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JANUARY 2019 IFRS 9 INSIGHTS BDO UK FINANCIAL SERVICES

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Page 1: BDO UK FINANCIAL SERVICES IFRS 9 INSIGHTS

JANUARY 2019

IFRS 9 INSIGHTSBDO UK FINANCIAL SERVICES

Page 2: BDO UK FINANCIAL SERVICES IFRS 9 INSIGHTS

2 BDO UK FINANCIAL SERVICES | IFRS 9 INSIGHTS

CHALLENGES FACED BY BANKS CLASSIFICATION AND MEASUREMENT

INTRODUCTION

Banks and building societies pursue different business models for their financial assets, which has sometimes required reclassification from one measurement basis to another. The main reclassification upon transition noted on the 15 financial institutions selected was from amortisedcost to FVTPL1.

The reclassifications from IAS 39 to IFRS 9 that were noted are as follows:

Amortised cost

Amortised cost

FVTOCI

FVTPL

FVTPL

IAS39

FVTPL

FVTOCI2

FVTPL

Amortised Cost

FVTOCI

IFRS 9

% of ECL transitional adjustments in relation to IAS 39 impairment balance

ECL MEASUREMENT

IFRS 9 Financial Instruments (“IFRS 9”) has been developed by the International Accounting Standards Board (“IASB”) to replace IAS 39 Financial Instruments: Recognition and Measurement (“IAS 39”).

The IASB completed IFRS 9 in July 2014, by issuing a final standard which incorporates the requirements of all three phases of the financial instruments projects, being Classification and Measurement, Impairment and Hedge Accounting.

We have conducted a study on the transition reports and interim financial statements of 15 top banks, mid-tier banks and building societies. The main areas of our study have been focused on the transitional impacts over Classification and Measurement, expected credit loss (“ECL”) estimation, stage allocation, critical accounting judgements and estimation uncertainty and associated disclosures.

32.8%

Average

76.3%

34.5%

16.1%

16.7%

-9.6%3

59.8%

156.9%

60.7%

Top banks

Challenger banks

Building societies

Governance changes

IFRS 9implementation

Developing policies

Business model assessments

Designing, building and implementing ECL model

Continuous reassessment of judgements and estimates

Disclosures

Internal system and processes changes

People, training and resources

1 – Fair Value Through Profit or Loss

2 – Fair Value Through Other Comprehensive Income

3 – This transitional adjustment represents a release of impairment provision on transition from IAS 39 to IFRS 9 for a building society.

A range of % of ECL transitional adjustments over opening Impairment balances per category of bank has been provided below.

Low Range High Range

Page 3: BDO UK FINANCIAL SERVICES IFRS 9 INSIGHTS

3BDO UK FINANCIAL SERVICES| IFRS 9 INSIGHTS

TRANSITION DISCLOSURES

The banks selected have used different judgements, assumptions and estimates when developing their models.

Examples of judgements, assumptions and estimates included:

Significant Increase in Credit Risk (“SICR”) – Backstop of 30 days applied in the first instance

At least 3 forward-looking multiple economic scenarios used

Multiple macro-economic variables used (e.g. GDP growth, unemployment rate, Bank of England base rate, house prices)

Instances where cure rates used (e.g. 6 to 12 months for retail products in terms of moving from Stage 2 to Stage 1)

Management overlays used (e.g. post model adjustments to cater for certain forecast economic scenarios in light of current political uncertainty)

No restatement made to comparative figures

STAGE ALLOCATION DISTRIBUTION

0.0% 20.0% 40.0% 60.0% 80.0% 100.0%

Stage 3

Stage 2

Stage 1

Average gross carrying amount (%)

Top Banks Challenger banks Building Societies

0.0% 20.0% 40.0% 60.0% 80.0%

Stage 3

Stage 2

Stage 1

Average ECL (%)

Top Banks Challenger banks Building Societies

0.0% 10.0% 20.0% 30.0% 40.0%

Stage 3

Stage 2

Stage 1

% of ECL in relation to gross carrying amount

Top Banks Challenger banks Building Societies

Based on the banks selected, it can be noted that the gross carrying amount of loans fall mainly under Stage 1, whereas the ECL is spread more evenly over IFRS 9’s 3 stages.

ECL MODEL

The principal transition disclosures relate to:

Changes in accounting policies on Classification and Measurement and Impairment of financial assets

Accounting judgements and estimates:

– Definitions of SICR, stage allocation, Exposure at Default, Probability of Default and Loss Given Default

– Multiple economic scenarios used

Changes in Classification and Measurement with a comparison between IAS 39 and IFRS 9 by main class of assets

Reconciliation of opening balances of Balance Sheet items on transition from IAS 39 to IFRS 9 by carrying amount

Reconciliation of opening balance of Impairment provisions from IAS 39 to IFRS 9 by key area of change

Analysis of financial assets by Stage for gross carrying amount of financial assets and ECL

Page 4: BDO UK FINANCIAL SERVICES IFRS 9 INSIGHTS

FOR MORE INFORMATION:

HB0

1140

2

This publication has been carefully prepared, but it has beenwritten in general terms and should be seen as containing broadstatements only. This publication should not be used or reliedupon to cover specific situations and you should not act, or refrainfrom acting, upon the information contained in this publicationwithout obtaining specific professional advice. Please contact BDOLLP to discuss these matters in the context of your particularcircumstances. BDO LLP, its partners, employees and agents donot accept or assume any responsibility or duty of care in respectof any use of or reliance on this publication, and will deny anyliability for any loss arising from any action taken or not taken ordecision made by anyone in reliance on this publication or anypart of it. Any use of this publication or reliance on it for anypurpose or in any context is therefore at your own risk, withoutany right of recourse against BDO LLP or any of its partners,employees or agents.

BDO LLP, a UK limited liability partnership registered in Englandand Wales under number OC305127, is a member of BDOInternational Limited, a UK company limited by guarantee, andforms part of the international BDO network of independentmember firms. A list of members' names is open to inspection atour registered office, 55 Baker Street, London W1U 7EU. BDO LLPis authorised and regulated by the Financial Conduct Authority toconduct investment business.

BDO is the brand name of the BDO network and for each of theBDO member firms.

BDO Northern Ireland, a partnership formed in and under the lawsof Northern Ireland, is licensed to operate within theinternational BDO network of independent member firms.

Copyright © January 2019 BDO LLP. All rights reserved.Published in the UK.

www.bdo.co.uk

Dan Taylor

Partner

+44 (0)20 7893 [email protected]

Mark Spencer

Accounting Advisory Leader

+44 (0)20 7893 [email protected]

Nathalie Cheong

Senior Manager

+44 (0)20 7893 [email protected]