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Analysing Impact of AS

30, 31, 32 on Banks

Financial Services Industry – Emerging


Trends, Challenges & Way Forward

Presented  by :‐ WIRC of ICAI
Ashutosh Pednekar November 20, 2009 
Partner, M P Chitale & Co.

Disclaimers
” These are my personal views and can not be construed to
be the views of M/s.M. P. Chitale & Co., Chartered
Accountants

” ICAI has no responsibility for its contents

” These views do not and shall not be considered as a


professional advice.

” This presentation should not be reproduced in part or in


whole, in any manner or form, without my written
permission.

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 2


Why an AS for Financial Instruments ?
ΠGlobalisation of Indian Economy;

ΠIncreasing sophistication of financial products and


markets;

ΠIncreased use of derivatives for risk mitigation and


trading;

ΠNo comprehensive standard until now (AS -13, AS - 11


and AS - 16 partly deal with the same);

ΠDiverse practices made comparability of performance


difficult.

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 3

AS for financial instruments

AS 30 AS 31 AS 32

Recognition
and Measurement Derivatives
derecognition of and
Presentation Disclosure
of financial hedge
financial instruments accounting
instruments

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 4


Key concepts
The standard focuses on substance over form in accounting
for financial instruments. The key concepts that come to
fore are:

ΠFair valuation;
ΠSymmetry; and
ΠHedge accounting

The standard is likely to have far reaching implications on


accounting of most assets and liabilities with consequent PL
implications due to fair valuation, changes in various laws
and challenging certain normally accepted principles
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 5

AS 31 – Objective and scope


ΠEstablish principles for
” Presenting financial instruments as liability or equity (and related
classification of interest, dividends, losses and gains) by the
issuer

” Offsetting a financial asset and a financial liability

” Presentation of transactions in own equity

” Accounting for treasury stock

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 6


Financial instruments – definition

Contract that gives rise to A financial liability and /or an


both a financial asset of one & equity
entity instrument of another entity

Financial Financial Equity


asset liability instrument

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 7

Financial instruments – examples


ΠFinancial assets and liabilities
” Trade receivables and payables
” Loans receivable and payable
” Deposits and advances
” Perpetual debt instruments
” Contractual rights arising on contingent assets – eg. Guarantees
” Finance leases

ΠFollowing are not financial assets and instruments


” Physical assets such as property, plant and equipment
” Prepaid expenses (associated with the delivery of goods and services
and not contractual obligation to pay cash or another financial asset).
” Liabilities that are not of a contractual nature (such as income taxes)
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 8
Financial instruments – examples…
IMPACT ANALYSIS
ΠEquity instruments
ΠNew concept for Indian GAAP
” Equity shares
” Irredeemable preference shares
” Portion of preference shares having discretionary dividends after
reducing liability component
” Warrants / written call options that are settled by a fixed number of
own instruments for a fixed amount of cash or another financial
asset (equity option component of a convertible bond/debenture)

ΠDerivative financial instruments


” Options, futures, forwards, interest rate swaps, currency swaps
etc.

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 9

Liability or Equity?
ΠFinancial instrument is an equity instrument only if both criteria are
met:
” There is no obligation to deliver cash or another financial asset or to
exchange financial assets or financial liability; and
” The issuer will exchange fixed amount of cash or another financial asset
for a fixed number of its own equity instruments.

Does the entity have an unavoidable contractual obligation to deliver or exchange?

Yes No

Liability Equity

When there is a statutory requirement for classification as equity or liability,


compliance with law = compliance with AS

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 10


Liability or Equity?
ΠCompound instrument = part equity and part debt e.g. convertible debt
” Split accounting required
” The liability portion is valued first and the equity portion is the residual amount
ΠClassification of liability and equity components of a convertible instrument is
not revised as a result of a change in the likelihood that a conversion option
will be exercised.
ΠStandard does not prescribe the specific line item in equity where a equity
component of a compound instrument should be reflected in.
ΠNo gain or loss arises from initially recognising the components of a
compound instrument separately.
ΠOnce allocation of equity and liability components are made, subsequent gain
or loss is made in accordance with the accounting principles applicable to the
related component.
ΠSubsequent changes in the terms of an instrument are recognised (by
comparing with the fair value of the new instrument) in the profit and loss
account.
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 11

Liability or Equity?
A contract is not an equity instrument solely because it will result in the delivery of
the entity’s own equity instruments

Does the issuer potentially have


an obligation to settle gross in
cash or in a variable number
Yes Liability
of own shares?

