Professional Documents
Culture Documents
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Deloitte 2007
Apart from meeting reporting requirements relating to IFRS introduction, implementing provisioning according to IAS 39 and IAS 37 will result in: 1. Convergence of provisioning methodology with the approach used in credit risk management and Basel 2 e.g. use of PD, LGD, recovery rates, EAD) 2. Better collateral management, ability to analyse collateral efficiency and credit risk measurement. 3. More accurate estimation of loan provisions: Accounting for banks specifics in the area of exposures, internal credit risk assessment methods, effectiveness of receivables and collateral collection processes.
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Our experience
Experience in the development of effective interest rate and financial asset impairment methodologies gained in both local and international financial institutions. Possessing dedicated, tested and working IT solutions IRR Tool and Impairment Tool hence we can assure efficient, competent and timely project realization. Playing active role in Polish Banking Supervision Commission (KNB) and Polish Banking Association working group developing KNBs impairment implementation recommendation. Capacity to provide complete services due to possessing a unique team representing comprehensive knowledge and expertise acquired in local and Central European environment in the areas of IFRS implementation, financial instrument accounting, Basel II, risk management, and developing own IT tools related to these areas. Experience in managing projects which covered both development of methodology and implementing it in IT systems. Experience in implementing integrated risk management systems covering ALM, FTP, Basel 2 and IAS 39. Experience in building and implementing IT solutions which support accounting in accordance with IFRS in banks and non-financial institutions:
Impairment tool - system for specific and portfolio provisions according to IFRS; IRR Tool - system for measurement of debt instruments using effective interest rate; CRD Synergy Engine integrated IT solution for Capital Adequacy EU Directive (CRD).
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Deloitte 2007
Our experience
Impairment
Methodology: BRE Bank (Commerzbank Group) Invest Bank (Poland) DZ Bank Poland Fortis Bank Polska OTP Bank Slovakia & Romania EFL Leasing (Credit Agricole Group) Santander Consumer Bank (Poland) Hypo-Alpe-Adria banks in Serbia & Bosnia Cacanska Banka (Serbia) GE Money Bank (Czech Republic) IT supporting tools: BRE Bank (Commerzbank Group) Invest Bank (Poland)
IT supporting tools: Raiffeisen Bank Polska Bank BISE (Poland) Invest Bank (Poland)
Deloitte 2007
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Impairment a reduction of the asset value (recoverable value) below its book value due to the increase in credit risk. Default inability to fulfill the contractual obligations. A delay in payment over 90 days is an example of a default indicator. Loss event objective evidence of impairment - an event indicating an increased risk of default, e.g. a breach of contractual obligations, bankruptcy, distressed restructuring. LGD (loss given default) loss on a loan that has defaulted (1-LGD = recovery rate). PD (probability of default) probability of a loan to become defaulted. IBNR (incurred but not reported) losses losses which based on statistical data has already occurred but have not been identified individually by the bank
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The segmentation of assets into those which are assessed individually and those which are assessed on the portfolio basis in order to identify loss event. Individually significant items are assessed individually. Individually insignificant items are assessed either individually or on the portfolio basis (portfolios build based on similar credit risk characteristics) Assessment of significance should take into account actual management of an exposure (managed on individual basis or group basis) Those which have been identified as impaired during individual assessment are excluded from the collective assessment Collective assessment is not possible if the number of homogenous transactions is insufficient Need to compare model results with the actual losses
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Deloitte 2007
Credit risk type of given transaction/portfolio and credit risk management method employed by the Bank: retail vs. non-retail exposures when dividing exposures into those assessed individually and collectively it is important to account for the actual method used to manage given exposures; Financial report materiality (value of transaction / portfolio individually / collectively); Number of transactions of a given type and availability of data relating to those transactions portfolio approach cannot be used if there is a small number of transactions of a given type.
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Past due status in principal or interest payments past due 90 days or more. Significant breach of contract. Distressed restructuring: Change in payment schedule of credit/transaction arising from lack of financial ability on the part of the borrower to make payments specified in the original contract, The Bank has requested payment of the obligation (in whole), but has not started collateral realization proceedings, Contract cancellation (in whole or in part) and /or start of collateral realization proceedings.
Decrease in the borrowers rating. Information regarding account blocked as of the date of the analysis (for significant reasons). Decrease in borrowers rating (into default category or by two grades or more). Decrease in the value of collateral: increase in LTV (transaction exposure amount / value of realizable collateral) above a certain threshold for project finance transactions and brokerage loans.
