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

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  of ineffectiveness (see 7.4.4.B below).

  6.3.1 Business

  combinations

  In a business combination accounted for using the purchase method of accounting

  where the acquiree has designated hedging relationships, the question arises of whether

  the acquirer should:

  • be permitted to continue to apply the hedge accounting model to hedge

  relationships designated previously by the acquiree, assuming it is consistent with

  the acquirer’s strategies and policies; or

  • be required to re-designate hedge relationships at the acquisition date.8

  IFRS 3 – Business Combinations – provides guidance that in order to obtain hedge

  accounting in their consolidated financial statements, acquirers are required to

  redesignate the acquiree’s hedges. [IFRS 3.15, 16(b)]. Further, the acquirer should not

  recognise in its consolidated financial statements any amounts in equity in respect of

  any cash flow hedges of the acquiree relating to the period prior to acquisition.

  Redesignating the hedge relationships at the acquisition date means that if the hedging

  instrument has a fair value other than zero (see 7.4.4.B below), it is likely that

  ineffectiveness will be introduced in a hedge that may have been nearly 100% effective

  prior to the acquisition, particularly for cash flow hedges. To mitigate this, the

  acquirer may, subsequent to the combination, choose to settle the hedging

  instruments and replace them with more effective ones. Furthermore, the existence

  of this source of ineffectiveness may influence the chosen methodology used to

  demonstrate the existence of an economic relationship in order to qualify for hedge

  accounting in the acquirer’s consolidated financial statements (see 6.4 1 below).

  [IFRS 9.B6.4.15].

  For business combinations under common control, for which IFRS 3 is not applicable,

  see further discussion in Chapter 10 at 3.3.3.

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  6.3.2

  Dynamic hedging strategies

  A dynamic risk management strategy is one where the entity uses a dynamic process in

  which the risk exposure and/or risk management instruments used to manage the

  exposure do not remain the same for long. [IFRS 7.23C].

  IFRS 9 permits, but does not require, separation of the intrinsic and time value of an

  option contract and designation only of the intrinsic value as the hedging instrument

  (see 3.6.4 above). [IFRS 9.6.2.4(a)]. For a dynamic hedging strategy that assesses both the

  intrinsic value and time value of an option contract, it is helpful that there is no

  requirement to exclude the time value of hedging option contracts from the hedge

  relationship. Accordingly, it is possible for a delta-neutral option hedging strategy (i.e. a

  strategy that is designed to create net risk positions (including the full option value) that

  are unlikely to be affected by small movements in the price of the underlying) to achieve

  hedge accounting without excluding the option time value, as long as the other

  qualifying criteria are met (see 6.1 above).

  Similarly, other dynamic hedging strategies under which the quantity of the hedging

  instrument is constantly adjusted in line with the risk management strategy in order to

  maintain a desired hedge ratio (e.g. to achieve a delta-neutral position, insensitive to

  changes in the fair value of the hedged item), may qualify for hedge accounting.

  For a dynamic hedging strategy to qualify for hedge accounting, the documentation

  must specify how the hedge will be monitored and updated and how the effectiveness

  criteria will be assessed. Consideration must also be made as to whether the periodic

  changes made as part of dynamic hedging strategy should be treated as a rebalancing of

  the hedge relationship (see 8.2 below) or a discontinuation and redesignation of the

  hedge relationship (see 8.3 below). Such a determination is not a choice but based on

  facts and circumstances; for example, treatment as rebalancing is only permitted where

  changes to the hedge ratio are made (i.e. the quantity of hedged item compared to the

  quantity of hedging instrument). In contrast, the introduction of new types of hedging

  instruments would most likely be treated as a discontinuation and redesignation.

  The guidance on rebalancing is applicable when the quantity of the hedging instrument

  is constantly adjusted in order to maintain a desired hedge ratio for the existing hedged

  item(s), often referred to as a closed portfolio (see 8.2 below). Accounting for dynamic

  risk management of the associated risk in an open portfolios, to which new exposures

  are frequently added, existing exposures mature, where frequent changes also occur to

  the hedged item(s) is the subject of a live project for the IASB (see 11.1 below).

  6.3.3 Forecast

  transactions

  In the case of a hedge of a forecast transaction, the documentation should identify the

  date on, or time period in which, the forecast transaction is expected to occur. This is

  because, in order to qualify for hedge accounting:

  • the hedge must relate to a specific identified and designated risk;

  • it must be possible to measure its effectiveness reliably; and

  • the hedged forecast transaction must be highly probable (see 2.6.1 above).