No

Will settlement be the exchange


of fixed number of shares
for fixed amount?
Yes Equity

No

Derivative
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 12
Contingent settlement provisions

An instrument with a contingent settlement provision would


be a financial liability for the issuer unless:

ΠThe contingent settlement provision that could require settlement in


cash or another financial asset is not genuine; or

ΠThe issuer can be required to settle the obligation in cash or another


financial asset only in the event of liquidation of the issuer.

IMPACT ANALYSIS

ΠRecognition on BS the financial liability arising out of such


provisions

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 13

Buyback of shares

If an entity re-acquires (buys-back) its own shares, nominal


value of those shares should be deducted from share capital
ΠNo gain or loss should be recognized in the profit and loss account;

ΠDifference between the consideration paid and the nominal value of


shares should be recognized in an appropriate equity account.

IMPACT ANALYSIS

ΠIn an era of capital raising by banks this has not been


experienced yet

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 14


Interest, dividends, losses and gains

Income statement classification of interest, dividends, losses and gains


follows directly from the balance sheet classification as liability or equity.

ΠAny income statement effect on a financial liability will be recognized as an


expense irrespective of the nomenclature of the item eg. dividends,
distributions etc.
ΠDistributions to holders of an equity instrument should be recognized in an
appropriate equity account
ΠTransaction costs, net of any income tax benefit, of an equity transaction
should be recognized in an appropriate equity account
ΠDiscount accretion / redemption premiums form part of the recognized
interest expense for a period on an effective interest rate basis.
ΠDividends classified as an expense are presented in the statement of profit
and loss as a separate item.

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 15

Offsetting a financial asset and a


financial liability
currently has a legally enforceable right to set off
and an intention to settle net
or to realise the asset and settle the liability simultaneously

but

Practical situations will cause implementation challenges


ΠMaster netting agreements
ΠSeveral instruments used to emulate a single instrument (synthetic instrument)
ΠItems with the same risk, but different counterparties
ΠFinancial assets pledged as collateral for non-recourse liabilities
ΠFinancial assets that did not qualify for de-recognition under AS 30

In practice, netting will be difficult to achieve other than in very limited


situations….because neither pure intention nor pure legal right is sufficient

IMPACT ANALYSIS

ΠNew concept for Indian GAAP

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 16


AS 30 Coverage

Ô Definition

Ô Recognition & Measurement

Ô Reclassification

Ô Impairment & Derecognition

Ô Derivatives & Embedded Derivatives

Ô Hedging

Ô Transitional Provisions
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 17

Scope of AS 30 – applies to all Financial


instruments except:
ΠInterest in Subsidiaries, Associates and Joint Ventures covered by AS 21,
23 & 27 except as mentioned in those standard;
ΠLease transaction covered by AS 19. However lease receivables, payables
& derivatives embedded in lease will be covered by this standard;
ΠInsurance Contracts. However financial guarantee contracts and derivatives
embedded in insurance contract covered by this standard ;
ΠContingent consideration for the acquirer or business combinations to buy
or sell at a future date;
ΠLoan commitments, other than specific inclusions;
ΠShare based payments (incl ESOPs) and Employers rights and obligations
under AS 15;
ΠOwn use commodity contracts other than those which are generally settled
net in cash;
ΠItems are scoped out of the standard if another standard is more prescriptive
in dealing with such items.
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 18
Present Classification of financial
instruments by Banks

