Hedge accounting for banks

Contents

What is hedge accounting?


Hedging is the attempt to mitigate the impact of economic risks on an entity's performance. Many businesses will engage in hedging activity to limit economic risk. Hedging activity can be as simple as borrowing in a foreign currency where an entity has a usual revenue stream in that currency. Many economic hedges will not meet the criteria to qualify for the special accounting treatment identified in IFRS as hedge accounting.

 

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Hedge accounting modifies the usual accounting treatment of a hedging instrument and/or a hedged item, so as to recognise their offsetting changes in fair value or cash flows in profit or loss at the same time. Hedge accounting requires that a hedging instrument, normally a derivative, is designated as an offset to changes in the fair value or cash flows of a hedged item. Non-derivative financial instruments may be used as hedging instruments in certain limited circumstances . A hedged item can be an asset, liability, firm commitment, highly probable forecast transaction, or net investment in a foreign operation that exposes the entity to the risk of changes in fair value or future cash flows and is designated as being hedged [IAS39R.9]. A hedged item can be a single item or a group of items with similar risk characteristics.

The normal rules for financial instruments call for all derivatives to be carried at fair value with gains and losses in the income statement . Conversely, under normal accounting requirements, many hedged items are measured at amortised cost or at fair value with gains and losses recognised in equity, or (in the case of a hedged forecast transaction) are not recognised at all. This creates a mismatch in the timing of gain and loss recognition. Hedge accounting seeks to correct this mismatch by changing the timing of recognition of gains and losses on either the hedged items or the hedging instrument. This avoids the significant volatility that might arise if the gains and losses were recognised in the income statement under normal accounting rules.



Criteria to achieve hedge accounting


Hedge accounting is an exception to the usual rules for financial instruments. Therefore there are strict criteria that must be met before it can be used. Management must identify, document and test the effectiveness of those transactions for which it wishes to use hedge accounting. The specific requirements are [IAS39R.88]:

a) The hedged item and the hedging instrument are specifically identified;
b) The hedging relationship is formally documented;
c) The documentation of the hedged relationship must identify the hedged risk and how the effectiveness of the hedge will be assessed;
d) At the inception of the hedge, the hedge must be expected to be highly effective;
e) The effectiveness of the hedge must be tested regularly throughout its life. Effectiveness must fall within a range of 80 to 125% over the life of the hedge. This leaves some scope for short-term ineffectiveness, provided that overall effectiveness falls within this range;
f) One to one designation is normally required between a single external asset, liability or forecast transaction and a single external derivative instrument; and
g) In the case of a hedge of a forecast transaction, the forecast transaction must be 'highly probable'

The criteria to achieve hedge accounting are onerous and will have systems implications for all entities. Hedge accounting is optional and management should always consider the costs and benefits when deciding whether to use it .



Hedged items


Hedge accounting can be applied to qualifying hedged items. A hedged item must create an exposure to risk that could affect the income statement, currently or in future periods. The usual types of risks that are hedged include foreign currency risk, interest-rate risk, equity-price risk, commodity price risk and credit risk. Portfolio hedging, that is, hedging the open position arising from a number of similar hedged items, is difficult to achieve [IAS39R.76] [IAS39R.83] . Designating a net open position as a hedged item is not permitted [IAS39R.84] [IAS39R.IG.F.2.21].

Any financial asset or liability that creates exposure to risk can be a hedged item with two specific exclusions. First, held-to-maturity investments cannot be hedged items for interest-rate risk [IAS39R.79]. Second, investments in subsidiaries or associates that are consolidated or measured using the equity method cannot be a hedged item in a fair value hedge [IAS39R.AG99]. However, the net investment in a foreign entity can be hedged. Additionally, if the hedged item is a financial asset or financial liability, it may be a hedged item with respect to the risks associated with only a portion of its cash flows or fair value (such as one or more selected contractual cash flows or portions of them or a percentage of the fair value) provided that effectiveness can be measured. [IAS 39R.81].

Some examples of common hedged items are:

a) foreign currency monetary item (risk of changes in foreign exchange rate);
b) fixed interest debt security classified as available for sale (risk of changes in interest rates or credit risk);
c) highly probable forecast sale or purchase in a foreign currency; and
 
d) originated loans (risk of changes in interest rates).

An exposure to general business risks cannot be hedged, including risk of obsolescence of plant or risk of unseasonable weather, because these risks cannot be reliably measured. For similar reasons, a commitment to acquire another entity in a business combination cannot be a hedged item, other than for foreign exchange risk [IAS39R.AG98].

Large groups use treasury centres to manage and hedge risks on a group-wide basis. Economically, the treasury centre may seek to hedge the net principal amount of all assets, liabilities and derivative instruments denominated in a particular currency. This might provide a reasonable economic hedge of the group's exposure to that currency. But the net position may not be designated as the hedged item under IFRS. There are ways to achieve hedge accounting, but they may require major systems changes [IAS39R.84] [IAS39R.AG101] [IAS39R.AG111] [IAS39R.IG.F.6.1] [IAS39R.IG.F.6.2] .



