International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards

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  determining the fair value of the derivative liability. We believe this generally would

  apply even if the LOC were deemed separable from the derivative contract. In our view,

  including the effect of separable credit enhancements while excluding the effect of

  inseparable credit enhancements would contradict the principles of IFRS 13.

  11.3.2

  Does IFRS 13 require an entity to consider the effects of both

  counterparty credit risk and its own credit risk when valuing its

  derivative transactions?

  IFRS 13 addresses the issue of credit risk both explicitly and implicitly. As discussed

  at 11.3 above, in relation to an entity’s own credit risk in the valuation of liabilities, the

  guidance is explicit; the fair value of a liability should reflect the effect of non-

  performance risk, which includes own credit risk.

  The standard’s requirements are less explicit regarding counterparty credit risk. IFRS 13

  requires the fair value of an asset or liability to be measured based on market participant

  assumptions. Because market participants consider counterparty credit risk in pricing a

  derivative contract, an entity’s valuation methodology should incorporate counterparty

  credit risk in its measurement of fair value.

  1012 Chapter 14

  11.3.3

  How should an entity incorporate credit risk into the valuation of its

  derivative contracts?

  As discussed at 11.3.2 above, IFRS 13 requires entities to consider the effects of credit

  risk when determining a fair value measurement, e.g. by calculating a debit valuation

  adjustment (DVA) or a credit valuation adjustment (CVA) on their derivatives.

  As no specific method is prescribed in IFRS 13, various approaches are used in practice

  by derivatives dealers and end-users to estimate the effect of credit risk on the fair value

  of OTC derivatives.

  The degree of sophistication in the credit adjustment valuation method used by a

  reporting entity is influenced by the qualitative factors noted below. Estimation can be

  complex and requires the use of significant judgement which is often influenced by

  various qualitative factors, including:

  • the materiality of the entity’s derivative’s carrying value to its financial statements;

  • the number and type of contracts for derivatives in the entity’s portfolio;

  • the extent to which derivative instruments are either deeply in or out of the money;

  • the existence and terms of credit mitigation arrangements (e.g. collateral

  arrangements in place);

  • the cost and availability of technology to model complex credit exposures;

  • the cost and consistent availability of suitable input data to calculate an accurate

  credit adjustment; and

  • the credit worthiness of the entity and its counterparties.

  While the degree of sophistication and complexity may differ by entity and by the size and

  nature of the derivative portfolio, any inputs used under any methodology should be

  consistent with assumptions market participants would use. The complexity and judgement

  involved in selecting and consistently applying a method may require entities to provide

  additional disclosures to assist users of financial statements (see 20 below). 11.3.3.A to

  11.3.4.B below provide further insights into some of the considerations for determining

  valuation adjustments for credit risk on derivatives measured at fair value, except for which

  a quoted price in an active market is available (i.e. over-the-counter derivatives).

  In situations where an entity has a master netting agreement or credit support annex19

  (CSA) with a counterparty, the entity may consider the credit risk of its derivative

  instruments with that counterparty on a net basis if it qualifies to use the measurement

  exception noted at 2.5.2 above (see 12 below for more detail on applying the

  measurement exception for financial instruments with offsetting credit risks).

  11.3.3.A

  How do credit adjustments work?

  In simple terms, the requirement for a credit adjustment as a component of fair value

  measurement can be analogised to the need for a provision on a trade receivable or an

  impairment charge on an item of property, plant and equipment. Whilst this analogy helps

  conceptualise the requirement, the characteristics of derivatives mean that the calculation

  itself can be significantly more complex than for assets measured at amortised cost.

  Consistent with the fact that credit risk affects the initial measurement of a derivative

  asset or liability, IFRS 13 requires that changes in counterparty credit risk or an entity’s

  Fair value measurement 1013

  own credit standing be considered in subsequent fair value measurements. It cannot be

  assumed that the parties to the derivative contract will perform.

  The terms of the asset or liability were determined based on the counterparty’s or

  entity’s credit standing at the time of entering into the contract. In addition, IFRS 13

  assumes a liability is transferred to another party with the same credit standing at the

  measurement date. As a result, subsequent changes in a counterparty’s or entity’s credit

  standing will result in the derivative’s terms being favourable or unfavourable relative

  to current market conditions.