Category Particulars
Loans ΠBills Purchased & Discounted

ΠCC, ODs and Loans Repayable on Demand

ΠTerm Loans

Œ Further detailed presentation – popularly called 9 –way


classification

Investments Π6 line items to be presented

Œ 3 way categorisation Æ HTM, AFS & HFT

Derivatives ΠPresented by way of a note and as Contingent Liabilities

Liabilities ΠNo specific categorization other than the line items


specified in the BR Act format
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 19

AS’ classification of financial


instruments
Category Definition
Financial assets ΠClassified as held for trading (intended to be actively
and financial traded)
liabilities at fair
value through profit ΠAll derivatives are classified as held for trading (except
and loss those used as hedging instruments on financial guarantee)

ΠFinancial asset or financial liability designated as such at


inception (subject to certain conditions)

Held-to-maturity ΠFinancial assets with fixed or determinable payments and


investments fixed maturity that an entity has the positive intention and
ability to hold to maturity
Loans and ΠNon-derivatives financial assets with fixed or determinable
receivables payments, whether originated or acquired, quoted in an
active market. (Does not need to have a fixed maturity)

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 20


AS’ classification of financial
instruments…
Category Definition
Available-for- ΠNon-derivative financial assets designated as AFS
sale financial or that are not:
assets
” Loans or receivables
(AFS)
” Held-to-maturity investments

” Financial assets at fair value through profit


and loss
Other financial Œ Financial liabilities that are not classified as “fair
liabilities value through PL”, e.g. Warrants, obligations to
deliver cash/cash equivalents/financial assets

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 21

Held-to-Maturity Investments

Positive intent and ability to hold to maturity ?

Yes

Was any held-to-maturity instrument sold or


reclassified in the current or two preceding years?
Yes No

ΠNear maturity Yes


Classify as held-to-maturity and
Œ Isolated event beyond an entity’s control measure at amortised cost
ΠCollected substantially all principal OR
ΠInsignificant amount in relation to the held-to-
maturity portfolio IMPACT ANALYSIS
No
ΠRBI permits sale of
Reclassify all HTM instruments as HTM portfolio – will
available-for-sale
this fail the test of
intention to hold?
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 22
Available-for-sale financial assets

ΠAll available for sale assets are marked to market through a separate
component of equity (Investment revaluation reserve account)
ΠGains and losses on AFS assets are recognised in the profit and loss
account on disposal or impairment of the asset. However, there are a
number of other complications with available for sale gains and losses

Gain or loss on available-for-sale asset

Change in value Change in value


Effective interest Other changes in
due to embedded due to spot FX
rate fair value
derivative change

Profit and Loss Account Equity

Recycled to the profit and


loss account on disposal or
impairment of the asset

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 23

Classification determines subsequent


measurement of financial assets
IMPACT ANALYSIS

ΠAll valuation has to be


Classified as held for
trading or designated on gross basis unless
At fair value Yes
as at fair value off setting applies
through P&L
through P&L at
inception
No
(Amortised) cost

Non-derivative
Fair value

financial assets, Yes Loans and


fixed/determinable
receivables
payments, not quoted
in active market
No

Intent and ability to


No hold to maturity Yes
Available-for-sale Held-to-maturity
and meets other
criteria

… similarly applies to financial liabilities

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 24


Initial Recognition
Initial Recognition of a FA or FL to be done by an entity
when, and only when it becomes a party to the
contractual provisions of the instrument

All contractual rights & obligations under derivatives are to


be recognized on balance sheet as asset or liability except:-
ΠIf a transfer does not qualify for dercognition then

” Transferor does not recognize derivatives of the FA / FL separately

” Transferee does not recognize transferred FA / FL as its FA / FL

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 25

Initial Recognition…
Recognize assets to be acquired or liabilities to be incurred as
a result of firm commitment to purchase or sell goods or
services only when
ΠAt least one of the parties has performed under the agreement or
ΠIt is a firm commitment applicable under the Standard
” But in case of an unrecognized firm commitment that is designated as
“hedged item” in a fair value hedge, any change in net fair value attributable
to hedged risk is recognized as asset or liability after inception of hedge

Œ Don’t recognize FA/FL arising out of planned future transactions no


matter how likely, as entity is not party to the contract

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 26


Initial Measurement
FA / FL @ FVTPL Short-term receivables / Other FA / FL
payables with no stated interest
rate