  To meet these criteria, entities are not required to predict and document the exact date

  a forecast transaction is expected to occur. However, the time period in which the

  Financial instruments: Hedge accounting 4061

  forecast transaction is expected to occur should be identified and documented within a

  reasonably specific and generally narrow range of time from a most probable date, as a

  basis for measuring hedge ineffectiveness. Consideration of the effectiveness criteria

  would need to reflect differences in timing of the hedged and hedging cash flows in a

  manner consistent with the designated hedged risk (see 6.4.1 and 7.4.4.A below).

  If a forecast transaction such as a commodity sale is properly designated in a cash flow

  hedge relationship and, subsequently, its expected timing changes to an earlier (or later)

  period, this does not affect the validity of the original designation. If the entity can

  conclude that this transaction is the same as the one designated as being hedged, then

  hedge accounting may be able to continue. However, ineffectiveness may arise due to the

  change in timing, as the calculation would be based on the up to date expectation of the

  timing of the hedged forecast transaction. For example, if the forecast transaction was

  now expected earlier than originally thought, the hedging instrument will be designated

  for the remaining period of its existence, which will exceed the period to the forecast sale.

  Further, hedged forecast transactions must be identified and documented with

  sufficient specificity so that when the transaction occurs, it is clear whether the

  transaction is, or is not, the hedged transaction. Therefore, a forecast transaction may

  be identified as the sale of the first 15,000 units of a specific product during a specified

  three-month period (see 2.3.1 above), but it could not be identified as the last

  15,000 units of that product sold because they cannot be identified when they occur.

  For the same reason, a forecast transaction cannot be specified solely as a percentage
/>   of sales or purchases during a period.

  6.4

  Assessing the hedge effectiveness requirements

  A hedging relationship can only qualify for hedge accounting if all the hedge

  effectiveness requirement are met, assuming the other qualifying criteria are also met

  (see 6.1 above).

  The hedge effectiveness requirements are as follows:

  • there is ‘an economic relationship’ between the hedged item and the hedging

  instrument (see 6.4.1 below);

  • the effect of credit risk does not ‘dominate the value changes’ that result from that

  economic relationship (see 6.4.2 below); and

  • ‘the hedge ratio of the hedging relationship is the same as that resulting from the

  quantity of the hedged item that the entity actually hedges and the quantity of the

  hedging instrument that the entity actually uses to hedge that quantity of the

  hedged item. However, that designation shall not reflect an imbalance between the

  weightings of the hedged item and the hedging instrument that would create hedge

  ineffectiveness (irrespective of whether recognised or not) that could result in an

  accounting outcome that would be inconsistent with the purpose of hedge

  accounting’. The second part of this requirement is an anti-abuse clause that is

  explained in more detail in at 6.4.3 below. [IFRS 9.6.4.1].

  An entity shall assess at the inception of the hedging relationship, and on an ongoing basis

  whether the hedge effectiveness requirements are met. The standard does not specify a

  particular method for assessing whether the effectiveness requirements are met, however

  4062 Chapter 49

  the methods selected must be documented within the hedge documentation (see 6.3

  above). [IFRS 9.B6.4.12, B6.4.13, B6.4.19].

  6.4.1 Economic

  relationship

  The first effectiveness requirement means that the hedging instrument and the hedged item

  must generally be expected to move in opposite directions as a result of a change in the

  hedged risk. This is within the context of how the hedged item and hedging instrument have

  been designated as described at 2 and 3 above. [IFRS 9.B6.4.1]. The guidance does not require

  that the value changes of the hedging instrument and the hedged item are expected to move

  in the opposite direction for the hedged risk in all circumstances, but that generally there is

  an expectation that they will systematically move in opposite directions. It is clear therefore,

  that there can be instances where the value changes in the hedged item and hedging

  instrument are expected to move in the same direction. The standard discusses an example

  where the price of the hedged instrument is based on the West Texas Intermediate (WTI)

  price of oil whereas the price of the hedged item is based on the Brent crude oil price. The

  values of the hedging instrument and the hedged item can both move in the same direction

  if, for example, there is only a minor change in the relative underlyings of each of the hedged

  item and hedging instrument (i.e. the WTI and Brent oil prices) but there is a change in the

  price differential between the two. However no guidance is provided as to how frequently

  this would have to happen so as to lead us to reject the expectation that they would

  ‘generally’ move in opposite directions. One possibility might be to use correlation analysis

  to demonstrate that there is, over time, a reliable and systematic price relationship. We

  expect practice to evolve in this area. [IFRS 9.B6.4.4, B6.4.5, BC6.238].

  The assessment of whether there is an economic relationship should be based on an

  economic rationale rather than it just arising by chance, as could be the case if the

  relationship is based only on a statistical correlation. That is, causality cannot be

  assumed purely from correlation or, to quote the IASB, ‘the mere existence of a

  statistical correlation between two variables does not, by itself, support a valid

  conclusion that an economic relationship exists’. [IFRS 9.B6.4.6].

