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

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by International GAAP 2019 (pdf)

An entity takes into account the effect of its credit risk (credit standing) on the fair value

  of the liability in all periods in which the liability is measured at fair value because

  market participants valuing the entity’s obligations as assets would take into account the

  effect of the entity’s credit standing when estimating the prices at which they would

  transact. [IFRS 13.IE31]. Valuation techniques continue to evolve and new concepts are

  developing in relation to considering non-performance risk. Whether an entity should

  incorporate them into an IFRS 13 fair value measurement depends on whether market

  participants would take them into account.

  Incorporating non-performance risk into subsequent fair value measurements of a

  liability is also consistent with the notion that credit risk affects the initial measurement

  of a liability. Since the terms of a liability are determined based on an entity’s credit

  standing at the time of issuance (and since IFRS 13 assumes the liability is transferred to

  another party with the same credit standing at the measurement date), subsequent

  changes in an entity’s credit standing will result in the obligation’s terms being

  favourable or unfavourable relative to current market requirements. The standard gives

  the following example illustrating how the fair value of the same instrument could be

  different depending on the credit risk of the issuer. [IFRS 13.IE32].

  Example 14.17: Non-performance risk

  Assume that Entity X and Entity Y each enter into a contractual obligation to pay cash (CU 500) to Entity Z

  in five years. Entity X has a AA credit rating and can borrow at 6%, and Entity Y has a BBB credit rating and

  can borrow at 12%. Entity X will receive about CU 374 in exchange for its promise (the present value of

  CU 500 in five years at 6%). Entity Y will receive about CU 284 in exchange for its promise (the present

  value of CU 500 in five years at 12%). The fair value of the liability to each entity (i.e. the proceeds)

  incorporates that entity’s credit standing.

  The effect of non-performance risk on the fair value measurement of the liability will

  depend on factors, such as the terms of any related credit enhancement or the nature of

  the liability – that is, whether the liability is an obligation to deliver cash (a financial

  liability) or an obligation to deliver goods or services (a non-financial liability). The

  following example, from the standard, illustrates changes in fair value measurement due

  to changes in non-performance risk. As indicated in this example, changes to an entity’s

  non-performance risk does not require there to be a change in credit rating. Instead,

  such changes are often based on changes in credit spreads. [IFRS 13.IE34].

  1008 Chapter 14

  Example 14.18: Structured note

  On 1 January 20X9 Entity A, an investment bank with a AA credit rating, issues a five-year fixed rate note

  to Entity B. The contractual principal amount to be paid by Entity A at maturity is linked to an equity index.

  No credit enhancements are issued in conjunction with or otherwise related to the contract (i.e. no collateral

  is posted and there is no third-party guarantee). Entity A designated this note as at fair value through profit

  or loss. The fair value of the note (i.e. the obligation of Entity A) during 20X9 is measured using an expected

  present value technique. Changes in fair value are as follows:

  (a) Fair value at 1 January 20X9 – The expected cash flows used in the expected present value technique are

  discounted at the risk-free rate using the government bond curve at 1 January 20X9, plus the current market

  observable AA corporate bond spread to government bonds, if non-performance risk is not already reflected

  in the cash flows, adjusted (either up or down) for Entity A’s specific credit risk (i.e. resulting in a credit-

  adjusted risk-free rate). Therefore, the fair value of Entity A’s obligation at initial recognition takes into

  account non-performance risk, including that entity’s credit risk, which presumably is reflected in the proceeds.

  (b) Fair value at 31 March 20X9 – During March 20X9 the credit spread for AA corporate bonds widens, with

  no changes to the specific credit risk of Entity A. The expected cash flows used in the expected present

  value technique are discounted at the risk-free rate using the government bond curve at 31 March 20X9,

  plus the current market observable AA corporate bond spread to government bonds, if non-performance

  risk is not already reflected in the cash flows, adjusted for Entity A’s specific credit risk (i.e. resulting in a

  credit-adjusted risk-free rate). Entity A’s specific credit risk is unchanged from initial recognition.

  Therefore, the fair value of Entity A’s obligation changes as a result of changes in credit spreads generally.

  Changes in credit spreads reflect current market participant assumptions about changes in non-performance

  risk generally, changes in liquidity risk and the compensation required for assuming those risks.

  (c) Fair value at 30 June 20X9 – As at 30 June 20X9 there have been no changes to the AA corporate bond

  spreads. However, on the basis of structured note issues corroborated with other qualitative information,

  Entity A determines that its own specific creditworthiness has strengthened within the AA credit spread.