At fair value on Original invoice amount At fair value + / - directly


attributable transaction cost
date of if effect of discounting is
acquisition or immaterial
issue
If settlement date accounting is used for an asset that is subsequently
measured at cost or amortized cost, then it is initially recognized at FV on
the trade date

Fair Value = the amount for which an asset could be exchanged, or a


liability settled, between knowledgeable, willing parties in an arm’s
length transaction
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 27

Fair value (FV)


Presumption of FV
Entity is a going concern, without
Πthe intention or need to liquidate or
Πcurtail materially the scale of operations or
Πto undertake a transaction on adverse terms
FV is not the amount that would be received or paid in
Πa forced transaction,
Πinvoluntary liquidation or
Πdistress sale
FV reflects credit quality of financial instrument
E.g. Amount lent at below market rate and up-front received as
compensation; discount accreted to the PL A/c using effective
interest rate method
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 28
Transaction Costs (TC)
TC = Incremental cost directly attributable to acquisition, issue or disposal
of FA or FL
ΠIncrement cost = cost that would not have been incurred if the entity had not acquired,
issued or disposed off the financial instrument

” For FA Æ TC are added to amount originally recognized

” For FL Æ TC are deducted from amount of debt originally recognized

” Present RBI requirement is to charge off TC

TC expected to be incurred on transfer or disposal of a FI are not included in its


measurement
TC not considered in fair value measurement at initial recognition
ΠFI @ FV through PL

ΠShort term receivables & payables

TC included in calculation of amortized cost using effective interest rate method and
thus amortized through P & L over life of instrument
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 29

Subsequent Measurement of FA
FA @ FVTPL HTM Investments Loans & Available for Sale
Receivables
FV without Amortized Cost Amortized Cost using FV without
deducting using effective effective interest deducting
transactions costs interest method method except for transactions costs
short-term that maybe incurred
that may be
receivables that are on sale or disposal
incurred on sale or carried at original
disposal invoice amount

No test for Test for Test for impairment Test for


impairment to be impairment to be to be performed impairment to be
performed performed performed

ΠEquity instruments without quoted value & whose fair value cannot be reliably measured and
derivatives linked to such equity instruments Æ measured at cost
ΠFor FA measured at FV and the FV is negative, then it is a FL
Œ Hedged FA items Æ to follow hedge accounting requirements

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 30


Subsequent Measurement of FL
At amortized cost using effective interest method except
ΠFL at FVTPL unless
” Derivative liability linked to an unquoted equity instrument whose
FV cannot be determined Æ measured at cost
ΠFL arising out of transfer of FA not qualifying for derecognition
” Recognize obligations retained by the entity
ΠShort-term payables at original invoice amount
ΠFinancial Guarantee Contract & Commitments to provide Loans
below Market Interest Rate, higher of
” Amount determined as per AS 29 and
” Amount initially recognized
Œ Hedged FL items Æ to follow hedge accounting requirements

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 31

Trade date/Settlement Date

Regular Way Purchase or Sale of a Financial Asset


ΠTrade Date Accounting : The trade date is the date that an entity
commits itself to purchase or sell an asset.
ΠSettlement Date Accounting : The settlement date is the date on
which an asset is delivered to or by an entity.

There is no bar in applying Trade Date Accounting for


certain category of Financial Asset and Settlement Date
Accounting for another category

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 32


Reclassifications
At fair value through profit or loss category
ΠNo reclassification of a financial instrument either into or out of this
category is permissible IMPACT ANALYSIS

HTM Investments to AFS category ΠRBI permits reclassification


– will this be construed as
Œ Reclassify the investment as ‘available for sale’ against AS 30?

