International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards
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Company X’s internal credit risk rating, and determines it to be 7 at the reporting date. Bank A considered
the change in credit risk on the loan, including considering the change in the internal credit risk rating, and
determines that there has been a significant increase in credit risk and recognises lifetime ECLs on the
loan of $150,000.
Despite the recent downgrade of the internal credit risk rating, Bank A grants another loan of $50,000 to
Company X in 2018 with a contractual term of 5 years, taking into consideration the higher credit risk at that date.
The fact that Company X’s credit risk (assessed on a counterparty basis) has previously been assessed to have
increased significantly, does not result in lifetime ECLs being recognised on the new loan. This is because
the credit risk on the new loan has not increased significantly since the loan was initially recognised. If Bank
A only assessed credit risk on a counterparty level, without considering whether the conclusion about changes
in credit risk applies to all individual financial instruments provided to the same customer, the objective in
paragraph 5.5.4 of IFRS 9 would not be met.
Most banks manage their credit exposures on a counterparty basis and would be keen
to use their existing risk management processes where they can. This is particularly the
case for those banks who are seeking to use processes such as the use of watch lists to
make the assessment. However, this will be challenging as the standard only allows use
of a counterparty basis when it can be demonstrated that it would make no difference
from making the assessment at an individual instrument level. It may be necessary for
these banks to add procedures to track increase in the risk of default at the instrument
level in order to comply with the standard.
6.4.5
Determining maximum initial credit risk for a portfolio
The IFRS 9 credit risk assessment that determines whether a financial instrument
should attract a lifetime ECL allowance, or only a 12-month ECL allowance, is based on
whether there has been a relative increase in credit risk. One of the challenges identified
by some constituents in responding to the 2013 Exposure Draft is that many credit risk
Financial instruments: Impairment 3807
systems monitor absolute levels of risk, without tracking the history of individual loans
(see 6.1 above). To help address this concern the standard contains an approach that
turns a relative system into an absolute one, by segmenting the portfolio sufficiently by
loan quality at origination.
As indicated by Illustrative Example 6 in the Implementation Guidance of IFRS 9 on
which Example 47.14 below is based, an entity can determine the maximum initial credit
risk accepted for portfolios with similar credit risks on initial recognition.
[IFRS 9 IG Example 6 IE40-IE42]. Thereby, an entity may be able to establish an absolute
threshold for recognising lifetime ECLs.
Example 47.14: Comparison to maximum initial credit risk
Bank A has two portfolios of automobile loans with similar terms and conditions in Region W. Bank A’s
policy on financing decisions for each loan is based on an internal credit rating system that considers a
customer’s credit history, payment behaviour on other products with Bank A and other factors, and assigns
an internal credit risk rating from 1 (lowest credit risk) to 10 (highest credit risk) to each loan on origination.
The risk of a default occurring increases exponentially as the credit risk rating deteriorates so, for example,
the difference between credit risk rating grades 1 and 2 is smaller than the difference between credit risk
rating grades 2 and 3. Loans in Portfolio 1 were only offered to existing customers with a similar internal
credit risk rating and at initial recognition all loans were rated 3 or 4 on the internal rating scale. Bank A
determines that the maximum initial credit risk rating at initial recognition it would accept for Portfolio 1 is
an internal rating of 4. Loans in Portfolio 2 were offered to customers that responded to an advertisement for
automobile loans and the internal credit risk ratings of these customers range between 4 and 7 on the internal
rating scale. Bank A never originates an automobile loan with an internal credit risk rating worse than 7 (i.e.
with an internal rating of 8-10).
For the purposes of assessing whether there have been significant increases in credit risk, Bank A determines
that all loans in Portfolio 1 had a similar initial credit risk. It determines that given the risk of default reflected
in its internal risk rating grades, a change in internal rating from 3 to 4 would not represent a significant
increase in credit risk but that there has been a significant increase in credit risk on any loan in this portfolio
that has an internal rating worse than 5. This means that Bank A does not have to know the initial credit rating
of each loan in the portfolio to assess the change in credit risk since initial recognition. It only has to determine
whether the credit risk is worse than 5 at the reporting date to determine whether lifetime ECLs should be
recognised in accordance with paragraph 5.5.3 of IFRS 9.