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Impairment occurs only when a loss event(s) occurring after the initial recognition of an asset negatively impacts the amount and/or timing of cash flows related to the asset. In this case, the Bank should measure the potential impairment loss amount and related provisions. Expected losses which may arise due to future events, no matter how likely, are not recognized. However, need to recognise incurred but not reported losses (IBNR). Impairment loss = Carrying amount recoverable amount recoverable amount = PV (expected cash flows from the asset) + PV (expected cash flows form collaterals) PV (collection expenses)
The discount rate used to calculate PV of expected cash flows is the assets effective interest rate at the impairment measurement date (for restructured assets effective interest rate from the moment of restructuring). Under IFRS interest income is calculated and recognized in income statement on impaired assets (concept of suspended interest is not present in IFRS). If there is a decrease in impairment loss in a future time period which is caused by events which occurred after the initial impairment recognition, provisions for impairment should be decreased.
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Provision for guarantees, letters of credit and unused credit lines calculated under IAS 39 & IAS 37. The approach to off-balance sheet exposures entails calculating the provision which should be the larger of two values: best estimate of current obligation calculated under IAS 37 or fair value as at initial recognition (usually premium received for granting guarantee) adjusted for amortization of the initial fair value according to IAS 18.
Provision amount is decreased by expected recoveries from collateral, unless the collateral constitutes a guarantee or insurance policy provided by a different entity in this case the collateral is accepted only if its realization is virtually certain. Credit Conversion Factor (CCF) applied for measuring provisions for off-balance sheet exposures.
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Loan
Deloitte 2007
A bank extended a 2 year loan for 100 PLN. The Bank did not take any commissions at loan origination. Consequently, the contractual interest rate on the loan of 10% is equal to the effective interest rate (EIR). The principal is to be repaid in two equal installments at the end of each year. One year after loan origination, the loan was identified as impaired (the debtor went bankrupt). The book value of the loan at the time of impairment amounted to 110 PLN (100 principal + 10 accrued interest). The bank assessed the recoverable amount from collateral at 66 PLN to be received in one year. After discounting the recoverable amount using EIR (10%), the present value (PV) of the recoverable amount equals to 60 PLN (66/(1+10%)=60). Consequently, a 50 PLN (110 60) provision was created, and consequently the net book value of the loan after provision amounts to 60 PLN. From this moment interest should still be accrued using to the original EIR (10%), but now applied to the 60 PLN basis. Consequently, after one year accrued interest will equal 6 PLN and the net book value of the loan will equal to 66 PLN (60 + 6), which is the amount the bank estimates to obtain from the collateral realization.
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1)
2) 4)
2) 4) 6)
Provision 50 1) 2) 3) 4) 5) 6)
3)
Loan extension Contractual interest accrual for first year (before impairment) Creation of provision Contractual interest accrual for second year Interest income adjustment to impairment interest level Interest income for second year according to IFRS (impairment interest) Impairment interest: Contractual interest Loan net book value Interest rate Impairment interest Interest adjustment
Provision calculation: Principal Accrued interest Book value of the loan Minus: discounted recovery Provision
10 60 10% 6 4
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Implementation of Impairment Tool supporting identification, assessment and measurement of impairment losses and IRR Tool supporting effective interest rate calculation and EIR adjustments or alternatively Supporting internal or external development, implementation, and acceptance test of IT tool supporting impairment identification and measurement of impairment losses and effective interest rate.
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Special cases
During implementation there is a need to cover special cases for which IAS 39 does not provide direct treatment, for example:
Mismatch between currency of loan (e.g. EUR) and collateral value which is usually assessed in local currency (e.g. RON). Should it be converted using: spot rate or forward rate?
Which interest rate use for discounting of recoveries from a loan after troubled restructuring? IAS 39 requires to use the rate prior restructuring. But what to do if, for example: the rate prior restructuring was floating? the currency of the loan has changed?
Impairment interest on exposures for which IBNR provision has been created.
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Lack or insufficient quality of data on historical recoveries, default rates (PD), credit conversion factor (CCF) extended use of expert judgement. Too small homogenous portfolios impossible to apply collective approach. Lack or insufficient quality of data on current collaterals e.g.: difficulties in linking collaterals with loans, inaccurate collateral value entered in the systems,
Difficulties in linking interest rate used for discounting with appropriate loan.