ΠRemeasure it at fair value

ΠRecognise the difference between its carrying amount and the fair value in the
appropriate equity account (Investment Revaluation Reserve Account).
From AFS to HTM category
Πthe fair value carrying amount on that date becomes its new cost.
ΠAny previous gain or loss recognised directly in the appropriate equity
account:
” Is amortised over the remaining life of the investment using the effective
interest rate method.
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 33

Gains & Losses on changes in FV


IMPACT ANALYSIS
FA / FL @ FVTPL
Œ Recognized in P & L Œ AFS Æ presently net negative in PL
and net positive is ignored
AFS – FA
ΠAppropriate Equity Account (Investment Revaluation Reserve) except
” Impairment losses & Foreign Exchange Gains & Losses to P & L
ΠWhen FA is derecognized, balance in this equity account is transferred
to P & L
FA / FL @ Amortized Cost
ΠRecognized in P & L
ΠHedged items to follow Hedge Accounting requirements
In case of settlement date accounting
ΠChange in FV between trade date & settlement date is not recognized if
the FA / FL is carried at cost
ΠOtherwise it is taken to P & L or the Appropriate Equity Account

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 34


Objective evidence of impairment
At each balance sheet date, the entity should assess
whether there is objective evidence of impairment for an
asset or group of financial assets
Evidence of impairment
ΠSignificant financial difficulty of the issuer
ΠDefault or breach of contract
Œ Granting of a concession by the lender due to the borrower’s financial position
ΠBankruptcy or financial reorganisation of the borrower
ΠDisappearance of an active market for the assets concerned because of financial
difficulties
ΠSignificant or prolonged decline in market price in the case of an equity security
ΠObservable data that there is a measurable decrease in the estimated future cash flows
for a group of financial assets
” Adverse changes in the payment status of borrowers in the group
” National or local economic conditions that correlate with defaults on assets in the group

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 35

Assessment of objective evidence for Impairment


of financial assets measured at amortised cost

Individually significant
financial assets

yes no

Asses separately Collectively

results

Individually continue
significant impaired

yes no
Not included in IMPACT ANALYSIS Included in
collective ŒWill all this change the IRAC collective
assessment norms? assessment
ŒFocus is on cash flows not on
security value as at present
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 36
Derecognition
Removal of a previously recognised Financial Asset (FA)
or Financial Liability (FL) from an entity’s balance sheet
ΠDerecognition of an FA is on transfer of associated risks and rewards
while that of a FL is on extinguishment of obligation
A transaction is treated as a transfer of FA if all three criteria
are met:
ΠAn entity has no obligation to pay amounts to the eventual recipients
unless it collects equivalent amounts from the original asset;
ΠAn entity is prohibited from selling or pledging the original asset; and
ΠAn entity has an obligation to remit any cash flows it collects on
behalf of the eventual recipients without material delay.

Derecognition can be applied to a part of FA / FL or a


part of a group of similar FA / FL
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 37

Derecognition of FA…

Derecognition is applied to a part of a FA or group of


similar FA if, and only if, it meets one of the following
three conditions
Part Comprises Example Derecognition
applied to
Specially identified cash Transaction of an interest Interest cash
flow rate strip flow
Fully proportionate (pro Rights to 90% share of all 90% of those
rata) share of the cash cash flows cash flows
flows
Pro rata share of specially Transaction where the 90% of those
identified cash flows counter party obtains the interest cash
rights to a 90% share of flows
interest cash flows

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 38


Main concepts of derecognition principles
Have the rights to the cash flows from
Yes the asset expired?

No Continued
recognition
Has the entity transferred its rights to
receive the cash flows from the asset? Assets remain on
the balance sheet of
Derecognise No the transferor
Has the entity assumed an obligation to
Assets qualify Yes pay the cash flows from the asset that
meets the conditions in paragraph 18? No
for Yes
de-recognition Analysis of
Has the entity transferred substantially
and removal all risks and rewards?
risks and
Yes Yes rewards
from the No of ownership of
balance sheet financial assets
Has the entity retained substantially all
risks & rewards?

