Proposed Accounting for Derivatives Why Is It So Hard? Different instruments & countless products Discounting, present value, yield curve, implied forward rate, volatility, option pricing, gamma, theta Jargon Hedging: offsets versus outcomes Accounting model Mixed attribute model Expected transactions are not recognized in the accounting model Examples of Jargon Caps, Collars, Floors Spark spread Crack spread GASB Environment— Derivative Users Pensions and endowments: foreign exchange derivatives Utilities and transit agencies: energy derivatives Governments active in debt market: interest rate swaps No investment banks Some History Technical Bulletin 94-1, Disclosures about Derivatives and Similar Debt and Investment Transactions Statement No. 31, Accounting and Financial Reporting for Certain Investments and for External Investment Pools Technical Bulletin 2003-1, Disclosure Requirements for Derivatives Not Reported at Fair Value on the Statement of Net Assets GASB Documents GASB’s Preliminary Views document, Accounting and Financial Reporting for Derivatives Plain Language Supplement, Accounting and Financial Reporting for Derivatives Both issued March 31, 2006 and available at www.gasb.org What is a Derivative for Financial Reporting Purposes? A derivative has: 1. One or more reference rates (underlyings) and one or more notional amounts 2. Leverage 3. Net settlement Examples of Derivatives Interest rate swap Variable-rate to fixed-rate Fixed-rate to variable-rate Basis swap Exchange payments based on the changes of two variable rates Swaption Gives the purchaser of the option the right, but not the obligation, to enter into an interest rate swap Commodity swap Reduce exposure to a commodity’s price risk Hybrid Instruments Hybrid instruments consist of a companion instrument (not measured at fair value) and a derivative (measured at fair value) This is a substance over form issue: A derivative should be treated as a derivative regardless of whether it is a stand-alone instrument or included in another instrument, such as a bond, insurance contract, or a purchase or sale contract Example: off-market swap. That is, a swap that presents a government with an up-front payment. Excluded Instruments Normal purchases & normal sales contracts Commodity (e.g., gas or electricity) Govt. intends to and has practice of taking delivery or selling commodity Quantity is consistent with volume used Traditional insurance contracts Traditional financial guarantee contracts Non exchange-traded climate contracts, liquidated damages, etc. Fair Value Based on either: Market-observed prices or Models, such as from a Bloomberg terminal Proposed Accounting Fair value with hedge accounting Derivatives would be measured on the balance sheet at fair value Fair value changes would be reported on the “change statement” as investment income Exception: Effective HEDGES! Changes in fair value of derivative would be reported on the balance sheet as deferrals—either deferred charges or deferred credits Swap asset, deferred credit Swap liability, deferred charge Hedge Financial Statement Presentation Statement of net assets Cash Deferred outflow Swap liability Change statement Interest expenditure/expense Year 1 Year 2 $5,000 $5,000 ($6,000) $0 $0 $0 $6,000 Drivers of the Proposed Accounting Derivatives should be measured at fair value If it is an effective hedge, hedge accounting should be applied Effective hedge is found using one acceptable method of evaluating hedges If method subsequently renders hedge ineffective, “may” use another method Up-front payments to a government may represent borrowings Fair Value with Hedge Accounting Pros Fair value recognize the economic reality of the transactions Deferrals recognize the effects of a mixed-attribute model and that fair value gains and losses relate to future periods Reduces volatility in the change statements Cons Suspend normal accounting conventions—change statement does not reflect the economic substance of the transaction Deferrals would not meet the traditional definitions of assets and liabilities Complexity—need to develop qualifying criteria What is a Hedge? Hedging instrument is a derivative Derivative is associated with a hedgeable item The hedge is effective No need to document Management’s intent Facts & circumstances Hedgeable Items Single asset or liability Groups of similar assets or liabilities— same risk exposure Expected transaction—occurrence is probable Intra-entity transactions do not qualify for hedge accounting Is a Hedge Effective? Methods of Evaluating Hedges Consistent critical terms Synthetic instrument Quantitative techniques Linear regression Dollar offset Others? Consistent Critical Terms Method Notional and principal amounts the same Fair value of derivative is zero at date of inception No modifications to net settlements Benchmark rates based on the same index—BMA to BMA Additional terms based on Fair value Cash flow Consistent Critical Terms Method Little or no ineffectiveness is expected Retained—The PV addressed interest rate hedges (based on FAS 133’s shortcut method) Added—hedges that employ options (caps, floors, and collars), forwards, and futures. (Text tentatively based on FAS 133, paragraph 65—Easy Pass) Consistent Critical Terms Method An example: Hedged Principal/notional Term Payments Variable payment Debt $1,000 10 years Every 6 months BMA Hedging Derivative $1,000 10 years Every 6 months BMA Synthetic Instruments Method Based on notion that the combined cash flows of a swap and hedged debt create a third instrument—a synthetic instrument Synthetic fixed-rate bond Synthetic variable-rate bond Comes from Consistent Critical Terms Approach, but used when benchmark rates are not the same—% of LIBOR swap Synthetic Instruments Method Uses the fixed-leg of the swap as the fixed leg. As long as actual payments travel within a range of 90% to 111% of the fixed leg, the hedge would be considered to be effective. Swap-based hedge should use the fixed payment of the swap Commodity hedges would use the fixed rate established by the hedge Quantitative Techniques Methods Dollar offset Regression analysis Dollar Offset Changes of the hedged item are offset by changes of the hedging derivative Change in fair values or cash flows of the hedging derivative divided by the same changes of the hedged item should be within the range of 80 to 125 percent Evaluation may be done on either a periodic or cumulative basis Dollar Offset Example Hedged debt Interest rate swap Fair Value Change $1,000 (1,150) ($1,000/$1,150) 86.96% Regression Evaluation of the hedge should indicate that the hedged item and the hedging derivative regress such that: R-squared statistic must be 0.80 or higher F-statistic 95 percent confidence interval Slope coefficient between –1.25 and –0.80 Disclosures Similar derivatives may be aggregated Summary of derivative activity by: 1) 2) 3) Govt. activities, business-type activities, and fiduciary activities Then fair value hedges, cash flow hedges, and investment derivatives Then type Notional amount Fair values & changes and where reported Fair values & amounts reclassified from hedge to investment Disclosures Disclosures for HEDGING derivatives Application of TB-2003 disclosures Significant terms Risks: Credit, Interest Rate, Basis, Termination, Rollover, Market-access, Foreign Currency No disclosure of hedge ineffectiveness Disclosures for INVESTMENT derivatives Risks: Credit, Interest Rate, Foreign Currency Disclosures Contingencies (e.g., collateral posts) Fair value of derivatives with feature Amount of all potential settlements Amounts posted Hedged debt Synthetic guaranteed investment contracts Description and nature Fair values Wrapper Underlying investments Summary Derivatives would be reported on the balance sheet and measured according to their fair values. Fair value changes would be reported on the change statement, provided a derivative is not a hedging derivative. If a derivative is a hedging derivative, its fair value changes would be deferred on the balance sheet until the hedged transaction occurs. Test hedge effectiveness Disclose Looking Forward Exposure Draft second quarter of 2007 Final standard second quarter of 2008 Proposed Standard would be effective for reporting periods beginning after June 15, 2009 Retroactive Questions? Randal Finden—203.956.5240 rjfinden@gasb.org Web site—www.gasb.org The views expressed in this presentation are those of the GASB’s staff. Official positions of the GASB are determined only after extensive due process and deliberation