  Unlike the credit exposure of a ‘vanilla’ receivable, which generally remains constant

  over time (typically at the principal amount of the receivable), the bilateral nature of the

  credit exposure in many derivatives varies, whereby both parties to the contract may

  face potential exposure in the future. As such, many instruments may possibly have a

  value that is either positive (a derivative asset) or negative (a derivative liability) at

  different points in time based on changes in the underlying variables of the contract.

  Figure 14.5 below illustrates the effect on the income statement and on the statement of

  financial position of CVA and DVA adjustments as a component of fair value

  measurement on a single derivative asset or liability.

  Figure 14.5:

  Accounting for CVA and DVA

  Derivative asset

  Derivative liability

  CU

  CU

  example – CVA

  example – DVA

  Derivative

  Risk-free derivative

  100,000

  Risk-free derivative

  (100,000)

  position valued

  asset

  liability

  using the risk-free

  curve (1)

  Credit adjustment

  Counterparty credit

  (10,000)

  Debit adjustment

  5,000

  required (2)

  adjustment

  based on own credit

  Credit-adjusted

  Derivative asset

  90,000

  Derivative liability

  (95,000)

  derivative position

  Subsequent credit movements

  Counterparty

  A gain arises in the income

  Own credit

  A loss arises in the income

  credit improves

  statement and is reflected by a

  improves

  statement and is reflected by a

  larger derivative asset in the

  larger derivative liability in the

  statement of
financial position

  statement of financial position

  Counterparty

  A further CVA charge is

  Own credit

  A further DVA credit is required

  credit deteriorates

  required in the income

  deteriorates

  to the income statement and is

  statement and is reflected by a

  reflected by a reduced derivative

  reduced derivative asset in the

  liability in the statement of

  statement of financial position

  financial position

  Notes:

  (1)

  The

  table

  represents a point-in-time during the life of a derivative asset or liability

  (2)

  For illustrative purposes, we have assumed the counterparty credit valuation adjustment is CU 10,000 and

  the debit valuation adjustment is CU 5,000. These credit adjustments are not intended to reflect reality

  1014 Chapter 14

  11.3.3.B Valuation

  methods

  The determination of a credit adjustment can be complex. Part of the complexity stems

  from the particular nature of credit risk in many OTC derivative contracts. Credit risk

  associated with a derivative contract is similar to other forms of credit risk in that the

  cause of economic loss is an obligor’s default on its contractual obligation. However, for

  many derivative products, two features set credit risk apart from traditional forms of

  credit risk in instruments such as debt:

  • the uncertainty of the future exposure associated with the instrument – this is due

  to the uncertainty of future changes in value of the derivative, as the cash flows

  required under the instrument stem from: (a) movements in underlying variables

  that drive the value of the contract; and (b) the progression of time towards the

  contract’s expiry; and

  • the bilateral nature of credit exposure in many derivatives, whereby both parties

  to the contract may face potential exposure in the future – this can occur in

  instruments, such as swaps and forwards, given the potential for these derivatives

  to ‘flip’ from an asset to a liability (or vice versa), based on changes in the underlying

  variables to the contract (e.g. interest rates or foreign exchange rates).

  As previously noted at 11.3.3 above, IFRS does not prescribe any specific valuation

  methods to quantify the impact of non-performance risk on derivatives’ fair value. IFRS 13

  is a principles-based standard intended to provide a general framework for measuring fair

  value. It was not intended to provide detailed application guidance for calculating the fair

  value of various types of assets and liabilities. Likewise, IFRS 9 does not provide specific

  valuation guidance related to derivatives. As a result, extensive judgement needs to be

  applied, potentially resulting in diversity in the methods and approaches used to quantify

  credit risk, particularly as it pertains to derivatives. As discussed at 11.3.3 above, a variety

  of factors may influence the method an entity chooses for estimating credit adjustments.

  In addition, the cost and availability of technology and input data to model complex credit

  exposures will also be a contributing factor.