However, determining the maximum initial credit risk accepted at initial recognition for Portfolio 2 at an
internal credit risk rating of 7, would not meet the objective of the requirements as stated in paragraph 5.5.4
of IFRS 9. This is because Bank A determines that significant increases in credit risk arise not only when
credit risk increases above the level at which an entity would originate new financial assets (i.e. when the
internal rating is worse than 7). Although Bank A never originates an automobile loan with an internal credit
rating worse than 7, the initial credit risk on loans in Portfolio 2 is not of sufficiently similar credit risk at
initial recognition to apply the approach used for Portfolio 1. This means that Bank A cannot simply compare
the credit risk at the reporting date with the lowest credit quality at initial recognition (for example, by
comparing the internal credit risk rating of loans in Portfolio 2 with an internal credit risk rating of 7) to
determine whether credit risk has increased significantly because the initial credit quality of loans in the
portfolio is too diverse. For example, if a loan initially had a credit risk rating of 4 the credit risk on the loan
may have increased significantly if its internal credit risk rating changes to 6.
At its meeting on 16 September 2015, the ITG (see 1.5 above) discussed how to
identify a significant increase in credit risk for a portfolio of retail loans when
identical pricing and contractual terms are applied to customers across broad credit
quality bands. The question was influenced by the operational simplifications
described above which allows an entity to assess if there has been a significant
increase in credit risk by determining the maximum initial credit risk accepted for
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portfolios with similar credit risks on original recognition, and by reviewing which
exposures now exceed this limit. The ITG discussed an example of a retail loan
portfolio (Portfolio A) comprising customers who had been assigned initial credit
grades between 1 and 5 (based on a 10-grade rating scale where 1 is the highest credit
quality) and had been issued loans with the same contractual terms and pricing. The
qu
estion was whether it would be appropriate to make the determination of
significant increases in credit risk by using a single threshold approach such as that
outlined for Portfolio 1 in Illustrative Example 6 of IFRS 9, on the basis that the
exposures in Portfolio A could be considered to have a similar initial credit risk, or
whether there were other more appropriate approaches such as, for example,
defining a significant increase in credit risk as a specific number of notch increases
in credit grade.
The ITG members observed that:
• When assessing whether there has been a significant increase in credit risk, it
would not be appropriate for the entity to consider only factors such as pricing and
contractual terms. In this regard, while the concept of economic loss was
considered in developing the IFRS 9 model, the standard requires an assessment
of changes in credit risk based on a wide range of factors including internal and
external indicators of credit risk, changes to contractual terms, actual and expected
performance/behaviours and forecasts of future conditions.
• Credit grading systems were not necessarily designed with the requirements of
IFRS 9 in mind, and thus it should not be assumed that they will always be an
appropriate means of identifying significant increases in credit risk. The
appropriateness of using internal credit grading systems as a means of assessing
changes in credit risk since initial recognition depends on whether the credit
grades are reviewed with sufficient frequency, include all reasonable and
supportable information and reflect the risk of default over the expected life of
the financial instrument. As credit grading systems vary, care needs to be taken
when referring to movements in credit grades and how this reflects an
increased risk of default occurring. In addition, the assessment of whether a
change in credit risk grade represents a significant increase in credit risk in
accordance with IFRS 9 depends on the initial credit risk of the financial
instrument being assessed. Because the relationship between credit grades and
changes in the risk of default occurring differs between credit grading systems
(e.g. in some cases the changes in the risk of a default occurring may increase
exponentially between grades whereas in others it may not), this requires
particular consideration.
• Consequently, the impairment model is based on an assessment of changes in
credit risk since initial recognition, rather than the identification of a specific level
of credit risk at the reporting date and a smaller absolute change in the risk of
default occurring will be more significant for an asset that is of high quality on initial
recognition than for one that is of low quality.
• In Illustrative Example 6 in IFRS 9, the assessment of significant increases in
credit risk of Portfolio 1 was made using a form of absolute approach. However,
it was pointed out that this approach was still consistent with the objective of
Financial instruments: Impairment 3809
identifying significant increases in credit risk since initial recognition. In
particular, only loans with an initial credit grade of 3 or 4 were included in
Portfolio 1 and furthermore, the entity had concluded that a movement from
credit grade 3 to 4 did not represent a significant increase in credit risk.
Consequently, using a single threshold of credit grade 5 as a means of
identifying a significant increase in credit risk since initial recognition served
to capture changes in credit risk in a manner that achieved the objective of the
impairment requirements.
