GASB No. 53 – Accounting For Derivative Instruments FGFOA Conference, Orlando FL, Mark A. White, CPA, Partner, Purvis Gray & Company LLP Jim Towne, Senior VP, DerivActiv Precision Experience Assurance 1 Statement 53 Accounting and Financial Reporting for Derivative Instruments Precision Experience Assurance 2 Attribution and Acknowledgment We would like to acknowledge and thank both David Bean of GASB and Stephen Gauthier of GFOA for sharing some of their presentation materials on this subject with us. Much of the material contained in this presentation comes from information that they have provided, we hope to do it some justice! Precision Experience Assurance 3 What Will We Talk About Today? There are many different types of derivatives that exist in the markets today Impossible to cover all possibilities today Will cover basics of the statement Will go into more detail on Interest Swaps Interest Rate Swaps are the most common derivative used by local governments and are a major piece of the statement Precision Experience Assurance 4 Prior Guidance Supersedes Technical Bulletin No. 2003-1, Disclosure Requirements for Derivatives Not Reported at Fair Value on SONA Amends Statement No. 7, Advance Refundings Resulting in Defeasance of Debt, paragraph 11 Amends Statement No, 23, Accounting and Financial Reporting for Refundings of Debt Reported by Proprietary Activities Various other less used areas Precision Experience Assurance 5 One Page Summary of No. 53 Derivatives generally fit into two general categories; Hedging derivative if effectiveness test is met Record at FMV and defer the gain or loss Investment derivative if effectiveness test is not met Record at FMV and recognize investment gain or loss OUCH!! Thus most of the statement deals with meeting hedge effectiveness—the prize! Precision Experience Assurance 6 What is a Derivative Instrument for Financial Reporting Purposes? A financial instrument or contract that has all of the following characteristics: Precision One or more reference rates (underlying) and one or more notional amounts or payment provisions LIBOR, SIFMA Currency or other units specified in the derivative Currency units, shares, pounds, MMBTUs Leverage Little or no initial cash investment Net settlement Terms require or permit settlement net Not required to take delivery of commodity Can be settled with another derivative (swaption) Experience Assurance 7 How Does a Derivative Differ From a Traditional Financial Instrument? Investment instruments—generally do not meet the second characteristic (initial investment is not leveraged) Debt instruments—generally do not meet the third characteristic (not net settled) Precision Experience Assurance 8 Excluded Instruments Normal purchases and normal sales contracts Commodity—for example, gas or electricity used in an activity Government intends to and has practice of taking delivery or selling the commodity Quantity is consistent with volume used Traditional insurance contracts Non exchange-traded climate contracts, liquidated damages, etc. Precision Experience Assurance 9 Hedging Derivative Instruments The derivative instrument is associated with a hedgeable item Consistency of notional amounts Derivative instrument will be reported in same fund as hedgable item Term or time period consistency The hedging derivative is effective in significantly reducing the identified financial risk using No. 53 methods Precision Experience Assurance 10 Common Derivative Instruments Interest Rate Swaps Futures contracts--NYMEX Options—exchange-traded and others Swaptions Precision Experience Assurance 11 Features of Futures Contracts Exchange-traded-NYMEX, etc. Standard terms—notional amount, reference rate/underlying, settlement dates At the market Entered into a no cost; however, accounts are adjusted daily Margin—collateral is required Precision Experience Assurance 12 Terminating Events Hedge accounting to cease upon terminating event; Hedging derivative is no longer effective by applying No. 53 criteria Hedging derivative is terminated Bond refunding (interest rate swap) Precision Experience Assurance 13 Terminating Events Balance in deferral account should be reported in flow of resources statement within investment revenue - no more hedge accounting If refunding or advance refunding of hedged debt, the balance in the deferral account is considered carrying value of old debt for gain or loss on refunding If debt is remarketed—no gain/loss deferral must go to investment gain/loss Precision Experience Assurance 14 How To Implement Two ways to calculate effectiveness; End of first year of adoption (FYE 9/30/10) Life to date of derivative through end of first year of adoption (5/14/04 through 9/30/10) Must have information available from inception Annual test, can use any of the approved methods If you test as of 9/30/10 and are deemed effective; employ hedge accounting Record derivative at FMV and defer the gain loss at 9/30/10 values Re-test annually Precision Experience Assurance 15 How To Implement If 9/30/10 effectiveness fails; Test effectiveness as of 9/30/09, if effective; Record at FMV and defer gain/loss as of 9/30/09 Bring deferred gain/loss into Investment Income in 2010 Test effectiveness as of 9/30/09, if ineffective; Record at FMV and restate equity as of 9/30/09 Current year change in FMV—investment gain/loss What about retesting next year if ineffective this year? Too bad forever, unless terms of instrument substantially modified Record at fund level or entity wide? Precision Experience Assurance 16 Practical Considerations If Interest Rate Swap effectiveness fails; DSC coverage problems in utility