  Conversely, a statistical correlation may provide corroboration of an economic

  rationale. For example, if it can be seen that value drivers exist such that there is an

  expectation that the value of the hedged item and hedging instrument would generally

  move in opposite directions, but that significant sources of ineffectiveness exist within

  a relationship that may counteract the offset, then quantitative analysis may assist in

  determining whether an economic relationship exists or not. For example, in the case

  of a fair value hedge of an inflation risk component in a fixed rate bond (assuming it is

  determined that an eligible risk component exists (see 2.2.6 above)), quantitative

  analysis may provide additional evidence as to whether an economic relationship exists

  or not. In summary, a quantitative assessment alone is not enough to establish an

  economic relationship, but it may be useful in a small number of cases to support a

  qualitative analysis that an economic relationship exists.

  The requirement of an economic relationship will automatically be fulfilled for many hedging

  relationships, as the underlying of the hedging instrument often matches, or is closely aligned

  with, the hedged risk. [IFRS 9.B6.4.14]. Even though it is not sufficient to focus solely on changes

  in value due to the hedged risk, where there are differences between the hedged item and

  Financial instruments: Hedge accounting 4063

  the hedging instrument such that there are other value drivers, the economic relationship will

  often still be capable of being demonstrated using a qualitative assessment. A qualitative

  assessment may also be used to determine that an economic relationship does not exist. For

  example, a hedge of one-sided risk in forecast purchases is designated as being hedged by an

  out-of-the-money call option. If the main driver of value change in the option is expected to

  be the time value of the option, (perhaps as the option is expected to remain out of the

  money) then it can easily be seen the hedged item and hedging instrument are generally not

  expected to move in opposite directions with respect to the hedged risk. Of course, if the

  time value of the option was excluded from the hedge relationship (see 3.6.4 above), then it

  will be easier to demonstrate that there is an economic relationship.

  When the critical terms of the hedging instrument and hedged item are not closely aligned,

  and there is increased uncertainty about the extent of offset, such that hedge effectiveness

  is more difficult to predict, as noted above, IFRS 9 suggests that ‘it might only be possible

  for an entity to conclude [that there is an economic relationship] on the basis of a

  quantitative assessment.’ [IFRS 9.B6.4.16, BC6.269]. The standard does not provide any further

  guidance on when a quantitative assessment might be required or how it would be made.

  However, it would seem to be most relevant when the hedged item and the hedging

  instrument are each based on prices derived from different markets, as in the example of

  WTI and Brent crude oil, cited earlier, where there is a reasonable chance that the value

  changes of the hedging instrument and the hedged item will frequently move in the same

  direction. This is an area where practice will develop, but we expect the need for a

  quantitative assessment over
and above what is already undertaken for risk management

  purposes, to be relatively infrequent. [IFRS 9.B6.4.18].

  The standard also mentions hedging relationships where a derivative with a non-zero fair

  value is designated as the hedging instrument, as an example of a situation where a

  quantitative assessment might be required to establish an economic relationship. It depends

  on the particular circumstances as to whether hedge effectiveness arising from the non-zero

  fair value could potentially have a magnitude that a qualitative assessment would not

  adequately capture. [IFRS 9.B6.4.15]. However, as noted above, the standard does not provide

  guidance on how large the non-zero fair value would have to be for a quantitative

  assessment to be required, or for an economic relationship to be considered not to exist.

  The assessment of the economic relationship, whether qualitative or quantitative,

  would need to consider, amongst other possible sources of mismatch between the

  designated hedged item and the hedging instrument, the following:

  • maturity;

  • volume or nominal amount;

  • cash flow dates;

  • interest rate basis, or quality and location basis differences;

  • day count methods;

  • features that arise only in either the designated hedged item or hedging instrument;

  • differences in valuation methods and inputs such as discount rates or credit risk; and

  • the extent that the hedging instrument is already ‘in the money’, or ‘out of the

  money’ when designated.

  4064 Chapter 49

  The assessment should also include an analysis of the possible behaviour of the hedging

  relationship during its term to ascertain whether it can be expected to meet the risk

  management objective. [IFRS 9.B6.4.6]. The assessment must be forward looking at all

  times, without solely relying on actual retrospective offset. This does not mean that

  retrospective offset is never relevant, but it should only be relied upon if there is a

  reasonable expectation that it is representative of the future.

  IFRS 9 does not specify a method for assessing whether an economic relationship exists.

  An entity should use a method capturing all the relevant characteristics of the hedging

 

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