• In contrast, in the fact pattern discussed, Portfolio A contained loans with initial
credit grades ranging between 1 and 5. Questions were raised as to whether such a
broad range of credit grades could be considered to represent a similar initial credit
risk and the ITG members noted that in order to conclude that the assessment
could be based on whether loans had a credit rating worse than 5, the entity would
need to have determined that movements between credit grades 1 and 5 did not
represent a significant increase in credit risk.
• Information available at an individual financial instrument level and/or built into a
credit risk grading system may not incorporate forward-looking information as
required by IFRS 9. Consequently, the assessment of significant increases in credit
risk may need to be supplemented by a collective assessment to capture forward-
looking information. However, a collective assessment should not obscure
significant increases in credit risk at an individual financial instrument level. In this
regard, portfolio segmentation is important and entities should ensure that sub-
portfolios are not defined too widely.
6.5 Collective
assessment
Banks may have hundreds of thousands, or even millions, of small exposures to retail
customers and small businesses. Much of the information available to monitor them is
based on whether payments are past due and behavioural information that is mostly
historical rather than forward looking. As a result such exposures tend to be managed
on an aggregated basis, combining past due and behavioural data with historical
statistical experience and sometimes macroeconomic indicators, such as interest rates
and unemployment levels, that tend to correlate with future defaults. Also, even when
exposures are managed on an individual basis, as is the case for most commercial loans,
the information used to manage them may not be sufficiently forward looking to comply
with the standard.
To address these concerns, the standard introduces the idea of making a collective
assessment for financial assets, to determine if there has been a significant increase in
credit risk, if an entity cannot make the assessment adequately on an individual
instrument level. This exercise must consider comprehensive information that
incorporates not only past due data but other relevant credit information, such as
forward-looking macroeconomic information. The objective is to approximate the
result of using comprehensive credit information that incorporates forward-looking
information at an individual instrument level. [IFRS 9.B5.5.4]. Hence, even if a financial
asset is normally managed on an individual basis, it should also be assessed collectively
(i.e. based on macroeconomic indicators), if the entity does not have sufficient
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forward-looking information at the individual level to make the determination. The
way that this might work is not very different from the IAS 39 requirement to assess
an asset collectively for impairment if it has already been assessed individually and
found not to be impaired.
Some kind of collective adjustment or overlay will be needed for many retail lending
portfolios, given that most customer-specific information will not be forward looking.
In contrast, for commercial loans, the lender will typically have access to much more
information and a forward-looking approach may already have been built into loan
grading systems. Nevertheless, we are aware of some banks who consider that they need
to introduce an additional overlay for com
mercial loans so as to be more responsive to
emerging macroeconomic and other risk developments. Other banks using their existing
watch list approaches to supplement their credit grading system when assessing
whether there has been a significant increase in credit risk. This is because watch list
systems can be more reactive to changing circumstances than formal credit gradings.
Any one bank is likely to employ a variety of methods, depending on its products,
systems and data.
It is worth noting that the language on when a collective approach is required is not
entirely consistent within the standard. Paragraph B5.5.1 states that ‘it may be
necessary to perform the assessment’ on a collective basis, which is consistent with
the requirement in paragraph 5.5.11, that ‘an entity cannot rely solely on past due
information if reasonable and supportable forward-looking information is available
without undue cost or effort’. However, paragraph B5.5.4 states that if ‘an entity
does not have reasonable and supportable information that is available without
undue cost or effort to measure lifetime expected credit losses on an individual
instrument basis...lifetime expected credit losses shall be recognised on a collective
basis’ (emphasis added for each quotation). Banking regulators will probably ensure
that this ‘shall be’ wording will be applied, at least for more sophisticated banks
(see 1.6 above and 7.1 below). This raises a second concern: once significant
deterioration has been identified for a portfolio, whether the entire portfolio would
have to be measured using lifetime ECLs. This outcome would result in sudden,
massive increases in provisions as soon as conditions begin to decline.
Consequently the Board, in finalising the standard, set out examples of possible
methods, using which only a segment or portion of the portfolio would be changed
to lifetime ECLs.
Illustrative Example 5 in the Implementation Guidance for the standard illustrates
how an entity may assess whether its individual assessment should be complemented
with a collective one whenever the information at individual level is not sufficiently
comprehensive and up-to-date. The following examples have been adapted from