ICAC Annual Conference IFRS 9 Implementation Common Challenges & Possible Solutions

Similar documents
New and revised Standards -Applying IFRS 9 Presentation by: CPA Stephen Obock December 2017

IFRS 9 Application to banks

CIAA Annual Accounting Update

Wider Fields: IFRS 9 credit impairment modelling

In depth IFRS 9: Expected credit losses August 2014

IFRS 9 for Insurers. Syysseminaari. Aktuaaritoiminnan kehittämissäätiö. 30 November 2017

Putting IFRS 9 into practice Presentation by: CPA Stephen Obock February 2018

IFRS 9 Implementation Workshop. A Practical approach. to impairment. March 2018 ICPAK

ICPAK. IFRS 9 Practical approach to impairment. March kpmg.com/eastafrica

Investec plc and Investec Limited IFRS 9 Financial Instruments Combined Transition Report

Contents. Financial instruments the complete standard. Fundamental changes call for careful planning. 1. Overview Complete IFRS 9

Investec plc silo IFRS 9 Financial Instruments Transition Report

Implementing IFRS 9 Impairment Key Challenges and Observable Trends in Europe

Investec Limited group IFRS 9 Financial Instruments Transition Report

THE POWER OF BEING UNDERSTOOD AUDIT TAX CONSULTING

IFRS 9 Implementation Guideline. Simplified with illustrative examples

IFRS 9 Financial Instruments

Welcome to the participants of ICAI- Dubai Chapter on IFRS 9 Presentation

IFRS News. Special Edition on IFRS 9 (2014) IFRS 9 Financial Instruments is now complete

In depth IFRS 9 impairment: significant increase in credit risk December 2017

FINANCIAL INSTRUMENTS. The future of IFRS financial instruments accounting IFRS NEWSLETTER

Exposure Draft. Expected Credit Losses. International Financial Reporting Standards

Moody s Analytics IFRS 9 Impairment: Current State of the Market. Burcu Guner EMEA Specialist Team - Director 9 th March 2016

Close Brothers Group plc T +44 (0) Crown Place E Close Brothers Group plc. IFRS 9 Transition Report

Overview Why the introduction of IFRS 9?

IFRS 9 Financial Instruments for broker-dealers

IFRS 9 FINANCIAL INSTRUMENTS

Deutsche Bank. IFRS 9 Transition Report

Transition to IFRS 9

Hot topics treasury seminar

Interim Condensed Consolidated Financial Statements

Alizz Islamic Bank SAOG. UNAUDITED INTERIM CONDENSED FINANCIAL STATEMENTS 30 June 2018

Forward Looking Credit Losses IFRS 9 Seminar for Senior Bank Supervisors from Emerging Economies Washington, DC. October, 2018

Financial instruments IFRS 9 development Project phase Exposure draft Status / next steps 1a. Classification & measurement of financial assets 1b. Cla

IFRS 9 Financial Instruments Thai Life Assurance Association

EBA REPORT ON RESULTS FROM THE SECOND EBA IMPACT ASSESSMENT OF IFRS July 2017

IFRS 9 Financial Instruments Thai General Assurance Association

EMIRATES NBD BANK PJSC

Overview of new accounting standard IFRS 9 and impact on credit risk models. 9 th February 2015

Implementing IFRS 9: a guide for lessors

Expected Loss Models: Methodological Approach to IFRS9 Impairment & Validation Framework

What IFRS 9 means to insurers. Developing insurance specific business capabilities

INDIA INTERNATIONAL BANK (MALAYSIA) BERHAD (Incorporated in Malaysia)

IFRS 9 Financial Instruments : Transition. Lloyds Banking Group plc

GAAP & IFRS Updates: What you need to know

INDIA INTERNATIONAL BANK (MALAYSIA) BERHAD (Incorporated in Malaysia)