  The expected cash flows used in the expected present value technique are discounted at the risk-free rate

  using the government bond yield curve at 30 June 20X9, plus the current market observable AA

  corporate bond spread to government bonds (unchanged from 31 March 20X9), if non-performance risk

  is not already reflected in the cash flows, adjusted for Entity A’s specific credit risk (i.e. resulting in a

  credit-adjusted risk-free rate). Therefore, the fair value of the obligation of Entity A changes as a result

  of the change in its own specific credit risk within the AA corporate bond spread.

  The standard’s assumption that the non-performance risk related to a liability is the

  same before and after its transfer is not intended to reflect reality. In most cases, the

  reporting entity and the market participant transferee will have different credit

  standings. However, this assumption is important when measuring fair value under

  IFRS 13 for the following reasons:

  • if the transaction results in changes to the non-performance risk associated with

  the liability, the market participant taking on the obligation would not enter into

  the transaction without reflecting that change in the price.

  IFRS 13 gives the following examples; a creditor would not generally permit a debtor to

  transfer its obligation to another party of lower credit standing, nor would a transferee

  of higher credit standing be willing to assume the obligation using the same terms

  negotiated by the transferor if those terms reflect the transferor’s lower credit standing;

  • if IFRS 13 did not specify the credit standing of the entity taking on the obligation, there

  could be fundamentally different fair values for a liability depending on an entity’s

  assumptions about the characteristics of the market participant transferee; and

  • those who might hold the entity’s liability as an asset would consider the effect of

  the entity’s credit risk and other risk factors when pricing those assets (see 11.2.1

  above). [IFRS 13.BC94].

  Fair value measurement 1009

  The requiremen
ts of IFRS 13 regarding non-performance risk, when measuring fair

  value for liabilities, are consistent with the fair value measurement guidance in IFRSs

  prior to the issuance of IFRS 13. Specifically, IFRS 9 refers to making adjustments for

  credit risk if market participants would reflect that risk when pricing a financial

  instrument. However, the IASB acknowledged that there was inconsistent application

  of that principle for two reasons. Firstly, IFRS 9 referred to credit risk generally and did

  not specifically refer to the reporting entity’s own credit risk. Secondly, there were

  different interpretations about how an entity’s own credit risk should be reflected in the

  fair value of a liability using the settlement notion, under the previous definition of fair

  value, because it was unlikely that the counterparty would accept a different amount as

  settlement of the obligation if the entity’s credit standing changed. [IFRS 13.BC92, BC93]. As

  such, adoption of IFRS 13 may have resulted in a change for some entities in this regard.

  In developing IFRS 13, there was some debate among constituents about the usefulness

  of including non-performance risk after initial recognition because this might lead to

  counter-intuitive and potentially confusing reporting (i.e. gains for credit deterioration

  and losses for credit improvements). However, in the IASB’s view, this does not affect

  how to measure fair value, but rather whether an IFRS should require fair value

  measurement subsequent to initial recognition, which is outside the scope of IFRS 13.

  The standard is clear that a measurement that does not consider the effect of an entity’s

  non-performance risk is not a fair value measurement. [IFRS 13.BC95]. The adoption of

  IFRS 9 may have resolved some of these concerns. For financial liabilities designated at

  fair value through profit or loss (using the fair value option), IFRS 9 requires fair value

  changes that are the result of changes in an entity’s own credit risk to be presented in

  other comprehensive income, unless doing so would introduce an accounting mismatch.

  If it would introduce an accounting mismatch, the whole fair value change is presented

  in profit or loss (see Chapter 46 for further discussion). [IFRS 9.5.7.7].

  11.3.1

  Liabilities issued with third-party credit enhancements

  As discussed at 11.3 above, IFRS 13 requires entities to measure the fair value of a

  liability issued with an inseparable third-party credit enhancement from the issuer’s

  perspective, i.e. considering the issuer’s credit risk rather than that of the third-party

  providing the credit enhancement. This would apply in situations where a credit

  enhancement (or guarantee) is purchased by an issuer, then combined with a liability

  and issued as a combined security to an investor. IFRS 13’s requirements are based on

  the fact that the third-party credit enhancement does not relieve the issuer of its

  ultimate obligation under the liability. Generally, if the issuer fails to meet its payment

  obligations to the investor, the guarantor has an obligation to make the payments on the

  issuer’s behalf and the issuer has an obligation to the guarantor. By issuing debt

  combined with a credit enhancement, the issuer is able to market its debt more easily

  and can either reduce the interest rate paid to the investor or receive higher proceeds

  when the debt is issued.

  IFRS 13 requires the fair value measurement of a liability to follow the unit of account

  of the liability for financial reporting purposes. The standard anticipates that there may

  be instances where, even though it may be inseparable, the credit enhancement may

  need to be separated (i.e. separately recognised) for financial reporting purposes.

