonstrated that entities have not switched from cost accounting to fair accounting for tangible and intangible assets (see Busso and Devalle, []). With reference to investment properties, fair is generally not used when the reporting entity is not an investment property entity, i.e. when investment properties are not relevant (Devalle and Rizzato, []). On the contrary, the use of fair model for investment properties (land/building/part of land or building held to earn rentals or for capital appreciation or both) can lead to more useful information for users of financial statements. This was II. BACKGROUND AND RESEARCH QUESTION As stated in Section I, fair is an important criterion for IFRSs with many uses stated by different standards: for initial recognition, for allocation of the initial amount among its constituent parts, for subsequent measurement and for determination of the recoverable amount. The application of fair measurement fuelled a huge debate both in academic and practitioner contexts, in particular in the European continental accounting model. The debate on fair criterion is focused on different issues. Landsman () [] showed that the and the recognition of fair s are informative to investors, but that the level of informativeness is affected by the amount of measurement error and source of the estimates - management or external appraisers. An author underlined the ambiguity of the fair notion (Schmidt, []) as fair is defined as a The Author(s). This article is published with open access by the GSTF

3 GSTF Journal on Business Review (GBR) Vol.., vember transaction price but in imperfect markets buyer s and seller s marginal prices differ. Thus, the author states that in some cases the IFRS definition of fair is not readily applicable. Besides, fair s cannot be regarded as a suitable candidate for financial reporting or measuring taxable capacity in the real world (Rayman, []). Furthermore, it is possible to identify two main criticisms of fair accounting (Veron, []): illiquidity and procyclality. Moreover, fair accounting is able to change management philosophy and strategy (Barlev and Haddad, []) and can increase management discretion and subjectivity of fair valuation (Hilton and O Brien, []). Hitz () [] analyzed the notion of decision usefulness of a fair--based reporting system from a theoretical perspective. Findings indicate that the decision relevance of fair measurement can be justified from a regulator and information perspective, even if the conceptual case is not strong. Quagli and Avallone () [] showed that information asymmetry, contractual efficiency and managerial opportunism could account for the fair choice, with reference to. In particular the paper analyzed the determinants of the choice of the fair as a subsequent measurement. Size reduces the likelihood of using fair while market-to-book ratio is negatively associated with the fair choice. With reference to the aim of the paper is to verify the application of the fair as subsequent measurement in the real estate sector. So and Smith () [] showed that there is a higher market price reaction and return associations when changes of fair of investment properties are reported in the income statement. Furthermore, the goal of the paper is to analyze the impact of the new IFRS on the of how fair is determined when used as a criterion of subsequent measurement. As previously stated, is the first year of the application of IFRS and a more detailed has to be reported in the notes. In particular IFRS requires the following information: (i) the level of the fair hierarchy within the fair measurements are categorized in their entirety (Level, Level or Level ), (ii) for fair measurements categorized within Level and Level of the fair hierarchy, a description of the valuation technique(s) and the used in the fair measurement, (iii) for fair measurements categorized within Level of the fair hierarchy, quantitative information about the significant unobservable used (iv) and a narrative description of the sensitivity of the fair measurement to changes in unobservable if a change in those to a different amount might result in a significantly higher or lower fair measurement. III. The examined sample is made up of the groups listed on three European Continental Union s (, and ) belonging to the Real Estate Sector. In order to answer the above mentioned research questions, the sample is reported in Table. TABLE. (Q) to evaluate the application of the cost model or the fair model of the groups listed on the Italian, German and French s and belonging to the real estate sector; (Q) to analyze the of the fair measurement reported in the notes as stated by IFRS. COMPOSITION OF THE SAMPLE EXAMINED Companies belonging to real estate sector Consolidated Financial Statements analyzed % sample analyzed % % % % In this paper cases out of were analyzed. groups were excluded from the sample due to a lack of data. In particular, some groups did not draw up the consolidated financial statements (and the separate financial statements were not in compliance with IFRSs) or consolidated financial statements were not available. The investigation was based on the consolidated financial statements of the entities belonging to the above mentioned s and sector (Table ). In particular, the data of consolidated financial statements regarding were analyzed. With reference to the information required by IFRS was hand collected from the notes of consolidated financial statements. In more detail, the main s required by IFRS when fair is used on a recurring basis, such as for investment properties, are the following: (i) the level of the fair hierarchy within the fair measurements are categorized in their entirety (Level, Level or Level ), (ii) for fair measurements categorized within Level and Level of the fair hierarchy, a description of the valuation technique(s) and the used in the fair measurement, (iii) for fair measurements categorized within Level of the fair hierarchy, quantitative information about the significant unobservable used (iv) and a narrative description of the sensitivity of the fair measurement to changes in unobservable if a change in those to a different amount might result in a significantly higher or lower fair measurement. A total of, items were hand collected and a descriptive statistics approach was used in order to analyze the results. IV. To reach the objectives described the research questions are the following: DATA AND METHODOLOGY RESULTS A. Q: the application of fair model The first analysis is primarily a verification of the accounting model used (Table ) and of the impact of investment properties on total assets (Table and Table ). The Author(s). This article is published with open access by the GSTF

4 GSTF Journal on Business Review (GBR) Vol.., vember TABLE. losses arising from changes in fair are recognized in profit and loss. The weight of the changes in fair has been analyzed compared with investment properties and with net income (Table and Table ). ACCOUNTING MODEL USED IN THE SAMPLE ANALYZED Fair % on % on companies companies with I.P. with I.P. % % % % % % % % Presence % on of groups investment analyzed properties % % % % TABLE. As stated in Table, % of the analyzed groups have investment properties in their financial statements, with the lowest presence in Italy and the highest presence in France. Among the groups that have investment properties in their financial statements, % use the fair model and % the cost model. German companies have shown a strong tendency towards the fair model, chosen in % of cases whereas % of French companies have chosen the fair model. The relevance of investment properties for the real estate sector is confirmed by the weight of investment properties on total assets as reported in Table. TABLE. mean Mean mean % % % % Percentile,,, Mean of companies that use the cost model % % % % PERCENTILES OF THE WEIGHT OF INVESTMENT PROPERTIES ON TOTAL ASSETS Perc entil es,,,,%,%,% Fair,%,%,% Fair,%,%,%,%,%,%,%,%,%,%,%,% Fair Tota l,%,%,%,%,%,%,%,%,%,%,%,% -% % -% % Percentiles of the weight of changes in fair on investment property -,%,% -,% -,%,%,% -,%,%,% Percentiles of the weight of changes in fair on net income -,%,% -,% -,%,%,% -,%,%,% This analysis has been conducted only in regard to groups that use the fair model. The average effect of the changes in fair on investment properties is %, even though the situation is quite different in the countries analyzed. In fact, Italian companies show a negative impact, whereas French companies have a nearly nil effect. Companies listed at show a mean of % of the changes in fair on investment properties. The analysis of percentiles confirms the worst situation is that of Italian and French companies. In particular, % of Italian companies have a negative impact of more than %, whereas % of French companies have a negative impact of more than %. % of German companies show a nil effect, while % of the German sample has a positive effect of more than %. Regarding the weight of changes in fair on net income, Table shows that for Italian and French companies the average impact is negative, i.e. the losses arising from the fair measurement have either increased the net loss for the year or decreased the net income for the year. On the contrary, companies listed at have taken advantage of positive changes in fair. In analyzing the percentiles shown in Table, it is possible to note that % of German companies have a negative impact on net income, while % have a positive effect of more than %. % of French companies have a positive impact from changes in fair of more than %. Table shows that the mean of the weight of investment properties on total assets is equal to %. The results are consistent with the sector analyzed as the main assets of the real sector companies should be the investment properties. Table shows also that the mean of the weight of the investment properties on the total assets is % when fair is used and this mean decreases to % when cost is used. The country with the highest weight of investment properties is France. Thus, we can state that the companies where the weight of investment properties is higher uses the fair as a subsequent measurement. Table reports the percentiles of the weight of investment properties on total assets. TABLE. Mean of the weight of the changes in fair on net income PERCENTILES OF THE WEIGHT OF THE CHANGES IN FAIR VALUE ON INVESTMENT PROPERTIES AND ON NET INCOME TOTAL ASSETS Mean of the weight of the changes in fair on investment properties -% %,% % TABLE. MEAN OF THE WEIGHT OF INVESTMENT PROPERTIES ON Mean of companies that use the fair model % % % % MEAN OF THE WEIGHT OF THE CHANGES IN FAIR VALUE ON INVESTMENT PROPERTIES AND ON NET INCOME B. Q Disclosure Table shows the level of the fair hierarchy within the fair measurements are categorized in their entirety. % of the sample has a weight of investment properties on total assets of less than % and the median of the sample is %. Table confirms that in all the countries, companies that use the fair model have a higher weight of investment properties on total assets. The fair measurement of investment properties affects the net income, since gains and The Author(s). This article is published with open access by the GSTF

