• quantitative information that will assist users to understand any subsequent
   increase in credit risk, including information about modified financial assets
   for which the loss allowance has reverted from 12-month ECLs to lifetime
   ECLs; [IFRS 7.35F(f), B8B, 35J]
   • the entity’s credit risk exposure and significant credit risk concentrations, including
   the gross carrying amount of financial assets and the exposure to credit risk on loan
   commitments and financial guarantee contracts, by credit risk rating grades or past
   due status. This disclosure is required to be shown separately for:
   • those instruments that are measured using 12-month ECLs;
   • those that are measured using lifetime ECLs;
   • financial assets that are credit-impaired on initial recognition;
   • those that are subsequently credit-impaired;
   • trade receivables, contract assets and lease receivables measured under the
   simplified approach; [IFRS 7.35M, B8H, B8I] and
   • the write-off policy and amounts written off during the period that are still subject
   to enforcement activity (see 14.1.1 above). [IFRS 7.35F(e), 35L].
   Financial instruments: Impairment 3869
   It is critical for entities to align their credit risk management and financial reporting systems
   and processes, not only to estimate the loss allowance for ECLs, but also to produce a
   sufficient level of detailed information to meet the disclosure requirements in IFRS 7.
   In addition, the EDTF has developed common ECL disclosure practices (see Chapter 50
   at 9.2).
   16
   EFFECTIVE DATE AND TRANSITION
   This section covers the effective date and transition issues specific to impairment. For
   other transition provisions related to IFRS 9, please refer to Chapter 44 at 10.2,
   Chapter 46 at 5.2 and Chapter 49 at 13.3.
   16.1 Effective
   date
   IFRS 9 is effective for annual periods beginning on or after 1 January 2018.
   Previously, the IASB moved the mandatory effective date of IFRS 9 from annual periods
   beginning on or after 1 January 2013 to 1 January 2015. Its later decision to defer the
   mandatory effective date to annual periods beginning on or after 1 January 2018, was
   intended to allow sufficient time for entities to develop systems and processes and to
   gather historical data in order to make the calculations.
   16.2 Transition
   IFRS 9 contains a general requirement that it should be applied retrospectively,
   including the impairment requirements. However, the standard does specify a number
   of exceptions and reliefs. [IFRS 9.7.2.1, 7.2.15, 7.2.17]. These are covered below.
   16.2.1
   Restatement of comparatives
   Notwithstanding the general requirement to apply the standard retrospectively, perhaps
   the most important transitional relief is that IFRS 9 does not require restatement of prior
   periods. Indeed, an entity is permitted to restate prior periods only if it is able to do so
   without the use of hindsight. [IFRS 9.7.2.15].
   The IASB noted that as entities were not required to recognise or disclose ECLs for
   accounting purposes in the past, there was a risk that hindsight would be needed to
   recognise and measure the amount of ECLs in prior periods. [IFRS 9.BC7.75(b)]. This applies
   to situations where it is impracticable to calculate the period-specific effect or the
   cumulative effect of the change and hence, it is impossible for entities to objectively
   distinguish the historical information that is relevant for estimating ECLs from the
   information that would not have been available at that earlier date. [IFRS 9.BC7.74,
   IAS 8.50-53].
   It should be stressed that other IFRS transition requirements, such as the requirement that
   the business model should be assessed as at the date of initial application and that the
   application is not retrospective for assets derecognised prior to that date, may mean that
   comparative information may not, in any case, be very meaningful. To the extent financial
   assets were held during any prior periods but were sold before the date of initial application,
   their impairment will be measured under IAS 39 if comparative information is restated.
   3870 Chapter 47
   We are aware that some banks are considering providing pro forma comparative
   impairment information in their annual report in the year of initial application as if
   IFRS 9 were applied to all financial assets throughout the comparative period. Such
   entities will need to make it clear that these do not represent comparative numbers
   according to IFRS 9.
   If an entity is required to provide comparative information for two prior periods (e.g.
   US Foreign Private Issuers as required by the US Securities Exchange Commission), we
   believe that the requirement in paragraph 7.2.15 of IFRS 9 does not represent an all-or-
   nothing option, i.e. if the entity can only restate the latest comparative period without
   the use of hindsight but would need to use hindsight to restate the earlier comparative
   period, this does not preclude a restatement only of the latest comparative period.
   Therefore, the entity could choose to restate the latest comparative period for which
   the financial information does not involve the use of hindsight, while it would not restate
   the earlier comparative period for which the use of hindsight would be involved. Such
   circumstances may arise if the entity has chosen to do a parallel run for impairment only
   a year before the mandatory application date of IFRS 9, in which case they would be
   able to restate the latest comparative period without the use of hindsight but may not
   be able to do so for the earlier period. The same applies to any other information about
   prior periods, such as historical summaries of financial data. This treatment is consistent
   with the requirements in IAS 8 where for retrospective application of a new accounting
   policy, an entity need to only go back to the beginning of the earliest period for which
   retrospective applicable is practicable. [IAS 8.24, 25, 26, IFRS 9.BC7.13].