Hedging instruments


Only an external derivative instrument can be used as a hedging instrument in most cases [IAS39R.73]. An external non-derivative financial instrument can be used as a hedging instrument only for foreign currency risk [IAS39R.72]. A foreign currency borrowing, for example, could be designated as a hedge of the currency risk of a net investment in a foreign entity.

Multinational groups with complex treasury operations will often use intra-group derivatives to manage currency and interest-rate risk across the group. Intra-group derivatives are not external derivative instruments, do not qualify as hedging instruments and are eliminated on consolidation [IAS39R.73].

A group treasury centre might net all of the foreign currency positions and enter into a single external derivative transaction. This would qualify for hedge accounting provided all the other criteria in the standard are met [IAS39R.IG.F.1.6] .

Similarly, the net of internal positions relating to interest-rate risk cannot be designated as the hedged item [IAS39R.F.1.5]. If a net position is hedged with a single external derivative instrument the external derivative may be designated as hedging a part of the underlying gross position, similar in amount and timing to the net position [IAS39R.AG101] .

A single derivative with several elements, such as a cross-currency interest-rate swap, can be designated as a hedge of more than one type of risk (for example interest rate and foreign currency risk) provided the separate risks are clearly identifiable and effectiveness can be measured [IAS39R.76] [IAS39R.IG.F.2.18] .

Generally a hedging instrument is designated in its entirety in a hedge relationship. The only exceptions permitted are separating the intrinsic value and time value of an option; and separating the interest element and the spot price of a forward contract [IAS39R.74] .



Hedge accounting models


There are three types of hedge accounting recognised by IFRS, fair value hedges, cash flow hedges and hedges of the net investment in a foreign operation [IAS39R.86]. Each has specific requirements on accounting for the fair value changes.

Fair value hedges
The risk being hedged in a fair value hedge is a change in the fair value of an asset or liability or unrecognised firm commitment that will affect the income statement [IAS39R.86(a)]. Changes in fair value might arise through changes in interest rates (for fixed-rate loans), foreign exchange rates, equity prices or commodity prices . The impact on the income statement can be immediate or expected to happen in future periods. A foreign currency borrowing that is translated at the closing rate would have immediate impact on the income statement. An available-for-sale equity security, where gains and losses are deferred in equity, would affect the income statement when sold or impaired.

The hedged asset or liability is adjusted for fair value changes attributable to the risk being hedged, and those fair value changes are recognised in the income statement [IAS39R.89(b)] . The hedging instrument is measured at fair value with changes in fair value also recognised in the income statement [IAS39R.89(a)] . Examples of fair value hedges might be equity securities classified as available-for-sale denominated in a foreign currency that are hedged with foreign currency forward contracts ; a fixed-rate loan that is 'converted' to floating rates with an interest-rate swap ; and a foreign currency receivable hedged using a foreign currency option .

Fair value hedge accounting for a portfolio hedge of interest rate risk
For banks, there is another type of fair value hedge accounting that may be applied for a portfolio hedge of interest rate risk. The requirements of IAS 39R are met if the following procedures are complied with:

(a) As part of its risk management process the bank identifies a portfolio of items whose interest rate risk it wishes to hedge. The portfolio may comprise only assets, only liabilities or both assets and liabilities.
(b) The bank analyses the portfolio into repricing time periods based on expected, rather than contractual, repricing dates. The analysis into repricing time periods may be performed in various ways including scheduling cash flows into the periods in which they are expected to occur, or scheduling notional principal amounts into all periods until repricing is expected to occur.
(c) On the basis of this analysis, the bank decides the amount it wishes to hedge. The bank designates as the hedged item an amount of assets or liabilities (but not a net amount) from the identified portfolio equal to the amount it wishes to designate as being hedged.
(d) The bank designates the interest rate risk it is hedging. This risk could be a portion of the interest rate risk in each of the items in the hedged position, such as a benchmark interest rate (e.g. LIBOR).
(e) The bank designates one or more hedging instruments for each repricing time period.
(f) Using the designations made in (c)-(e) above, the bank assesses at inception and in subsequent periods, whether the hedge is expected to be highly effective during the period for which the hedge is designated.
(g) Periodically, the bank measures the change in the fair value of the hedged item (as designated in (c)) that is attributable to the hedged risk (as designated in (d)), on the basis of the expected repricing dates determined in (b). Provided that the hedge is determined actually to have been highly effective when assessed using the bank's documented method of assessing effectiveness, the bank recognises the change in fair value of the hedged item as a gain or loss in profit or loss and in one of two line items in the balance sheet as described in paragraph 89A of IAS 39R. The change in fair value need not be allocated to individual assets or liabilities.
(h) The bank measures the change in fair value of the hedging instrument(s) (as designated in (e)) and recognises it as a gain or loss in profit or loss. The fair value of the hedging instrument(s) is recognised as an asset or liability in the balance sheet.
(i) Any ineffectiveness will be recognised in profit or loss as the difference between the change in fair value referred to in (g) and that referred to in (h)

Cash flow hedges
The risk being hedged is the potential volatility in future cash flows that will affect the income statement. Future cash flows might relate to existing assets and liabilities such as future interest payments or receipts on floating rate debt. Future cash flows can also relate to future transactions such as forecast sales or purchases in a foreign currency [IAS39R.86] or the foreign currency exposure in an unrecognised firm commitment [IAS39R.87]. Potential volatility in future cash flows might also result from changes in interest rates, changes in exchange rates or changes in commodity prices. Many fair value hedges can also be designated as cash flow hedges, but to qualify they must include an exposure to variability in cash flows as a result of the item being hedged .