EMIRATES NBD BANK PJSC

EMIRATES NBD BANK PJSC

Standard Bank Group IFRS 9 FINANCIAL INSTRUMENTS TRANSITION REPORT

BAC BAHAMAS BANK LIMITED Financial Statements

FINANCIAL INSTRUMENTS: EXPECTED CREDIT LOSSES INTERNATIONAL FINANCIAL REPORTING BULLETIN 2013/09

IFRS 9. Financial instruments for corporates Are you good to go? September kpmg.com/ifrs

IFRS 9 Financial Instruments. IICPAK: The Financial Reporting Workshop 4 th and 5 th December 2014 Hilton Hotel, Nairobi

AASB 9: Financial Instruments Transition. Tuesday 20 June 2017

APPLYING IFRS 9 TO RELATED COMPANY LOANS

In depth IFRS 9 Impact on the Pharmaceutical Industry December 2017 No. INT

SAGICOR FINANCIAL CORPORATION LIMITED

Forward-looking Perspective on Impairments using Expected Credit Loss

IFRS 9 Implementation Workshop 31 st January 1 st February 2018

IFRS 9 Readiness for Credit Unions

PwC ReportingInBrief. Ind AS 109, Financial Instruments for corporates

SAMBA FINANCIAL GROUP

INDEPENDENT AUDITOR S REPORT FINANCIAL STATEMENTS NOTES TO THE FINANCIAL STATEMENTS

Clarien Bank Limited. Consolidated Financial Statements (With Independent Auditors Report Thereon) For the nine months ended September 30, 2018

THE SACCO SOCIETIES REGULATORY AUTHORITY (SASRA) IFRS 9 - FINANCIAL INSTRUMENTS Efficient implementation by SACCOs

Arab Banking Corporation (B.S.C.)

SAMBA FINANCIAL GROUP

EBF Comment Letter on the IASB Exposure Draft - Financial Instruments: Expected Credit Losses

BANCO DE BOGOTA (NASSAU) LIMITED Financial Statements

Impairment of financial instruments under IFRS 9

AHLI UNITED BANK K.S.C.P. KUWAIT INTERIM CONDENSED CONSOLIDATED FINANCIAL INFORMATION 31 MARCH 2018 (UNAUDITED)

IFRS 9: Financial Instruments

Nationwide Building Society Report on Transition to IFRS 9

IFRS 9 financial instruments transition report as at 1 July

Summary of IFRS Exposure Draft - Financial Instruments: Expected Credit Losses. Who Will be Impacted by These Proposals? Objectives of the Proposals

Basel II Pillar 3 Disclosures Year ended 31 December 2009

An Overview of the Impairment Requirements of IFRS 9 Financial Instruments

IFRS 9 - Preliminary Plan

IFRS 9 Impairment Requirements

INVEST BANK P.S.C. CONDENSED CONSOLIDATED INTERIM FINANCIAL INFORMATION FOR THE THREE MONTH PERIOD ENDED 31 MARCH 2018

IFRS 9 FINANCIAL INSTRUMENTS FOR NON FINANCIAL INSTITUTIONS. New member firm training 2010 Page 1

Guidelines on credit institutions credit risk management practices and accounting for expected credit losses

Arab Banking Corporation (B.S.C.)

Applying IFRS. ITG discusses IFRS 9 impairment issues at December 2015 ITG meeting. December 2015

Instruments-Classification. Measurement and Impairment. Credibility. Professionalism. AccountAbility

Risk and Accounting. IFRS 9 Financial Instruments. Marco Venuti 2018

Export Development Canada Quarterly Financial Report September 30, 2018 Unaudited TRADE UNLIMITED

SAMBA FINANCIAL GROUP

Financial Instruments. October 2015 Slide 2

The new bank provisioning standards: Implementation challenges and financial stability implications

Export Development Canada Quarterly Financial Report June 30, 2018 Unaudited TRADE UNLIMITED

FRONTENAC MORTGAGE INVESTMENT CORPORATION

ANNOUNCEMENT. Subject: Financial Results of the Group of Hellenic Bank Public Company Ltd for the six-month period ended 30 th June 2018