funds? Pledge of NET Revenues Resolution definitions Technical default Additional bonds test FAS 71 bail out? Would not be a problem for governmental debt where gross revenues are pledged and Swap not recorded at fund level Precision Experience Assurance 17 Methods of Evaluating Effectiveness Consistent Critical Terms Notional amount same as principal amount Issued at FMV of zero Formula for net settlements don’t change over the term of the instrument Same reference rates Both or neither can have cap or floor Same time interval of reference rate Same maturity dates Precision Experience Assurance 18 Methods of Evaluating Effectiveness Synthetic Instrument Method Didn’t pass the CCT test, must now measure how much difference there is Test of if the variable cash flows substantially offset, -the synthetic fixed rate is substantially fixed Does the difference in variable cash flows move the fixed rate more than 10%? No—Effective Yes– Ineffective Precision Experience Assurance 19 Methods of Evaluating Effectiveness Dollar Offset Method Compares the changes in expected cash flows or fair values of the hedging derivative to the same for the hedgable item Can be applied YTD or LTD Has to fall within 80 to 125% in absolute terms Precision Experience Assurance 20 Methods of Evaluating Effectiveness Regression Analysis Other quantitative methods These methods are too detailed to go into today, they are in the statement and implementation guide and Jim Towne can answer any question you might have on them after the presentation Precision Experience Assurance 21 Components of an Interest Swap Time: Beginning and end Reference rate Notional amount Payment frequency Receive variable and pay fixed to counterparty Receive fixed and pay variable to counterparty Precision Experience Assurance 22 Swap-Cash Flow Hedge Fixed payment 5.0% State or local government Swap counterparty Variable-rate coupon payments; SIFMA Variable payment received: 67% of 1month LIBOR Variable-rate bond holders Precision Experience Assurance 23 Consistent Critical Terms Method Fail Due to Benchmark Interest Rate Contract Variable Rate Demand Bonds Swap Value at Inception 0 Swap Fixed Leg Fixed for Life of Swap Notional Amount $ 10,000,000 Bond Principal (no amortization) Termination Date 12/1/2030 Variable Index 70% of 1 Month LIBOR Frequency of Reset Weekly Swap Payment Dates Precision 1st Bus. Day of ea. Mo. Experience $ 10,000,000 (no amortization) Maturity Date 12/1/2030 Bechmark Interest Rate SIFMA Frequency of Reset Wekly Bond Coupon Payment Dates 1st Bus. Day of ea. Mo. Assurance 24 Consistent Critical Terms Method Pass Interest Rate Contract Variable Rate Demand Bonds Swap Value at Inception 0 Swap Fixed Leg Fixed for Life of Swap Notional Amount $ 10,000,000 Bond Principal (no amortization) Termination Date 12/1/2030 Variable Index SIFMA Frequency of Reset Weekly Swap Payment Dates Precision 1st Bus. Day of ea. Mo. Experience $ 10,000,000 (no amortization) Maturity Date 12/1/2030 Bechmark Interest Rate SIFMA Frequency of Reset Wekly Bond Coupon Payment Dates 1st Bus. Day of ea. Mo. Assurance 25 Synthetic Instrument Method (Cash Flow Hedges Only-No Hybrids of Fair Value Hedges) Swap Notional Amount $ 10,000,000 Swap Fixed Rate Pay Fixed - Receive Variable From Counterparty 4% SWAP Index 70% 1 Mo. LIBOR FYE 9/30/2010 Fixed Swap Variable Swap Net Variable Pmnt. To Receipt From Derivative Bond Total Synthetic Counterparty Counterparty (Pmnt) Receipt Interest Payments Rate $ (400,000) $ 100,000 $ (300,000) $ (95,000) $ (395,000) 3.95% Analysis of Synthetic Instrument Test Synthetic Rate 3.95% Swap Fixed Rate 4.00% Percentage Ratio 98.75% Is Ratio Between 90% and 111%? Precision Experience Pass Assurance 26 Synthetic Instrument Method (Cash Flow Hedges Only-No Hybrids of Fair Value Hedges) Swap Notional Amount $ 10,000,000 Swap Fixed Rate 4% SWAP Index 70% 1 Mo. LIBOR FYE 9/30/2010 Pay Fixed - Receive Variable From Counterparty $ Fixed Swap Variable Swap Net Variable Pmnt. To Receipt From Derivative Bond Total Synthetic Counterparty Counterparty (Pmnt) Receipt Interest Payments Rate (400,000) $ 45,000 $ (355,000) $ (95,000) $ (450,000) 4.50% Analysis of Synthetic Instrument Test Synthetic Rate 4.50% Swap Fixed Rate 4.00% Percentage Ratio 112.50% Is Ratio Between 90% and 111%? Precision Experience Fail Assurance 27 Dollar Offset Method FYE FYE Change In 9/30/2009 9/30/2010 FMV Fair Value of Derivative $ (1,000,524) $(1,254,755) $ (254,231) Fair Value of Item Being Hedged $ $(1,044,589) $ (242,144) Dollar Offset 104.992% Does Dollar Offset Fall Within the 80% to 125% Band? Precision (802,445) Experience Pass Assurance 28 Dollar Offset Method FYE FYE Change In 9/30/2009 9/30/2010 FMV Fair Value of Derivative $ (1,000,524) $(1,254,755) $ (254,231) Fair Value of Item Being Hedged $ (802,445) $ (955,447) $ (153,002) Dollar Offset 166.162% Does Dollar Offset Fall Within the 80% to 125% Band? Precision Experience Fail Assurance 29 Disclosures Summary Information; Segregate between Hedging and Investment Derivatives Within each category, present by type Notional amounts FMV and change in FMV Precision Experience Assurance 30 Disclosures Hedging Derivatives; Objectives Terms-notional amounts, reference rates, maturities Risks-credit risk, interest risk, basis risk, termination risk, rollover risk, market access risk, foreign currency risk, Investment Derivatives Risks above Precision Experience Assurance 31 GASB No. 53 – Accounting For Derivative Instruments FGFOA Conference, Orlando FL, Mark A. White, CPA, Partner Purvis Gray & Company LLP, 888-378-2463 Jim Towne, Senior VP, DerivActiv, 952-746-6049 Precision Experience Assurance 32