No
Has the entity retained control of the Analysis of
No assets? control of
financial assets
Yes

Continue to recognise the asset to the extent of the entity’s continuing involvement

IMPACT
If the entity retains the right to service the FA for a fee it should recognise a service ANALYSIS
asset or liability for that service contract
ΠSecuritisation guidelines will
E.g. Repo, securitization, PTC Etc.
Ashutosh Pednekar, Partner, M. P. Chitale & Co. need to be reviewed 39

Freestanding derivatives – definition

Three characteristics

Fair value changes in


response to the change in
underlying
z Interest rate No initial
z Financial instrument price net investment or an initial net
investment that is smaller than
z Commodity price
would be required for other Settled
z Foreign exchange rate types of contracts that would at a future date
z Credit rating/index be expected to have a similar
response to changes in
z Index of prices or rates
market factors
z Other variables (in the case
of a non-financial variable -
it is not specific to a party
to the contract)

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 40


Derivatives excluded from AS 30
derivative accounting rules
All derivatives are always marked-to-market (MTM) with
changes in fair value recognised in the P&L (unless used
as hedging instruments in cash flow hedge when fair value
changes are in reserves) except for:

Contracts for ‘normal’ purchases Regular way purchase or sale of a


and sales of non-financial items financial asset
ΠIntended to meet purchase, sale or ΠDelivery within a time frame
usage requirements established by regulation or
convention in the market
ΠDesignated for that purpose
ΠApply trade date or settlement date
ΠWill be settled by delivery
accounting

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 41

Embedded derivatives
An embedded derivative is a component of a hybrid (combined)
instrument that also includes a non-derivative host contract,
where some of the cash flows of the combined instrument vary in
a way similar to a stand-alone derivative.

When to separate? How to identify?

ΠThe embedded derivative is not ΠAn implicit or explicit term in a contract


that makes it behave like a derivative
closely related to economic
characteristics and risks of the host ΠInstruments with conversion features
(e.g. leverage, optionality feature); ΠInstruments with option to extend the term
of debt
ΠEmbedded derivative would be a
derivative if it was freestanding; and ΠIndex linked payments
ΠPurchase or sale of contracts in foreign /
ΠThe host contract is not carried at fair third currency (other than currency of
value through profit or loss major party, or currency in which the
contract is normally denominated)

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 42


Embedded derivatives – decision tree

Host held for trading with changes to fair value Yes


No separation
recorded in the income statement?

No

Does embedded derivative meet the definition No


No separation
of a derivative under AS 30?

Yes

Characteristics or risks which are closely related Yes


No separation
to the host contract?

No
No Entire contract is treated
Can fair value of the derivative component
as held for trading and
separately be reliably measured?
measured at fair value
Yes

Separately account for: IMPACT ANALYSIS


z derivative under AS 30
z host contract under AS 30 or other relevant AS
ΠNo guidelines at
present for embedded
derivatives
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 43

Hedging Relationships
Cash flow

Exposure
Net investment
Fair in a foreign
Value Hedged items Hedging entity
instruments

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 44


Criteria for hedge accounting

1. Hedge relationship must be documented at inception

ΠRisk management objective and strategy for the hedge


ΠIdentification of the hedging instrument
ΠThe related hedged item or transaction
ΠThe nature of the risk being hedged
Œ How hedging instrument’s effectiveness will be assessed

2(a) Hedge relationship must be expected to be highly effective at inception and


subsequent periods

2(b) Hedge effectiveness can be reliably measured

2(c) Actual hedge effectiveness must be measured

3. In the case of hedging future cash flows, there must be a high probability
of that cash flow occurring

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 45

Hedged Items
Qualifying Items ΠRecognized FA / FL
ΠUnrecognized Firm Commitment
ΠHighly Probable Forecast
transaction
ΠSingle or grouped

Designated FI ΠFor its entire fair value or for one


or more risk exposure
ΠFor a portion or a group of similar
assets / liabilities

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 46


Hedged Items…
Designated Non ΠForeign Currency Risk
Financial Items
ΠIn entirety for all risks
HTM ΠCan be hedged only for currency
risk and credit risk

Unrecognized Firm ΠChanges in the fair value through


Commitment Statement of Profit & Loss

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 47

Hedging Instruments
ΠDerivatives can be used as hedging instruments
” Proportion of the instrument can be designated
” Time value can be excluded
” Interest element & spot price of a forward contract can be
separated