5 GSTF Journal on Business Review (GBR) Vol.., vember TABLE. CATEGORIZATION OF FAIR VALUE MEASUREMENT WITHIN technique belonging to the income approach techniques. Besides, the most used technique by French companies is the revenue capitalization model, another income approach techniques. Table shows the different approaches among French and German companies: French companies out of state they use three techniques, sometimes in combination, at other times as a control method. one French company uses only one technique. We find the opposite situation in Germany, where none of the companies use three techniques at the same time and companies out of state they use only one technique. FAIR VALUE HIERARCHY Level Both level and level Level t disclosed % of companies analyzed categorize the fair measurement within Level (unobservable ) and % within both Level and Level. one German company categorizes the fair measurement of all investment properties within Level. % of the sample ( companies) do not provide any about the fair hierarchy. Two of these companies were not obliged to apply IFRS since their annual periods started before st January. In this sense, the importance of IFRS is confirmed. The fact that the other companies do not disclose the fair hierarchy is a surprising result because the information is mandatory. In their situation the information is also relevant considering that the company with the lowest level of investment properties has % of its total assets composed of investment properties. Table shows companies behavior about of quantitative information of the significant unobservable used when the fair measurement is categorized within Level of fair hierarchy. TABLE. QUANTITATIVE DISCLOSURE ABOUT INPUTS USED WHEN FAIR VALUE MEASUREMENT IS CATEGORIZED WHITIN LEVEL (out of ) (out of ) (out of ) Table shows if the valuation techniques are described when the fair measurement is categorized within either Level or Level and Table shows how many techniques are used. TABLE. DESCRIPTION OF VALUATION TECHNIQUES Detailed informati on about technique s (out of ) (out of ) (out of ) (out of ) TABLE. (out of ) (out of ) (out of ) (out of ) Comparable transactions % Revenue capitalisation method % % % % % % % % % % % % % % NUMBER OF VALUTATION TECHNIQUES USED Three Two One Average of many average rate of return quantitati ve The number of companies considered is because one German company states it uses only Level fair measurement. In cases, companies provide quantitative information only for one input (the rate of return) and the quantitative information consists of an average rate. In cases (% of the sample), companies disclose also the average of other, such as discount rate, increase in market rent, vacancy rate and so on. % of companies give quantitative information of many, disclosed separately according to different categories of investment properties (type, location, quality). German companies seems to have a greater tendency to disclose more detailed information about the used, since % of the companies provide quantitative either of many average or many separately for categories of investment properties. IFRS requires to disclose quantitative information of significant used. If the are significant, it is also very important to disclose a sensitivity of the fair measurement to changes in those significant. IFRS requires only a narrative description of the sensitivity analysis. The presence of quantitative information of the sensitivity analysis was investigated and is shown in Table. DCF Many differenti ated for categories of I.P. companies out of do not provide detailed information about the evaluation technique used. of them are companies not obliged to apply IFRS because of the commencement of their annual period, once more confirming the relevance of the new standard. one company does not provide detailed about the valuation techniques. Table shows a clear tendency towards the Discounted Cash Flow Model, a The Author(s). This article is published with open access by the GSTF

6 GSTF Journal on Business Review (GBR) Vol.., vember TABLE. QUANTITATIVE INFORMATION ABOUT SENSITIVITY ANALYSIS WHEN FAIR VALUE MEASUREMENT IS CATEGORIZED WHITIN LEVEL Effects of variations in many (out of ) (out of ) (out of ) effects of variations quantitative in one input TABLE. Disclosure of the fair (out of ) (out of ) (out of ) (out of ) Disclosure about fair hierarchy, quantitative information about significant whether fair measurement is within Level and sensitivity of fair to changes in significant are mandatory also when the cost model is used. Table, Table and Table show the results of the analysis conducted on companies that use the cost model. (par. ) encourages entities to measure the fair on the basis of a valuation by an independent r. The importance of this requirement is clear considering that % of the companies categorize the fair measurement within Level or both Level and Level (Table ), i.e. unobservable are used. Table shows the about this topic in the notes. TABLE. CATEGORIZATION OF FAIR VALUE MEASUREMENT WITHIN FAIR VALUE HIERARCHY WHEN COST MODEL IS USED DISCLOSURE ABOUT THE USE OF INDEPENDENT VALUER IN MEASURING THE FAIR VALUE Independent valuation, with indication of the name(s) Independent valuation, without indication of the name(s) Internal valuation Mean of the weight of the fair amount on the carrying amount % % % % German companies do not provide any information about the fair of investment properties. However, for these companies the investment properties are not so relevant: the weight of investment properties on total assets is % in one case and % in the other case. Italian and French companies disclose a fair respectively of % and % higher than the carrying amount of investment properties. For the German companies the gap between fair and carrying amount is smaller (%). % of the sample analyzed appreciates the change in fair due to a variation in one or