AHLI UNITED BANK K.S.C.P. KUWAIT INTERIM CONDENSED CONSOLIDATED FINANCIAL INFORMATION 30 JUNE 2018 (UNAUDITED)

Applying IFRS 9 Part II (Discussion) Presentation by: CPA Stephen Obock February 2018

OSFI Perspectives on High Quality Implementation for Expected Credit Losses and OSFI s IFRS 9 Project Plan

Media Industry Accounting Group Annual conference 2017

IFRS 4, Phase II - Ongoing changes and interaction with IFRS 9. June 9, 2015

Applying IFRS. IFRS 9 for non-financial entities. March 2016

Standard Chartered Saadiq Berhad (Company No K) (Incorporated in Malaysia) Financial statements for the three months ended 31 March 2018

Transcription:

www.pwc.com ICAC Annual Conference 2018 IFRS 9 Implementation Common Challenges & Possible Solutions 23 June 2018

Agenda Our goals for today Discuss key challenges and solutions Recap IFRS 9 Financial instruments Recap Discuss Key aspects of IFRS 9 classification Key aspects of IFRS 9 - Impairment Common Challenges for developing economies Possible solutions Impact of IFRS 9 PwC - IFRS 9 Financial Instruments 2

Key aspects of the standard - overview of classification & measurement Debt instruments Derivatives Equity instruments Is objective of the company s business model to hold the financial assets to collect contractual cash flows? No Is the financial asset held to achieve an objective by both collecting contractual cash flows and selling financial assets? No Yes Is the equity instrument held for trading? Yes Yes No Do contractual cash flows represent solely payments of principal and interest? Yes Yes Does the company apply the fair value option to eliminate an accounting mismatch? No Yes No Has the company taken the election to present changes in fair value in OCI for equity instruments that are not held for trading? No No Yes Amortised cost 1 FVOCI (with recycling) 1 FVPL FVOCI (no recycling) 1 Impairment considerations apply. PwC PwC 3

Key aspects of the standard - overview of classification & measurement Factors to consider Strategic Objective for owning Business Model How assets are managed Historical disposals IFRS training 4

Key aspects of the standard - overview of impairment Incurred loss (IAS 39) Portfolio Allowances Balance sheet exposure DCF* Collateral Probability of Default (PD) Exposure at Default (EAD) Loss given default (LGD) Future loss Future performance DCF* Collateral Expected loss (IFRS 9) PwC * Discounted Cash Flows 5

Key aspects of the standard - Overview of impairment The three stages Decision tree Absolute credit quality no Any change in relative credit quality Assessment based on payment status: no yes Credit-impaired yes no yes 1 2 3 Performing 12-Months-ECL Significant increase of credit risk Lifetime ECL Credit-impaired Lifetime ECL PwC 6

Expected credit losses Disclosures Quantitative Qualitative Reconciliation of opening to closing amounts of loss allowance showing key drivers of change Write off, recovers and modifications Inputs, assumptions and estimation techniques for estimating ECL Write off policies, modification policies and collateral Reconciliation of opening to closing amounts of gross carrying amounts showing key drivers of change Gross carrying amounts per credit risk grade Inputs, assumptions and estimation techniques to determine SICR and default Inputs, assumptions and techniques to determine credit impaired IFRS 9 training 7

Common Challenges in our environment Implementation Timeline & Project Governance Tax implications of IFRS 9 Internal data availability IFRS 9 Challenges Forecasting macroeconomic scenarios Defining significant increase in credit risk (SICR) Providing for sovereign debt PwC 8

- Implementation timeline and project governance Nov 2009 IFRS 9 Phase 1 C&M Effective date Jan 2013 Dec 2011 Effective date changed to Jan 2015 July 2014 Final IFRS 9 Standard Effective date 1 Jan 2018 Jan 2018 IFRS 9 effective date 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Nov Nov 2009 2009 ED ED on on impairment Impairment March 2013 ED on ECL Sept 2015 Option for deferral to 2021 proposed for Insurers PwC 9