  However, this assumes that: (i) the unit of account is clear in other standards, which may

  1010 Chapter 14

  not be the case; and (ii) that standards, such as IFRS 9, may permit or require separation

  when a credit enhancement is inseparable.

  As discussed in Figure 14.4 below, if the unit of account excludes the credit

  enhancement, the fair value of the liability measured from the issuer’s perspective in

  accordance with IFRS 13, will not equal its fair value as a guaranteed liability held by

  another party as an asset. The fair value of the asset held by the investor considers the

  credit standing of the guarantor. However, under the guarantee, any payments made by

  the guarantor result in a transfer of the issuer’s debt obligation from the investor to the

  guarantor. That is, the amount owed by the issuer does not change; the issuer must now

  pay the guarantor instead of the investor. Therefore, as discussed at 11.2.1 above, if the

  fair value of a third-party guaranteed liability is measured based on the fair value of the

  corresponding asset, it would need to be adjusted. [IFRS 13.BC96-BC98].

  Figure 14.4:

  Liabilities with credit enhancements

  Issuer’s perspective

  Perspective of the entity that holds the

  (i.e. the obligor)

  corresponding asset

  Credit enhancement provided by the issuer (e.g. collateral or master netting agreement)

  Separate unit of

  Dependent on the relevant IFRS

  Dependent on the relevant IFRS

  account?

  (e.g. IFRS 9).

  (e.g. IFRS 9) and the nature of the credit

  Depending on the nature of the credit

  enhancement.

  enhancement, it may be recognised (e.g.

  collateral recognised as an asset in the

  financial statements of the issuer) or

  unrecognised (e.g. a master netting

  agreement).

  Considered in the fair

  Generally, yes. The fair value

  Possibly. If the credit enhancement is not

  value measurement?

  measurement of a liability takes into

  accounted for separately, the fair value of the

  consideration the credit standing of the

  corresponding asset would take into

  issuer. The effect may differ depending on

  consideration the effect of the related the

  the terms of the related credit

  credit enhancement.

  enhancement.

  Credit enhancement provided by a third-party (e.g. financial guarantee)

  Separate unit of

  Dependent on the relevant IFRS

  Dependent on the relevant IFRS

  account?

  (e.g. IFRS 9). Likely to be a separate unit

  (e.g. IFRS 9) and the nature of the credit

  of account and remain unrecognised,

  enhancement.

  unless the issuer fails to meet its

  obligations under the liability.

  Considered in the fair

  Generally, no. If the credit enhancement is

  Possibly. If the credit enhancement is not

  value measurement?

  accounted for separately from the liability,

  accounted for separately, the fair value of the

  the issuer would take into account its own

  corresponding asset would take into

  credit standing and not that of the third

  consideration the effect of the related third-

  party guarantor when measuring the fair

  party credit enhancement.

  value of the liability.

  Fair value measurement 1011

  11.3.1.A
/>   Do the requirements of IFRS 13 regarding third-party credit

  enhancements in a fair value measurement apply to liabilities other than

  debt?

  The requirements of IFRS 13 for liabilities issued with third-party credit enhancements

  apply to all liabilities that are measured or disclosed at fair value on a recurring basis.

  Although the requirements would not affect financial liabilities after their initial

  recognition if they are subsequently measured at amortised cost in accordance with

  IFRS 9, it would apply to the disclosure of the fair value of those liabilities, as required

  by IFRS 7.

  While an issuer’s accounting for guaranteed debt may be the most common application

  of this guidance, the clarification with respect to the unit of account for certain types of

  credit enhancements could affect other liabilities, including derivative instruments

  measured at fair value in accordance with IFRS 9. Many OTC derivative contracts are

  subject to credit support requirements under an International Swaps and Derivatives

  Association18 (ISDA) Master Agreement between the derivative counterparties. The

  application of this guidance to OTC derivatives will depend on the nature of the credit

  support provided. For example, while credit support is typically provided through the

  posting of collateral, in certain industries posting a letter of credit (LOC) for the benefit

  of a derivative counterparty is not uncommon.

  In those instances where a LOC is posted for the benefit of a derivative counterparty,

  we believe the requirement in paragraph 44 of IFRS 13, to consider the issuer’s credit

  risk rather than that of the third party providing the LOC, would generally apply.

  [IFRS 13.44]. If an entity defaults on its derivative contracts, the bank issuing the LOC will

  pay the counterparty and the entity’s obligation merely transfers from the original

  counterparty to the issuing bank. In other words, the entity will have a continuing

  obligation, even in the event it defaults on the derivative. As such, the entity’s non-

  performance risk (not that of the bank providing the LOC) would be considered in

 

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