Global Banking: Paradigm Shift IAS 39 (Opportunities & Challenges) Sanjeev Agrawal CFO, India & South Asia Standard Chartered Bank Contents IAS 39: Financial Instruments: Recognition & Measurement • Introduction to IAS/IFRS • Herald of a new era • Business Implications • Challenges • Summary IAS/IFRS* : Major force in world accounting What is IAS ? Why IAS ? Who develops IAS ? .. And since when ? Single set of high quality, global accounting standards To increase transparency in financial reporting To enhance comparability of financial information For local banks with global aspirations, exchange listing More effective/consistent quality of compliance & audit Sole responsibility rests with IASB Pronouncement aims to be country neutral Standards issued after Apr’01 designated as IFRS Now Mandatory for “European Union” listed companies * International Accounting Standards Board (IASB) International Financial Reporting Standards (IFRS) 2 Understanding IAS 39 - Herald of a new era Financial Instruments: Recognition & Measurement Objective: Set accounting principles for recognition, measurement of financial assets/liabilities, rules (i.e. instruments/policies) for hedge accounting • • • • First introduced in 2000 since undergone decisive changes Latest promulgation of IASB. Also most deliberated, due to implications Effective from Jan 1, 2005 Intention to bring international GAAP similar to US GAAP New concepts having far reaching implications on financial reporting • Broadly divided into following categories: Classification of assets/ liabilities De-recognition, securitization, factoring, etc Measurement principles, i.e. cost or fair value rule Derivative and hedge accounting Income recognition, effective interest, impairment 3 Understanding IAS 39 – through the maze.. Financial Instruments: Recognition & Measurement On Balance Sheet Items: Off Balance sheet Items: Derivatives (FX, FW, SWAP, OP) Loans & receivables Consolidated Statement Debt / Equity instruments Commodity futures SCOPE & COVERAGE Cash & equivalents Financial Guarantee Debt / loan payables Loan commitment Exclusions (covered by other standards): Inventory Fixed Assets Disclosure Acctg. for own debt / equity 4 (..cont’d) Understanding IAS 39 Financial Instruments: Recognition & Measurement An attempt to move international GAAP to relevant US GAAP New classification categories: Category Balance Sheet valuation basis Changes in carrying amount Illustratives Held for trading Initially designated at fair value Fair Value Income Statement Debt/equity/receivables acquired for profit Loans & receivables Amortised cost Income Statement Fixed determinable payments. Unquoted Held to maturity investments Amortised cost Income Statement Fixed payments & maturity (debt., redeemable shares) Available for sale Fair Value Equity reserves Residual category (Trading) Financial liabilities Fair Value - - Other Financial liabilities Amortised cost - - Applicable for accounting periods beginning from Jan 1, 2005 5 Business Implications Financial Instruments: Recognition & Measurement Strategic Classification related Selection of “Fair Value” or “AFS” Income or Equity volatility Choice of “HTM” can throw up “liquidity management” issues Tainting rules. Restricted usage of this category for 2 yrs Products • Higher Impairment loss charge Discounted future receivable Income Recognition • Acquisition Cost (DAC) and Yield Fees (YEF) capitalized using Effective Interest method: New (and logical) way of profitability analysis Re-alignment of product features, fees, interest rate & cost Systems requirements for transaction accounting * Direct Acquisition cost (DAC) Yield Enhancing Fees (YEF) 6 (..cont’d) Business Implications Financial Instruments: Recognition & Measurement Conceptual rules • Derivatives to be stated in balance sheet at fair value Derivatives & Hedge Accounting • Satisfy hedge conditions & classification • Documentation of hedging relationships • Hedge effectiveness testing & documentation (80-125 rule) Criterion & consequences • Transfer of control is not enough Financial asset de-recognition • Risk and rewards need to be transferred Consequences : • On de-recognition, difference taken as “income” • On failed de-recognition, taken as collateralised borrowing * * Securitized portfolio will most likely stay in balance sheet as collateralised borrowing 7 Key changes in IAS 39 IAS 39 vis-à-vis UK GAAP - Differentials A. Income related : SN Existing UK GAAP / Indian Accounting IAS 39 1 Write off product acquisition cost, as incurred Capitalize and amortize over actuarial life 2 Up-front recognition of fees and commission income Capitalize fees/commission and amortize 3 Income recognition at contractual rates Recognition on Effective Interest basis 4 NPA specific provision based on actual cash flow Provision at discounted cash flow 5 Interest Income suspended for NPA’s Interest upto impairment taken to income 8 (.. cont’d) Key changes in IAS 39 IAS 39 vis-à-vis UK GAAP - Differentials B. Classification related : SN Existing UK GAAP / Indian Accounting IAS 39 1 Classification and valuation into – Banking & Trading Books 4 categories of assets and 2 of liabilities 2 Accrual basis of accounting for derivatives / hedges Derivative hedges at “Fair Value” (MTM) 3 Only one classification of hedges Fair Value hedge, Cash flow hedge and Economic hedge 4 Securitized assets could be de-recognized even if risks/rewards retained Assets to be de-recognized ONLY if risks/ rewards are transferred 9 Challenges: Business & Regulatory Financial Instruments: Recognition & Measurement Impact on strategy, policies, shareholder message; P/L volatility Business leadership Impact on products, clients and performance measurement Communicating change without unsettling investors, regulators or rating agencies Maintain control as processes change (e.g. hedging , impairment) Ops/product control Product valuation. Assets not previously revalued, will now do so Hedging effectiveness: difficult to achieve and operationally manage Regulatory capital – possible volatility due to greater use of ‘fair Risk & capital management value’ Impact on Credit risk processes and Basel II 10 (..cont’d) Challenges: Implementation Financial Instruments: Recognition & Measurement Vast scope and coverage Finance/tax Educating users of financial statements, impact of policy changes Changes to HO tax rules + local changes as countries move to IAS Systems capacity/scale of change in multiple locations Technology Procedure and system for new hedge accounting rules Impact on downstream users Information supporting remuneration policies Human Resources For many staff training, knowledge transfer will be essential Possible manual workaround solutions in initial stages 11 In Summary... What does IAS 39 mean to business Financial Operational Change in revenue/cost recognition New reconciliation process Changes to Net Debt charge Improved product programs Variance in customer Assets/Liability System changes Strategic New business opportunities Product strategy Profitability models 12