more. German companies seem to pay more attention also to this type of information, considering that % of them give quantitative information and % of the sample provides a quantitative sensitivity analysis for more than one input. When companies disclose the quantitative effect of the variation in only one input (% of the cases) this input is the average rate of return. TABLE. DISCLOSURE OF FAIR VALUE WHEN THE COST MODEL IS USED Level Both level and level Level t disclosed TABLE. DISCLOSURE OF QUANTITATIVE INFORMATION ABOUT INPUTS WHEN THE COST MODEL IS USED AND FAIR VALUE MEASUREMENT IS CATEGORIZED WHITIN LEVEL All the companies are compliant with because they disclose if the valuation is conducted internally or based on an independent party s appraisal. When the entities state that to use an independent r is used, they also disclose whether the r s results are taken into account without any adjustments or whether the management considers appropriate to make some adjustments. By now, it has become a common practice to disclose the name(s) of the independent r in order to allow users of financial statements to assess the professional qualification and experience of the appraiser(s). (out of ) (out of ) (out of ) When cost model is used ( cases out of ) about fair is mandatory. Table shows how many companies disclose fair of investment properties at the end of the period. Many Average of differentia many ted for categories of I.P. average rate of return quantitati ve The Author(s). This article is published with open access by the GSTF

7 GSTF Journal on Business Review (GBR) Vol.., vember TABLE. QUANTITATIVE INFORMATION ABOUT SENSITIVITY ANALYSIS WHEN THE COST MODEL IS USED AND FAIR VALUE MEASUREMENT IS CATEGORIZED WHITIN LEVEL (out of ) (out of ) (out of ) Effects of variations in many effects of variations in one quantitative input provided in % of the cases. The next step will be to analyze what the determinants of the choice of the fair in the real estate sector are. REFERENCES [] [] [] [] [] [] [] [] [] Table shows a distribution within fair hierarchy consistent with the one provided by companies using the fair model. With reference to companies that do not disclose fair hierarchy only have an insignificant amount of investment properties whereas the others have a weight of investment properties on total assets higher than %. Also the of quantitative information about significant is consistent with companies that use fair model (Table ): % of the companies disclose quantitative information about many separated for different categories of investment properties. As expected, only % of the companies provide quantitative information about sensitivity analysis (Table ) against % of companies that use the fair model. requires the about the use of an independent r also for companies that use the cost model. Table shows that only one company does not provide this, but it is necessary to take into account that for this company the investment properties are not significant (% of total assets). External, External, with without indication indication Internal of the of the name(s) name(s) V. [] [] [] [] [] [] [] [] [] CONCLUSION [] This research has shown that the fair model for investment properties is widespread among the real estate sector since it is used by % of the sample. IFRS has contributed to increasing about fair measurement even though not all the companies are compliant with the requirements of the standard. In particular, % of companies that use the fair model and % of companies that use the cost model do not provide any about the categorization within the fair hierarchy, which is mandatory according to IFRS. The results also show differences between the different countries: in fact, companies listed at are those more inclined to use the fair model and show a clear preference for Discounted Cash Flow Model as the sole valuation technique. French companies prefer to use more than one valuation technique even if the most used one is the revenue capitalization method. When companies use the cost model, quantitative information about sensitivity analysis is not B, IFRS, Business combinations, London,. B,, Financial instruments: presentation, London,. B,, Financial instruments: recognition and measurement, London,. B,, Investment properties, London,. 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Veron, Fair accounting is the wrong scapegoat for this crisis in Accounting in Europe, Vol., Issue,, pp.. B. Barlev, J.R. Haddad, Fair Accounting and the management of the firm in Critical Perspectives on Accounting, Vol., Issue,, pp.. AS Hilton, PC O'Brien, Inco Ltd: Market, fair, and management discretion in Journal of Accounting Research, Vol., Issue,, pp.. J.M. Hitz, The Decision Usefulness of Fair Value Accounting A Theoretical Perspective in European Accounting Review, Vol., Issue,, pp.. A. Quagli, F. Avallone, Fair Value or Model? Drivers of Choice for in the Real Estate Industry, in European Accounting Review, Vol., Issue,, pp.. S. So, M. Smith, Value-relevance of presenting changes in fair of investment properties in the income statement: Evidence from Hong Kong, in Accounting and Business Research, Vol., Issue,, pp. AUTHOR S PROFILE Donatella Busso is an Associate Professor in Business Administration at the University of Turin, Italy. She lectures in IFRS at the same University. Her main research interests and international publications are in financial statement analysis and IFRS. This article is distributed under the terms of the Creative Commons Attribution License which permits any use, distribution, and reproduction in any medium, provided the original author(s) and the source are credited. The Author(s). This article is published with open access by the GSTF