Changing mindset of staff involved in assessing individual impairment (e.g. sale staff - credit officers responsible for loans). Interest income after impairment adjusting contractual interest calculated by core banking systems conceptual (e.g. treatment of repayments and other events) and technical (infrastructure) problems.
Deloitte 2007
Assistance in calculating provisions at opening balance and any other dates. On going consultations on impairment methodology after completing the project. Organization of the impairment measurement process. Preparation of internal procedures. Data mining gathering data on historical default rates (PD), recoveries (LGD), collaterals etc. Data cleansing e.g. collateral data. Implementation of validation procedures to assure high quality of data. Implementing work flow for bad debt collection department. Modifying KPI affected by impairment (provisions and interest after impairment). Modifying budgeting and controlling processes affected by impairment (provisions and interest after impairment).
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Experience from a working group developing National Bank of Poland impairment recommendations
Polish Banking Supervision Commission (KNB) aimed at developing recommendation (Recommendation R) that would present best practices in implementing impairment requirements under IFRSs, including: defining roles and responsibilities of banks Supervisory Board and Management Board in the impairment process e.g. establishing the process of impairment identification and measurement and internal controls for this process, defining elements of internal impairment identification and measurement rules and procedures, defining impairment methodology, including use of expert judgement, valuation models, rules for creating homogenous portfolios, valuation of collaterals, validation tests, collecting historical data, defining roles of internal audit in relation to impairment process, explaining IAS 39 impairment concepts especially in the areas where IAS 39 does not provide direct guidance.
The Recommendation is not a binding law approaches other than those presented in the Recommendation are also acceptable (provided they are in accordance with IFRSs).
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Impairment Tool
Impairment Tool implements a transparent and real life proven concept of IFRS adjustments:
The Tool allows to maintain the existing process related to transactional systems operation and processing, that are currently implemented in a bank (IFRS requirements do not override the need to obtain data using the existing methods, e.g. tax, legal, business line performance, client communication). No significant changes to the banks reporting process are required: the existing reporting systems and the organization / reconciliation process still apply, but with a new (not critical) component added. The output data may be delivered on various levels to seamlessly integrate with the current banks environment: analytical data extracts required for reporting, stand alone GL as an adjustment to local GAAP GL, or direct adjustments accounted in the banks GL by using the existing interfaces.
The solution is focused on events, which have impact on IFRS valuation (all unadjusted values remain only in the core systems). Effective implementation, fastest processing (less data), transparent and verifiable, integrated into existing architecture.
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Deloitte 2007
Calculation methods Different methods of impairment calculation enabling convergence with the approach used in credit risk management (expected cash flows individual method, transition matrices portfolio method based on risk pools, optional direct input of risk parameters: PD, LGD). Portfolio management basing on characteristics of the chosen transaction and on the expert model parameterization. Analysis of scenarios and approval of parameters for calculation (PD, RI). Collection of historical recovery data and calculation of historical LGDs. Easily modifiable / extendable (on implementation level) event handling mechanisms for EOD processing. Preparation of reports for the accounting purposes.
Built in GL functionality Maintaining history of individual postings, triggers (events) for postings, account balances on transaction level. Revaluation mechanisms for foreign currency exposures and other residential processes EOM / EOY on single transaction / account level. Possibility of exporting account balances in pre-defined structure (file/DB) Flexible parameterization (on implementation level) of accounting schemes for each defined event Recognition of interest income on impaired loans and adjustments to bring interest income to the level of impairment interest.
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Individual exposures
Suitable user interface enables user to search (including multiple criteria search), browse and review of the Banks exposures. Available exposures may be limited based on users assigned rights.
Exposures matching search criteria listed together with major transaction details (e.g default and default acceptance status) For the chosen exposure the user chooses the loss-event from the predefined list (causing appearance of default flag). Default has to be approved by supervisor. Changes made by the user are stored for supporting of audit trail.
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When the user marks the exposure with a default flag, all other exposures of the given client are automatically marked with the default flag. Classification and default-flagging of exposure (including approval process) takes place automatically for the exposures that are portfolio-managed and manually for the exposures assessed individually. For the exposures that are individually assessed loss-events that can be automatically derived from transaction systems (e.g. days overdue) are also processed automatically. For defaulted transaction the user: Estimate estimated recoveries from principal (repayments expected from the borrower), supported with presented contractual repayment schedule. Estimate recoveries from interest (estimated repayments expected from the borrower).