- Implementation timeline and project governance Documentation Project Governance Exercising judgment Now vs Future Internal Controls Disclosure PwC 10

- internal data availability Origination Date: Defining a business cycle tranches Revolving vs non revolving facilities Origination Date SICR / Default Origination Data Origination Data: Establishing credit risk at origination Cost / benefit PwC 11

- internal data availability How is expected lifetime determined? 1 Contractual maturity 2 Behavioural maturity 3 Combine contractual and behavioural Options For non-revolving facilities, this will be easy to identify. 1Option Analyse historical data to identify average customer lifetime for each product type. Select either behavioural or contractual approach. This will be informed by the product management strategies in place, e.g. for revolving facilities - use behavioural lifetime. PwC conceptual suitability For revolving loans, this may not be appropriate. Potential difficulty justifying this approach on non-revolving products. D Note, behavioural life must be capped at contractual life (for nonrevolving facilities). Need to justify and potentially disclose the choice between contractual and behavioural lifetime. 12

- Defining a significant increase in credit risk (SICR) forward transition? 1 Absolute value 2 Relative value 3 Change in grade or bucket 4 Different value for each credit grade Options Absolute value (e.g. 5% threshold would trigger move if PD increased from 5% to 10%). 1Option Relative value (e.g. a 5% threshold would trigger move if PD increased from 2% to 2.10%). Loan moves to stage two when it moves by a number of internal credit grades. Option 1, 2 or 3 adopted but with a different threshold for each credit grade (or PD bucket). PwC conceptual suitability Potential calibration issues as appropriate absolute change in PD for high credit risks would not be suitable for low credit risks. Potential calibration issues in that an appropriate relative change in PD for high credit risk would not be suitable for low credit risk. The suitability is dependent on the structure of the internal credit grades. Conceptually appropriate but needs justification for differences for each grade. 13

- Defining a significant increase in credit risk (SICR) backward transition? Options 1 No longer increased credit risk Loan no longer meets criteria for significant increase in credit risk. 2 Probation period 1Option Loan has not met criteria for increase in credit risk for minimum number of months. 3 Minimum number of payments Borrower has made a minimum number of payments. 4 Recapitalisation criteria Meets requirements to have arrears recapitalised and set back to up to date status. PwC conceptual suitability Not appropriate unless original transition was due to macro-economic factors. Could lead to increased provision volatility. Conceptually sound and reduces volatility in provisions. More prudent than option 1 as it requires evidence of reduced credit risk. Conceptually sound and reduces volatility in provisions. More prudent than option 1 as it requires evidence of reduced credit risk. Conceptually sound and reduces volatility in provisions. Level of prudence depends on criteria applied. 14

- Providing for sovereign debt Treatment under IAS 39 Considered risk free Considered for general provision? Origination Treatment Data under IAS 39 Forward transitions Establishing a PD Establishing a PD Use of publicly available info vs internal Risk rated or not? PD available or not? Determining Lifetime PD Facility duration Transition Matrix Extrapolation / Terminal PD Determining Lifetime Simplification PD s Sovereign Debt Determining 12 month PD Determination of 12 month PD Interpretation of available PD PwC 15

- forecasting macroeconomic scenarios Variable inputs: Source of key risk inputs Historical data Current & forecast data Measuring impact Identifying relationships Quantifying impact Origination Data Variable inputs Forward Measuring transitions Impact Multiple scenarios: Probability weighing scenarios Multiple scenarios Simplification s Measuring lifetime aaaloss Macroeconomic Scenarios Macroeconomic scenarios: How many scenarios? PwC 16