Changes in the fair value of the hedging instrument, to the extent the hedge is effective, are deferred in a 'hedging reserve' in equity [IAS39R.95(a)] and recycled to the income statement when the hedged transaction affects the income statement [IAS39R.100]. Fair value changes from cash flow hedges that relate to highly probable forecast transactions and result in the recognition of non-financial assets or liabilities may be included in the initial measurement of those assets or liabilities if the entity chooses this option as its accounting policy [IAS39R.97-98].

Examples of common cash flow hedges are an interest-rate swap converting a floating-rate loan to fixed-rate and a forward foreign exchange contract hedging forecast future revenue or a forecast future purchase of equipment .

Hedge of net investment in a foreign operation
An entity may have subsidiaries that meet the tests and qualify for treatment as foreign operations of the parent. Exchange differences arising on consolidation are deferred in equity until the subsidiary is disposed of [IAS21R.32]. On disposal or liquidation they are recognised in the income statement as part of the gain or loss on disposal [IAS21R.48-49] . The net investment in a subsidiary including any related goodwill can be hedged with a foreign currency borrowing or a derivative . The fair value changes of the hedging instrument, if effective, are deferred in equity until the subsidiary is disposed of, when they become part of the gain or loss on disposal [IAS39R.102] .

The hedging instrument for a net investment hedge, in order to be effective, will almost always be denominated in the foreign operation's local currency .



Hedge effectiveness


A hedge is regarded as highly effective only if both of the following conditions are met:

(a) At the inception of the hedge and in subsequent periods, the hedge is expected to be highly effective in achieving offsetting changes in fair value or cash flows attributable to the hedged risk during the period for which the hedge is designated and
(b) The actual results of the hedge are within a range of 80-125 per cent [IAS39R.AG105].

When a hedge fails the effectiveness test, hedge accounting is discontinued prospectively [IAS39R.91] [IAS39R.101].

Hedges are seldom, if ever, perfectly effective. Any hedge ineffectiveness, even if the hedge continues to be considered effective overall, must be recognised in income in the current period. Hedge ineffectiveness can arise for a number of reasons. For example, the hedged item and the hedging instrument may:

a) Be in different currencies;
b) Have different maturities;
c) Use different underlying interest or equity indices;
d) Use commodity prices in different markets; or
e) Be subject to different counter-party risks.

Careful definition of the hedged risk and the components of the hedging instrument are the best ways to improve hedge effectiveness .



Discontinuing hedge accounting


Hedge accounting shall cease prospectively when any of the following occurs [IAS39R.91] [IAS39R.101]:

a) A hedge fails the effectiveness tests;
b) The hedged item is settled;
c) The hedging instrument is sold, terminated or exercised;
d) Management decides to revoke the designation; or
e) For a cash flow hedge, the forecast transaction is no longer highly probable.

Hedge accounting ceases prospectively from the beginning of the period in which the hedge fails the effectiveness test. All further fair value changes in a derivative hedging instrument are recognised in the income statement. Future changes in the fair value of the hedged item, and any non-derivative hedging instruments, are accounted for as they would be without hedge accounting .

Gains or losses arising in the effective period of a cash flow hedge will have been recognised in equity. These gains remain in equity until the related cash flows occur. Where a forecast transaction is no longer highly probable but still expected to take place, previous gains continue to be deferred. However, once a forecast transaction is no longer expected to occur, any gain or loss is released immediately to the income statement [IAS39R.101].



Presentation and disclosure


The presentation and disclosure requirements for financial instruments, including hedging, are extensive and detailed. Some of the specific and significant disclosures for hedging are [IAS32R.56-59]:

a) a description of the entity's financial risk management policies and objectives, including its policy for hedging each major type of forecast transaction;
b) for each category of hedge (fair value, cash flow and net investment):
- a description of the hedge;
- the hedging instruments used;
- the risks being hedged;
- the fair values of the hedging instruments at the balance sheet date;
- the periods in which forecast transactions are expected to occur and when they are expected to impact on the income statement; and
- a description of any forecast transaction which is no longer expected to occur but for which hedge accounting had previously been used.
c) If gains or losses on hedging instruments have been recognised in equity, the following disclosures are required in the statement of changes in equity:
- the amount that was recognised in equity in the current period;
- the amount removed from equity and recognised in the income statement in the current period; and
- the amount removed from equity and included in the initial carrying amount of assets or liabilities in the current period.




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