IFRS 9 for Financial Services Presentation and Disclosure Ulana Oswald Senior Manager December 9, 2015
Presentation and Disclosure: Classification and Measurement Page 1
Classification and measurement Transition disclosures In the reporting period that includes the date of initial application ( DIA ), the entity discloses: Original category and carrying amount at class level The new category and carrying amount at class level How classification requirements have been applied Reasons for any designations or de-designations at FVPL FVO option de-designations: Amounts involved distinguishing between mandatory and elective dedesignations. Changes in classifications as at the DIA Impact of reclassifications Page 2
Illustration One possible way to meet the quantitative transition disclosure requirements noted on the previous slide Page 3 1 January 2014 Presentation title
Presentation and Disclosure: Impairment Page 4
IFRS 9 Impairment - Presentation Presentation of ECLs in B/S differs by type of credit risk exposure: Credit risk exposure Financial assets measured at amortized cost, contract assets and lease receivables Loan commitments and financial guarantee contracts Partially drawn down credit facilities and commitments Debt instruments measured at FVOCI ECLs presented As an allowance (i.e., contra asset account) As a provision (i.e., as a liability) If ECLs cannot be separately identified, present combined ECLs as an allowance unless the combined ECLs exceed the gross carrying amount of the financial asset, in which case the ECLs should be recognized as a provision. As accumulated impairment amount in OCI Page 5
IFRS 9 Impairment Presentation (cont d) Any adjustment to the allowance or provision due to an increase or decrease of the amount of ECLs is reflected in profit or loss in a separate line as an impairment gain or loss. Write-offs are considered derecognition events. Write-offs can be for only a partial amount or for the entire gross carrying amount. A write-off should be made when the entity has no reasonable expectations of recovering the contractual cash flows on a financial asset in its entirety or a portion thereof. Write-offs require the entity to reduce the gross carrying amount of the financial asset against the accumulated loss allowance. IFRS 9 contains no explicit guidance on how the additional impairment loss should be presented, when the amount of loss on write-off is greater than the accumulated loss allowance. Should the additional impairment loss flow through the allowance, hence showing up in the allowance reconciliation as an addition and use? Page 6
IFRS 9 Impairment Disclosures Objective of the new credit risk disclosures: enable users to understand the effect of credit risk on the amount, timing and uncertainty of future cash flows Determination of whether credit risk increased significantly Default definition Grouping for collective assessments Write-off policy Credit Risk Mgmt Practices IFRS 7 (amend.) 35F-G Modifications Inputs, assumptions and estimation techniques for Measurement of 12 month EL and Lifetime EL Determining whether credit risk increased significantly. Classification as credit-impaired Incorporation of forward looking information Changes in estimation techniques or significant assumptions and reasons for changes Page 7
IFRS 9 Impairment Disclosures (cont d) Disaggregated quantitative reconciliation of provisions per class of financial instruments and according to stage allocation Qualitative and quantitative information to explain changes in provision levels Undiscounted expected credit losses for purchased/originated credit impaired assets initially recognized during period. Quantitative and Qualitative Information IFRS 7 (amend.) 35H-L Explanation of how significant changes in the gross carrying amount of financial instruments during the period contributed to changes in the loss allowance. Qualitative and quantitative information to understand the nature and effect of modifications on measurement of ECL Qualitative and quantitative information to understand the effect of collateral and other credit enhancements Contractual amount outstanding on financial assets that were written off during the reporting period and are still subject to enforcement activity. Page 8
IFRS 7 extract: Reconciliation of the loss allowance Illustrating the application of paragraphs 35H and 35I Page 9
EY example: reconciliation (1/2) EY example Reconciliation of the loss allowance Loss allowance on [asset class] 12-month ECLs m Lifetime ECLs not creditimpaired loans m Lifetime ECLscredit- impaired loans m Lifetime ECLs - simplified approach applied to trade receivables, contract assets and lease receivables m Purchased or originated credit impaired loans m Total m As at 1 January 2018: 56.3 247.4 36.7 13.2 3.4 357.0 Exchange and other adjustments (3) 2.4 9.3 1.8 (0.4) (0.7) 12.4 Amounts written off (2.8) (9.6) (13.5) (0.6) (1.2) (27.7) Unwinding of Discount (1) 0.5 7.4 1.7 0.5 0.1 9.7 New financial assets originated or purchased (1) 12.7 - - 3.7-16.4 Transfers (1) to 12-month ECLs 4.3 (12.7) (0.4) (8.8) to Lifetime ECLs not credit- impaired loans (5.2) 22.8 (3.4) 14.2 to Lifetime ECLs credit- impaired loans (2.4) (14.7) 23.3 (0.5) 6.2 Financial assets derecognised during period (not written off) i.e., repayments, modifications, sales, etc. (2) (14.6) (23.8) 2.4) (4.2) (3.7) (46.3) Changes in models/ risk parameters (1) 3.4 8.1 2.7 0.2 1.6 16.0 As at 31 December 2018 54.1 234.2 48.9 12.4 (0.5) 348.6 Page 10