ΠNon-derivative FA / FL can be hedging instrument only


for foreign currency risk
ΠHedge accounting permitted only when instruments
involve an external party
” Between group entities, transactions are eliminated and hence
do not qualify for hedge accounting in CFS
” But in SFS hedge accounting is permitted

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 48


Hedging Instruments…
ΠSingle instrument can hedge more than one risk

ΠTwo or more derivatives or proportions of them can hedge


one risk

ΠNot permitted for net written options


” But purchased options are permitted

ΠIn India a corporate can write options only for zero cost


structures Æ which can be designated as Hedging
Instrument
• Purchased options are permitted

• Recent draft guidelines on writing options by corporates


Ashutosh Pednekar, Partner, M. P. Chitale & Co. 49

Qualifying hedging instruments –


General rules
Natural hedges of FX risk permitted in limited circumstances
ΠAll of the derivative must be used in the hedge relationship

ΠDerivative cannot hedge another derivative

ΠMore than one derivative can be used in a hedging relationship

ΠPermitted strategies include:

” partial term

„ 5 year swap used to hedge part of 10 year debt as part of cash flow hedge

” proportional hedging

ΠProfit related hedges not permitted

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 50


Hedge effectiveness
ΠThe effectiveness test itself must be stated upfront in the hedge
documentation. This means that it must be designed and tested to
ensure that it provides a suitable solution before the hedge commences
ΠThere are two components to an effectiveness test:
” the prospective test
” the retrospective test
ΠFollowing criteria to be fulfilled at inception & during the life of the hedge

” Hedge is expected to achieve offsetting changes in fair value / cash flows


attributable to the hedged risk

„ Comparing past changes in fair value / cash flows

„ High statistical correlation between hedged item and hedging instrument

” Actual results of hedge are within a range of 80%-125%

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 51

Hedge effectiveness…
ΠHedging instrument - 120

ΠHedged item + 100


” computed effectiveness is within a range of 80% -125% (83% /
120% in this case)
„ the hedge relationship is highly effective

” nevertheless a loss of 20 has to be recorded in profit and loss


due to ineffectiveness
„ the fact that the hedge relationship is highly effective does not
lead to ignore the loss incurred due to ineffectiveness

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 52


Transitional Provisions
ΠDesignation and Measurement of existing Financial Asset
and Financial Liability.
” Change the designation and measurement as per the standard.

ΠAdjust resultant gain or loss


” To the extent of P&L impact, from the opening Revenue Reserve.
” To the extent of ‘equity’ impact to recognize in equity account.

ΠDerecognition of Financial Assets and Financial Liabilities


” Requirements of the Standard to be applied prospectively.
” Can be applied retrospectively provided the information needed was
obtained at the time of initially accounting for these transactions.
” If chosen to apply retrospectively, it should be done for all FA & FL.
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 53

Transitional Provisions…

ΠHedge Accounting :
” Measure all derivatives at fair value.

” Eliminate all deferred losses and gains if any, arising on


derivatives which under the previous accounting policy of the
entity were reported as assets or liabilities.
” Adjust any resulting gains or losses (as adjusted by any related
tax expense / benefit) against opening balance of revenue
reserves and surpluses.

ΠEmbedded Derivatives
” an entity to assess whether an embedded derivative is to be
separated from the host contract and accounted for as derivative.

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 54


AS 32’s Genesis of Disclosure

Requires disclosures in the financial statements that enable


users to evaluate
Œ the significance of financial instruments for the entity’s
financial position and performance; and
Πthe nature and extent of risks arising from financial
instruments to which the entity is exposed during the
period and at the reporting date, and how the entity
manages those risks.