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In case of estimating recoveries from tangible assets collaterals (e.g. property, plant and equipment, inventories) the system provides functionality allowing for additional verification of estimated recoveries by experts (banks valuators) in particular type of collateral.
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Deloitte 2007
In collective impairment approach the system enables definition of new portfolios for the calculation of PD and RI, basing on chosen transactions characteristics (product type, client rating etc.) Each available product can be assigned to a chosen portfolio. Definition of particular portfolios is available for the system administrator. For each type of product additional parameters can be defined to be used in the calculation (CCF, type of the discount rate).
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Calculation of provision is based on given computational set of data All results of provision calculation are available in the system. The last accepted provision could be also seen in the detailed view for each separate transaction. Before generating final report on provisions an approval is required
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This functionality enables a bank to build its own database of historical recoveries. Data collected on actual (historical) recoveries and collection costs are available in various reports.
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Administration
The system enables user and privileges management, stores users e-mail addresses and allows automatic notification via e-mail. During processing and computations the system presents the progress and status of computations.
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Additional features
Integration
Web user interface can be simply adjusted to different look and feel or translated to a local language (Custom Style Definition and resource bounding are used). Currently Polish version is available due to the clients requirements, an English version is planned. Application outputs are available in both an extract file (text, Excel), relational data set, or MQ messages. Either the internal ETL procedures or an external ETL tool may be used to integrate with the data sources.
Security
Impairment Tool takes advantage of the company global users repository (e.g. LDAP) to align users access with global privileges. Users roles are used to define access to the Tool functionality (specific modules and specific functions in modules). Restrictions on transactional data scope might also be implemented. Security functions are performed at the application server layer and are configured by a system administrator. That allows to define user groups (e.g. managers, operators, administrators) and then to assign users to those groups. The Tool record the users activities in a data base log, providing an audit trail option.
Performance
The Tool can be deployed on various system configurations scaling their performance to the provided IT infrastructure. The Tool implements a multi-tier architecture: each tier can be run on dedicated server in order to achieve the required performance
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According to the working cycle of a Branch, at least as often as main calculation cycle
Regardless ofod the Niezalenie main calculation gwnego cyklu oblicze cycle
Main calculation cycle (monthly cycle Gwny cykl obliczeniowy other frequency is possible) etap zatwierdzenia miesica w cyklu miesicznym )
YES
OK ?
NO
NIE
NO
OK ?
YES
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Architecture
Client Client layer Client Client
The Tools are built on Java technology which means it can be deployed on various hardware and software platforms. Accessible to the end-users via a thin web based client, from any workstation in the local or wide area network. Internet Explorer required only. Presentation tier and the workflow logic run on an application server (J2EE compliant). The source data is loaded into an internal data store, with use of the application ETL procedures, or an external ETL tool. Computations are performed on the Tools internal operational data store, independently from any banking systems (does not influence other banking systems performance nor security). For Impairment Tool, calculation logic is implemented as SQL procedures run directly on systems operational store. Tools have built-in basic reporting functionality. For further analysis relational data sets are available. Computing results are accessible for any external system (e.g. for reporting and further analysis) in the form of relational data sets, extract files, or direct bookings.
Database server Oracle
Data layer
System 1
System 2
System 3
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Logical architecture
SOURCE DATA LOADING
DATA LOADING FROM EXTERNAL DATA STORE
System has a clear-cut layered structure that enables effective functional customization.
Adjusting the system to custom requirements might be done effectively due to system layering. It is possible to change one aspect of the system while others are left untouched. It is possible to adjust the system to an alternative impairment calculation methodology.
MODEL PARAMETRISATION
PD MODULE LOSS-EVENTS DICTIONARY IMPAIRMENT AND REPORTS PORTFOLIO DEFINITION
CALCULATION OF PROVISIONS
PROVISIONS CALCULATIONS IMPAIRMENT INTEREST RATE CALCULATIONS RESULT ARCHIVING
The computation process is run asynchronously, i.e. other functions are still available to the users while daily/monthly computations are being performed.
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Deloitte ul. Piekna 18 00-549 Warszawa Poland tel. +48 22 511 0077 fax. +48 22 511 0813 For any questions contact: Adam Kolaczyk akolaczyk@deloittece.com
Deloitte 4-8 Titulescu Road, 3rd floor, sector 1, Bucharest, 011141 Romania Tel. +40 21 222 1661 Fax: +40 21 319 5100 For any questions please contact: Natalia Cierna ncierna@deloittece.com
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