- forecasting macroeconomic scenarios Source of macroeconomic inputs Options 1 Use internal expertise Use internal judgement to forecast scenarios for a range of macroeconomic variables. 2 Use internal model 1Option Update current model to produce macroeconomic forecasts in line with IFRS 9 requirements (i.e. over lifetime of loans), with potential for judgement based overlays if necessary. 3 Source external forecasts Obtain external macroeconomic forecasts. For example, use Moody s economic forecast. 4 Combine external and internal sources Obtain external macroeconomic forecasts and use in conjunction with internal models PwC conceptual suitability This approach allows scope for highly judgemental forecasts, potentially out of line with peers. Easier to ensure internal consistency of projections used. Whilst the approach is highly dependent on quality of the model, a reputable external source could improve investor perception. Easier to ensure consistency of projections. Whilst approach is sound it requires sufficient external data to provide a range of scenarios for each variable. Approach is sounds. Multiple sources of data will allow internal data to be compared with external data to check for soundness. 17

- forecasting macroeconomic scenarios How is the impact quantified? Options 1 Regression analysis Perform regression analysis on long term historical data This should be performed over a sufficiently long period such that it includes numerous economic cycles. 2 Expert judgement 1Option Use expert judgement to estimate the relationships between economic variables and key risk inputs. 3 Combination approach Regression analysis is used to quantify the impact of macroeconomic variables. This is combined with expert judgement to determine the overall adjustment to risk inputs. 4 PwC conceptual suitability This is a sound approach as it produces quantifiable estimates for the impact on key inputs by analysing a long period of historical data. Justification of impacts would need a robust, airtight and fully responsive governance framework. This approach is conceptually the preferred option as it allows sound quantifiable estimates, as well as expert judgement overlays where required. 18

- forecasting macroeconomic scenarios Incorporating multiple scenarios Options 1 1 2 1 Single provision 1Option ECL is calculated using single probability weighted economic scenario. E.g. 3 scenarios are probability weighted into 1 single scenario which is then used to calculate single ECL. 2 Single provision with overlay Run a single macroeconomic forecast through the model (Option 2) but then apply a top-down overlay informed by sensitivity analysis to reflect impact of alternate scenarios. 3 Probability weighted provisions ECL is calculated as the probability weighted average of the provision calculated for each economic scenario. E.g. for 3 scenarios, 3 ECLs calculated and probability weighted average taken. PwC conceptual suitability Combining scenarios before calculating provisions runs the risk of underestimating the impact of low probability scenarios (e.g. due to the asymmetric nature of loses). Sound, so long as approach can reliably estimate the impact of stress scenarios. Alternate scenarios can be difficult to factor in to transition test at the account level. This is the strongest approach conceptually as it provides for low probability, high impact scenarios. 19

- Taxation implications General vs Specific Capital adequacy How is SICR defined? Bad vs Doubtful How is SICR defined? What evidence is available? Origination General Data vs Specific Forward transitions Bad vs Doubtful Transition Design of system What evidence is available? Taxation implications Transition Year 1 Simplification Adjustment s Year 1 Adjustment UK precedent PwC 20

- Impact of IFRS 9 Effective Tax Rates Capital Adequacy Access to & cost of financing Operating Costs Policy & Structure PwC 21

Questions? PwC 19

Value, on your terms We focus on four areas: assurance, tax, consulting and deals services. But we don t think off-the-shelf products and services are always the way to go. How we use our knowledge and experience depends on what you want to achieve. PwC Canada has more than 5,800 partners and staff in offices across the country. Whether you re one of our clients or one of our team members, we re focused on building deeper relationships and creating value in everything we do. So we ll start by getting to know you. You do the talking, we ll do the listening. What you tell us will shape how we use our network of more than 195,000 people in 157 countries around the world and their connections, contacts and expertise to help you create the value you re looking for. See www.pwc.com/ca for more information. Creating a distinctive client experience Communicating better helps us understand you better. It means starting with what s important to you and, from there, building a stronger connection. We recognize that value means different things to different people. For us, it means discovering what value means from your perspective and then working together to achieve it. That s what our brand promise is all about: building relationships to create the value you're looking for. 23