   When prior periods are not restated, any difference between the previously reported
   carrying amounts and the new carrying amounts of financial instruments at the
   beginning of the annual reporting period that includes the date of initial application must
   be recognised in the opening retained earnings (or other component of equity, as
   appropriate) of the annual reporting period that includes the date of initial application.
   However, if an entity restates prior periods, the restated financial statements must
   reflect all of the requirements in the standard. [IFRS 9.7.2.15]. For impairment purposes,
   the cumulative impairment loss allowance is recognised in the opening retained
   earnings for all credit exposures.
   When interim financial reports are prepared in accordance with IAS 34 – Interim
   Financial Reporting, the requirements in IFRS 9 need not be applied to interim periods
   prior to the date of initial application if it is impracticable (as defined in IAS 8).
   [IFRS 9.7.2.16].
   16.2.2
   Initial credit risk and significant increases in credit risk on transition
   At the date of initial application, in order to determine the loss allowance that would be
   recognised under the IFRS 9 impairment requirements, an enti
ty is required to
   determine whether there has been a significant increase in credit risk since initial
   recognition, by comparing: [IFRS 9.7.2.18, IFRS 1.B8E]
   • the credit risk at the date that a financial instrument was initially recognised (or for
   loan commitments and financial guarantee contracts, at the date that the entity
   became a party to the irrevocable commitment); and
   • the credit risk at the date of initial application of IFRS 9.
   Financial instruments: Impairment 3871
   On transition, the standard allows an entity to approximate the credit risk on initial
   recognition of the financial instrument (or for loan commitments and financial guarantee
   contracts the date that the entity became a party to the irrevocable commitment), by
   considering all reasonable and supportable information that is available without undue
   cost or effort (see 5.9.1 above). [IFRS 9.7.2.18, B7.2.2, IFRS 1.B8E]. An entity may consider
   internal and external information, including information used for collective assessment
   (see 6.5 above) and information about similar products or peer group experience for
   comparable financial instruments. [IFRS 9.B7.2.3, B7.2.4]. When determining whether there
   have been significant increases in credit risk since initial recognition, an entity is not
   required to undertake an exhaustive search for information. [IFRS 9.B7.2.2].
   In addition, when determining whether there has been a significant increase in credit
   risk since initial recognition, an entity may use the low credit risk operational
   simplification (see 6.4.1 above) or the more than 30 days past due rebuttable
   presumption if significant deterioration is assessed solely based on delinquency
   (see 6.4.2 above). [IFRS 9.7.2.19]. The IASB also noted that an entity can assess the change
   in the credit risk of a financial instrument on a portfolio basis if the initial credit risk is
   not determinable for an individual financial instrument (see 6.5 above). [IFRS 9.BC7.81].
   If an entity is unable to determine whether there have been significant increases in
   credit risk since initial recognition without undue cost or effort, then the entity must
   recognise a loss allowance based on lifetime ECLs at each reporting date until the
   financial instrument is derecognised. Only if at subsequent reporting dates, the entity is
   able to determine that the financial instrument has low credit risk at the reporting date,
   then it would recognise a loss allowance based only on 12-month ECLs.
   [IFRS 9.B7.2.2, 7.2.20].
   As with the approximation of EIRs (see 5.7 above), entities will be faced with a challenge
   in interpreting how much flexibility is afforded by the term ‘to approximate’. Also, it is
   unclear to what extent entities would need to search for information that is available
   without undue cost or effort.
   The requirement to recognise lifetime ECLs may encourage entities to look for and use
   information about the initial credit risk and hence, will enhance comparability and the
   quality of the information provided. On the other hand, some entities may be
   discouraged to use such information if they are able to absorb lifetime ECLs on
   transition. While such an approach may result in inconsistency between entities, the
   IASB believes that the transition requirements and reliefs are the best way to balance
   the provision of useful and relevant information with the associated cost of providing it.
   [IFRS 9.BC7.79].
   3872 Chapter 47
   References
   1
   G20
   Declaration on Strengthening the
   17
   IASB Transition Resource Group for
   Financial System, April 2009.
   Impairment of Financial Instruments, Meeting
   2 Report of the Financial Crisis Advisory Group,
   Summary, paras. 56, 11 December 2015.
   July 2009.
   18 Transition Resource Group for Impairment of
   3 IASB Snapshot: Financial Instruments: Expected
   Financial Instruments, Agenda ref 4, Forward-
   Credit Losses Exposure Draft, March 2013.
   looking information, 16 September 2015.