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 55

Some Disclosures: Balance Sheet

Loans or Receivables designated at FV through P & L


ΠMaximum exposure to credit risks
ΠAny products which mitigates the aforesaid credit risks
ΠChanges in FV due to credit risk & methods used to evaluate it
ΠChanges in the fair value of the products mitigating the credit risks

Financial liability at FV through P & L


ΠChanges in fair value due to credit risk and the methods used to evaluate credit risk.
ΠDifferences between the carrying amount and the amount that would be contractually
required to pay.
Detailed reasons if changes in fair value due to credit risk and methods used to evaluate it
are not disclosed for
ΠLoans or receivables.
ΠFinancial liabilities at FV through P & L.
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 56
Some Disclosures: Balance Sheet

ΠReclassification of a financial asset from cost or amortized


cost to fair value and vice versa
ΠDerecognition of assets transferred
” Nature of the assets
” Nature of retained risk and benefits (rewards) of such
assets
ΠDetails of collateral Рas borrower and as lender
ΠReconciliation of changes in allowances for credit losses
created.
ΠFeatures of compound financial instruments containing
multiple embedded derivatives
ΠDefaults and breaches for loans payable
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 57

Some Disclosures: P & L

ΠNet gains or losses


” Financial assets or liabilities presented on fair value basis.
” Available for sale financial assets
” Held to maturity investments
” Loans & receivables
” Financial liabilities at amortized cost
ΠInterest income and expense excluding assets and liabilities
designated at fair value through P and L
ΠFee income and expense excluding assets and liabilities designated at
fair value through P and L
ΠInterest Income on impaired financial assets
ΠImpairment losses for each class of financial assets
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 58
Some Disclosure: Hedges

ΠDisclosure of types and details of hedges

” Fair value hedge

” Cash flow hedge

” Hedge of net investments in foreign operations

ΠDescription of each type of hedge

ΠDescription of the financial instruments used for hedging and their Fair value

ΠNature of risk being hedged


ΠIneffectiveness recognized in profit and loss account from cash flow hedges and net
investment in foreign operations hedges

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 59

Some Disclosures: Valuation

ΠMethods and valuation techniques


ΠAssumptions applied
ΠBasis of determining fair value

” Market price
” Initial transaction price
” Price quotations
” Valuation techniques based on market data
” Valuation techniques based on assumptions
ΠFair value of class of assets and liabilities should be disclosed in a way that
facilitates comparison with its carrying amount
ΠChanges in fair value estimates
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 60
Some Disclosures: Risk

ΠQualitative disclosures for risk of each class of financial


instruments
”The exposures to risks and how they arise
”Risk management procedures and methods
”Changes in the above from the previous years.
ΠQuantitative disclosures for risk of each class of financial
instruments
”Summary quantitative data provided internally to the key
management
”Concentration of risks

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 61

Some Disclosures: Risk…

ΠCredit Risk

” Failure of a party to discharge its obligation in an contract


ΠLiquidity Risk

” Failure of a party in meeting obligations associated with financial


liabilities
ΠMarket Risk

” The risk that the fair value or future cash flows of a financial
instrument will fluctuate because of changes in market prices.

” Types of market risk: currency risk, interest rate risk and other
price risk

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 62


Impact Analysis
ΠVolatility in earnings
ΠImpact on financial statements
ΠMIS comparability over pre AS 30 and post AS 30 era
ΠPerformance indicators and ratios
ΠIT systems
ΠContractual obligations (debt covenant, compensation)
ΠTaxes & Distributable Profits
ΠManaging market, investors and analysts
ΠGreater level of documentation spelling out intentions
ΠManagement awareness
ΠUse of experts critical
All this applies for bankers reading their clients’ financial statements
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 63

What now?
ΠRBI has set a group to assess impact and draw up a road map for AS
30 implementation in banks
ΠPreparedness to be tested Рdo a dry run and one more dry run
ΠGet ready for the volatility in the standard
ΠArising out of the economic crises IASB is in process of revamping IAS
39. Drafts / discussion papers issued on:-
• IFRS 9
„ Classification & Measurement Æ lesser number of categories of
FIs
„ Amortized Cost & Impairment
„ Hedging
• Fair Value Measurement Æ new definition of FV
• Credit Risk in Liability Measurement
Ashutosh Pednekar, Partner, M. P. Chitale & Co. 64
Thank You

ashu01@mpchitale.com

Ashutosh Pednekar, Partner, M. P. Chitale & Co. 65

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