EY example - Reconciliation (2/2) (1) Charge to profit or loss. The amount relating to the unwind of discount will be recorded in the impairment charge for columns one, two and four, but will be an implicit part of interest revenue for columns three and five. Note that for the transfers, the amounts differ by column, as the figures in columns two, three and four are lifetime ECLs and those in column one are only 12-month ECLs. The net effect across the columns will be the net impact on profit or loss. It will also be apparent that the numbers shown in the table will depend on the order in which these various items are applied, e.g., whether the transfers between columns are calculated before the changes in risk parameters. Similarly, while we have shown a nil number for columns two and three for new assets recognised in the period, strictly there could be something to record, if impairment is only assessed at the end of the period; an asset may have already significantly increased in credit risk before it is first assessed for impairment, in which case, it would not be transferred from column one. (2) None of these amounts will be reflected in the impairment charge in profit or loss. Any difference between the amortised cost and the consideration received on derecognition is recorded in profit or loss would be presented in the new mandatory line gains and losses arising from the derecognition of financial assets measured at amortised cost. (3) Part of this amount may be recorded in profit or loss as FX revaluation and part through other comprehensive income if it relates to the retranslation of an overseas subsidiary. Page 11
IFRS 7 extract: Gross carrying amount reconciliation Illustrating the application of paragraphs 35H and 35I Page 12
IFRS 9 Impairment Disclosures (cont d) Credit Risk Exposure IFRS 7 (amend.) 35M-36 Disclosures by credit risk rating grades to understand credit risk exposure Disclosures of significant credit risk concentrations. Page 13
IFRS 7 extract: Credit Risk Illustration Illustrating the application of paragraphs 35M and 35N Page 14
IFRS 7 extract: Credit Risk Illustration (cont d) Illustrating the application of paragraphs 35M and 35N Page 15
Presentation and Disclosures: Hedge Accounting Page 16
IFRS 9 vs. IAS 39 Hedging Presentation comparison Similarities: In general, no change to how cash flow hedges and fair value hedges are presented, except for the following differences Differences: Cash flow hedges Forecast transactions resulting in the recognition of a non-financial item: Amount accumulated in equity must be accounted for as a basis adjustment (i.e., no accounting policy choice) Fair value hedges Hedges of equity investments measured at FVOCI Gains or losses will never be recognised in profit or loss, even on sale Ineffectiveness is recognised in OCI Page 17
Presentation - Groups of items - Cash flow hedges Presentation of hedging gains or losses in the statement of profit or loss depends on the nature of the group position Page 18
Presentation - Groups of items - Fair value hedges Fair value hedges of a net position A. Income statement Hedging gains or losses will be presented in a separate line item in the income statement B. Statement of financial position The individual items in the group are separately adjusted for the change in fair value attributable to hedged risk Page 19
Objectives of IFRS 9 hedging disclosures Improve transparency on hedging activities for which hedge accounting is applied Entities shall disclose information about: 1) The risk management strategy and how it is applied to manage risks 2) How the risk management activities may affect the amount, timing and uncertainty of future cash flows 3) The effect that hedge accounting has had on the statement of financial position, the statement of comprehensive income and the statement of changes in equity Page 20
1) Risk management strategy Link between risk management activities and how they affect the financial statements Minimum disclosures (i.e., not a checklist approach), described by risk category Risk exposure e.g., how it arises, how its managed using financial instruments and extent of hedging Hedging instrument(s) used how it is used to hedge the risk exposure Determination of economic relationship Establishing the hedge ratio Sources of ineffectiveness Key judgements made should be disclosed Page 21
1) Risk management strategy (cont d) How detailed should the description be? Factors to consider include: a) How does the entity manage the risk? Instruments used Components (nominal or risk) or combination of risk components Risk categories managed Strategies under each particular risk category b) Level of aggregation of disaggregation of disclosed information Sufficient to provide the necessary context to the other hedge accounting disclosures Should not result in boiler plate disclosures that do not provide useful and relevant information Page 22
1) Risk management strategy (cont d) Additional disclosures when a risk component is designated as a hedged item: How the risk component is determined Nature of the relationship with the item as a whole. For example: whether contractually specified or not, if not contractually specified, how the entity determined that the risk component is separately identifiable and reliably measurable Indication of the size of the component to the whole (e.g., the designated component historically covered 85% of the changes in the value of the item as a whole) Page 23
2) Amount, timing, uncertainty of future cash flows Quantitative information that enables the users of financial statements evaluate the terms and conditions of hedging instruments and how they affect future cash flows By category of risk A profile of the timing of the nominal amount If applicable, the average price or rate e.g., a strike price or a forward rate Sources of hedge ineffectiveness during term of relationship including update of new sources of ineffectiveness that emerge over the term and resulting ineffectiveness Description of forecast transactions that are no longer expected to occur (cash flow hedges) Page 24
3) Effects of hedge accounting on financial position Information, presented in tabular format and prepared by type of risk and by type of hedge, on: 1. Designated hedging instruments: Nominal amount, carrying amount, location in B/S, change in fair value 2. Hedged items Fair value hedges: carrying amount, cumulative fair value adjustments to carrying amount, location in B/S, change in value, balance of remaining adjustments for hedged items that ceased to be adjusted Cash flow hedges and hedges of net investment: change in value, balances in CFH reserve and FX translation reserve (for continuing hedges) and remaining balances in reserves (for discontinued hedges) Page 25