   4 Based on illustration provided by the IASB in its
   19 IASB Agenda paper 5B, Financial Instruments:
   Snapshot: Financial Instruments: Expected Credit
   Impairment, Operational simplifications – 30dpd
   Losses Exposure Draft, p.9, March 2013.
   and low credit risk, 28
   October –
   5
   IASB Website Announcement. IASB to
   1 November 2013.
   establish transition resource group for
   20
   IASB Transition Resource Group for
   impairment of financial instruments, 23 June
   Impairment of Financial Instruments, Meeting
   2014 and Transition Resource Group for
   Summary, paras. 58 and 59,
   Impairment of Financial Instruments – Meeting
   11 December 2015.
   Summary, 22 April 2015.
   21 Basel Committee on Banking Supervision,
   6
   IASB Transition Resource Group for
   Guidance on credit risk and accounting for
   Impairment of Financial Instruments, Meeting
   expected credit losses, para. A55,
   Summary, 22 April 2015.
   December 2015.
   7
   IASB Transition Resource Group for 22 Basel Committee on Banking Supervision,
   Impairment of Financial Instruments, Meeting
   Guidance on credit risk and accounting for
   Summary, 16 September 2015.
   expected credit losses, para. 22,
   8
   IASB Transition Resource Group for
   December 2015.
   Impairment of Financial Instruments, Meeting
   23 Basel Committee on Banking Supervision,
   Summary, 11 December 2015.
   Guidance on credit risk and accounting for
   9
   IASB
   website,
   www.ifrs.org
   expected credit losses, para. 21,
   10 Basel Committee on Banking Supervision,
   December 2015.
   International Convergence of Capital 24 Basel Committee on Banking Supervision,
   Measurement and Capital Standards, June 2006
   Guidance on credit risk and accounting for
   and Basel III:A global regulatory framework
   expected credit losses, para. A47,
   for more resilient banks and banking systems,
   December 2015.
   June 2011.
   25 Basel Committee on Banking Supervision,
   11 Regulation (EU) No 575/2013 of the European
   Guidance on credit risk and accounting for
   Parliament and of the Council of 26 June 2013
   expected credit losses, para. 69,
   on prudential requirements for credit
   December 2015.
   institutions and investment firms and amending
   26 Basel Committee on Banking Supervision,
   Regulation (EU) No 648/2012.
   Guidance on credit risk and accounting for
   12 Transition Resource Group for Impairment of
   expected credit losses, para. 57,
   Financial Instruments, Meeting Summary,
   December 2015.
   para. 42(b), 22 April 2015.
   27 Basel Committee on Banking Supervision,
   13 Transition Resource Group for Impairment of
   Guidance on credit risk and accounting for
   Fi
nancial Instruments, Agenda ref 1, The
   expected credit losses, paras. 46-49,
   maximum period to consider when measuring
   December 2015.
   expected credit losses, 22 April 2015.
   28 Basel Committee on Banking Supervision,
   14
   IASB Transition Resource Group for
   Guidance on credit risk and accounting for
   Impairment of Financial Instruments, Meeting
   expected credit losses, paras. 50, 51 and 58,
   Summary, para. 49, 11 December 2015.
   December 2015.
   15
   IASB Transition Resource Group for 29 Basel Committee on Banking Supervision,
   Impairment of Financial Instruments, Meeting
   Guidance on credit risk and accounting for
   Summary, paras. 50 and 51,
   expected credit losses, paras. 64 and 65,
   11 December 2015.
   December 2015.
   16
   IASB Transition Resource Group for
   Impairment of Financial Instruments, Meeting
   Summary, paras. 53, 11 December 2015.
   Financial instruments: Impairment 3873
   30 Basel Committee on Banking Supervision, 35 Transition Resource Group for Impairment of
   Guidance on credit risk and accounting for
   Financial Instruments, Agenda ref 3, Loan
   expected credit losses, paras. A15-A21,
   Commitments – Scope, 22 April 2015.
   December 2015.
   36 Transition Resource Group for Impairment of
   31 Basel Committee on Banking Supervision,
   Financial Instruments, Agenda ref 6,
   Guidance on credit risk and accounting for
   Measurement of expected credit losses for an
   expected credit losses, paras. A23 to A30,
   issued financial guarantee contract, 22 April 2015.
   December 2015.
   37 Exposure Draft – Financial Instruments:
   32 Basel Committee on Banking Supervision,
   Expected Credit Losses, March 2013, para. 17.
   Guidance on credit risk and accounting for 38 Exposure Draft – Financial Instruments:
   expected credit losses, paras. A44,
   Amortised Cost and Impairment, November
   December 2015.
   2009, para. B23.
   33 Basel Committee on Banking Supervision, 39 Transition Resource Group for Impairment of
   Guidance on credit risk and accounting for
   Financial Instruments,
   Agenda
   ref 9,
   
 
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