  In recent years, some derivative dealers have started to include a funding valuation

  adjustment (FVA) in the valuation of their uncollateralised derivative positions, as is

  illustrated in Extract 14.1 at 20.2 below. FVA is included in order to capture the funding

  cost (or benefit) that results from posting (or receiving) collateral on inter-bank

  transactions that are used to economically hedge the market risk associated with these

  uncollateralised trades. The methods for determining FVA can vary. As such,

  determining whether these methods comply with IFRS 13 requires judgement based on

  the specific facts and circumstances. A number of valuation adjustments have also

  emerged in addition to CVA, DVA and FVA. Examples include self-default potential

  hedging (LVA), collateral (CollVA) and market hedging positions (HVA), as well as tail

  risk (KVA), collectively these are now referred to as X-Value Adjustments (XVA). It is

  important to note that some of these valuation adjustments may be useful for internal

  reporting, but may not be appropriate to use when measuring fair value in accordance

  with IFRS 13. As noted above, the inputs used in measuring fair value must reflect the

  assumptions of market participants transacting for the asset or liability in the principal

  (or most advantageous) market at the measurement date.

  Fair value measurement 1015

  11.3.3.C Data

  challenges

  In addition to the method employed to determine a credit adjustment, the inputs used

  in the various approaches can often require significant judgement. Regardless of the

  method used, probability of default, loss given default (i.e. the amount that one party

  expects not to recover if the other party defaults) or credit spread assumptions are

  important inputs. While the sources of information may vary, the objective remains

  unchanged – that is, to incorporate inputs that reflect the assumptions of market

  participants in the current market.

  Where available, IFRS 13 requires entities to make maximum use of market-observable

  credit information. For example, credit default swap (CDS) spreads may provide a good

  indication of the market’s current perception of a particular reporting entity’s or

  counterparty’s creditworthiness. However, CDS spreads will likely not be available for

  smaller public companies or private entities. In these instances, reporting entities may

  need to consider other available indicators of creditworthiness, such as publicly traded

  debt or loans.

  In the absence of any observable indicator of creditworthiness, a reporting entity may

  be required to combine a number of factors to arrive at an appropriate credit valuation

  adjustment. For example, it may be necessary to determine an appropriate credit spread

  using a combination of own issuance credit spread data, publicly available information

  on competitors’ debt pricing, sector specific CDS spreads or relevant indices, or

  historical company or sector-specific probabilities of default.

  In all cases, identifying the basis for selecting the proxy, benchmark or input,

  including any analysis performed and assumptions made, should be documented.

  Such an analysis may include calculating financial ratios to evaluate the reporting

  entity’s financial position relative to its peer group and their credit spreads. These

  metrics may consider liquidity, leverage and general financial strength, as well as

  comparable attributes such as credit ratings, similarities in business mix and level of

  regulation or geographic footprint.

  The use of historical default rates would seem to be inconsistent with the exit price

  notion in IFRS 13, particularly when credit spread levels in the current environment

  differ significantly from historical averages. Therefore, when current observable

  information is unavailable, management should adjust historical data to arrive at its best

  estimate of the assumptions that market participants would use to price the instrument

  in an orderly transaction in the current market.

  Figure 14.6 below high
lights some of the common sources of credit information and the

  advantages and disadvantages of using each input for the credit adjustment calculation.

  1016 Chapter 14

  Figure 14.6:

  Credit data requirements

  Data requirements

  Advantages

  Disadvantages

  CDS curve (own or

  • Market observable

  • Not available for many entities

  counterparty)

  • Information is current (for

  • May not be representative of all the

  counterparties with adequate CDS

  assets of the entity

  trading volume)

  • May have liquidity issues due to low

  • Easy to source from third party data

  trading volumes, resulting in higher-than-

  providers

  expected spreads and additional volatility

  • Exposure specific data available for

  in calculations

  most banking counterparties

  • CDS quotes may be indicative quotes,

  not necessarily reflective of actual trades

  Current debt credit

  • Market observable

  • May require an adjustment for illiquidity

  spread

  • Available for some publicly traded

  • May require a judgemental adjustment

  debt instruments

  due to maturity mismatch and amount of

  • Easy to source from third party data

  security of debt issuance and derivative

  providers

  to be valued

  Sector-specific CDS

  • Market-observable

  • Not exposure-specific; may require

  Index or competitor

  • Information is current

  judgemental adjustments to reflect

  CDS Curve

  • Easy to source from third party data

  differences between proxy and entity

  providers

  (e.g. size, credit rating, etc.)

  • Proxy CDS curve mapping is possible

  • Index CDS curves can be influenced by

  for almost all entities

 

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