Example: Designated hedging instruments Page 26
Example: Designated hedged items Page 27
3) Effects of hedge accounting on performance Hedge ineffectiveness and hedging gains or losses 1) Fair value hedges: Hedge ineffectiveness (recognized in P&L or OCI) and its location in the Statement of P&L and OCI 2) Cash flow hedges and hedges of NIFOs: Gains and losses recognised in OCI during reporting period Hedge ineffectiveness recognised in P/L and its location in the Statement of P/L and OCI Reclassifications from the reserves into P/L: Amounts for which the hedged future cash flows are no longer expected to occur Amounts transferred in relation to hedged items which has affected P/L Location of reclassification in Statement of P/L and OCI Gains and losses recognised in separate line item in Statement of P/L and OCI (for hedges of net positions) Page 28
Example: Application of hedge accounting: Amounts affected Statement of Comprehensive Income Page 29
3) Effects of hedge accounting on performance (cont d) Reconciliation of AOCI, by risk category: Gains and losses recognised in OCI during reporting period Reclassifications from the reserves into P/L: Amounts for which the hedged future cash flows are no longer expected to occur; Amounts transferred in relation to hedged items which has affected P/L Amounts removed from CFH reserve and included directly in initial cost or other carrying amount, as a basis adjustment, of an item Reclassification adjustments from CFH reserve into P/L in relation to a loss that the entity is not expected to recover in a future period. Time value of money amounts in relation to: Purchased options hedging transaction-related hedged items Purchased options hedging period-related hedged items Forward element of forward contracts and FX basis spreads amounts in relation to: Financial instruments hedging transaction-related hedged items Financial instruments hedging period-related hedged items Page 30
3) Effects of hedge accounting on performance (cont d) Credit exposures carried at fair value through profit or loss (FVPL)*: Credit derivative: A reconciliation of each of the nominal amount and the fair value at the beginning and end of the period Financial instrument (or a proportion of it) designated at FVPL: Gain or loss recognised in P/L ( as a result of changing the accounting) On discontinuation of designation, the fair value and the related nominal or principal amount * In addition to existing IFRS 7 disclosures relating to credit risk exposures Page 31
Transition Experience: Preparation, Considerations, Experience Page 32
Preparing for IFRS 9 implementation Start early; Identify stakeholders and impacted parties including technical accounting expert to understand requirements and identify gaps; Assess system requirements for gathering the necessary information; Develop templates and disclosure mock-ups and communicate changes to Financial Reporting Group and oversight committees; Assess consistency between financial statement disclosures and other financial supplements published by the entity; Benchmark to other companies that may have early implemented; Work with external auditors to minimize changes after implementation; Introduce templates and new requirements to business segments as process changes may be required; Perform dry-runs to identify gaps in the new process and what could go wrong. Page 33
IFRS 9 disclosure implementation considerations Comparatives Levels of detail and aggregation or disaggregation not prescribed and require judgment, particularly when multiple strategies used to hedge the same category of risk Whether additional explanations are necessary to meet the objectives New disclosures require detailed information which may not be readily available given existing systems and processes System enhancements may be required which can be costly and require lead time to implement Consider different alternatives for compiling the necessary information Page 34
IFRS 9 Transition Comparative year IFRS 9 7.2.1: An entity shall apply this Standard retrospectively, in accordance with IAS 8. Classification and measurement, and impairment: Reminder: IFRS 9 7.2.15: the entity may restate prior periods if, and only if, it is possible without the use of hindsight Reminder: IFRS 9 7.2.1: this standard shall not be applied to items that have already been derecognized at the date of initial application. Hedge accounting: No reference is made in the hedge accounting transition rules as it relates to para. IFRS 9 7.2.15 Impact: Comparative restatement is required for cost of hedging Alternatives to comparative restatement: Non-GAAP and pro-forma measures Disclosure in the MD&A Page 35
National Australia Bank (NAB) Transition experience NAB has early adopted IFRS 9, reporting for the first time: Half year as at March 31, 2015 Full year as at September 30, 2015 Key elections: A significant portion of the Group (non-traded) AFS equity instruments will be classified at FVOCI The Group will elect to revoke previous FVO designations of specific lending portfolios. As such, these portfolios will be subsequently accounted at amortised cost. Page 36
National Australia Bank (NAB) Transition disclosure NAB disclosed the expected the over all impact of the transition to IFRS 9 as being a decrease to net assets of $847M AUD, as at October 1, 2014: $815M AUD decrease to financial asset balances, reclassification and measurement consisting of: Other financial assets at FVTPL $295M AUD Loans and advances at amortized cost $801M AUD Deferred tax asset $292M AUD Other assets $11M AUD $32M AUD increase to financial liability balances, reclassification and measurement consisting of: Deposits and other borrowings $32M AUD NAB s provision for doubtful debts increased by $547M AUD as at October 1, 2014 as a result of reclassification and measurement. Page 37
Questions? Page 38
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