Analysing Impact of AS 30, 31, 32 on Banks Finan cial Servi ces Indust ry – Emer ging Trends, Challenges & Way Forward WIRCofICAI November20,2009Presentedby:‐ AshutoshPednekarPartner, MPChitale&Co. 2Ashutosh Pednekar, Partner, M. P. Chitale & Co. Disclaimers These are my personal views and can not be construed to be the views of M/s.M. P. Chitale & Co., Chartered Accountants ICAI has no responsibility for its contents These views do not and shall not be considered as a professional advice. This presentation should not be reproduced in part or in whole, in any manner or form, without my written permission.
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8/6/2019 As 30 31 32 - Analysing Impact on Banks - 201109
The standard focuses on substance over form in accountingfor financial instruments. The key concepts that come tofore are:
The standard is likely to have far reaching implications onaccounting of most assets and liabilities with consequent PLimplications due to fair valuation, changes in various lawsand challenging certain normally accepted principles
6 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
AS 31 – Objective and scope
Establish principles for
Presenting financial instruments as liability or equity (and relatedclassification of interest, dividends, losses and gains) by theissuer
Offsetting a financial asset and a financial liability
Presentation of transactions in own equity
Accounting for treasury stock
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Portion of preference shares having discretionary dividends afterreducing liability component
Warrants / written call options that are settled by a fixed number ofown instruments for a fixed amount of cash or another financialasset (equity option component of a convertible bond/debenture)
15 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Interest, dividends, losses and gains
Income statement classification of interest, dividends, losses and gainsfollows directly from the balance sheet classification as liability or equity.
Any income statement effect on a financial liability will be recognized as anexpense irrespective of the nomenclature of the item eg. dividends,distributions etc.
Distributions to holders of an equity instrument should be recognized in anappropriate equity account
Transaction costs, net of any income tax benefit, of an equity transactionshould be recognized in an appropriate equity account
Discount accretion / redemption premiums form part of the recognizedinterest expense for a period on an effective interest rate basis.
Dividends classified as an expense are presented in the statement of profit
and loss as a separate item.
16 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Offsetting a financial asset and afinancial liability
currently has a legally enforceable right to set off
and an intention to settle net
or to realise the asset and settle the liability simultaneously
Practical situations will cause implementation challenges
Master netting agreements
Several instruments used to emulate a single instrument (synthetic instrument)
Items with the same risk, but different counterparties
Financial assets pledged as collateral for non-recourse liabilities
Financial assets that did not qualify for de-recognition under AS 30
but
In practice, netting will be difficult to achieve other than in very limitedsituations….because neither pure intention nor pure legal right is sufficient
IMPACT ANALYSIS
New concept for Indian GAAP
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19 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Present Classification of financial
instruments by Banks
Presented by way of a note and as Contingent LiabilitiesDerivatives
Category Particulars
Loans Bills Purchased & Discounted
CC, ODs and Loans Repayable on Demand
Term Loans
Further detailed presentation – popularly called 9 –wayclassification
Investments 6 line items to be presented
3 way categorisation HTM, AFS & HFT
Liabilities No specific categorization other than the line itemsspecified in the BR Act format
20 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
AS’ classification of financialinstruments
Category Definition
Financial assetsand financialliabilities at fairvalue through profit
and loss
Classified as held for trading (intended to be activelytraded)
All derivatives are classified as held for trading (exceptthose used as hedging instruments on financial guarantee)
Financial asset or financial liability designated as such atinception (subject to certain conditions)
Held-to-maturityinvestments
Financial assets with fixed or determinable payments andfixed maturity that an entity has the positive intention andability to hold to maturity
Loans andreceivables
Non-derivatives financial assets with fixed or determinablepayments, whether originated or acquired, quoted in anactive market. (Does not need to have a fixed maturity)
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23 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Available-for-sale financial assets
All available for sale assets are marked to market through a separatecomponent of equity (Investment revaluation reserve account)
Gains and losses on AFS assets are recognised in the profit and lossaccount on disposal or impairment of the asset. However, there are anumber of other complications with available for sale gains and losses
Gain or loss on available-for-sale asset
Effective interest
rate
Other changes in
fair value
Change in valuedue to spot FXchange
Change in valuedue to embeddedderivative
EquityProfit and Loss Account
Recycled to the profit andloss account on disposal orimpairment of the asset
24 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Classification determines subsequentmeasurement of financial assets
Available-for-sale
At fair valuethrough P&L
No
Yes
Classified as held fortrading or designated
as at fair valuethrough P&L at
inception
Non-derivativefinancial assets,fixed/determinable
payments, not quotedin active market
Intent and ability tohold to maturityand meets other
criteria
Yes
Yes
No
No
Loans andreceivables
Held-to-maturity
F a i r v a l u e
( A m or t i s e d ) c o s t
… similarly applies to financial liabilities
IMPACT ANALYSIS
All valuation has to beon gross basis unlessoff setting applies
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All derivatives are always marked-to-market (MTM) withchanges in fair value recognised in the P&L (unless usedas hedging instruments in cash flow hedge when fair valuechanges are in reserves) except for:
Regular way purchase or sale of afinancial asset
Delivery within a time frameestablished by regulation orconvention in the market
Apply trade date or settlement dateaccounting
Contracts for ‘normal’ purchasesand sales of non-financial items
Intended to meet purchase, sale orusage requirements
Designated for that purpose
Will be settled by delivery
42 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Embedded derivatives
How to identify?
An implicit or explicit term in a contractthat makes it behave like a derivative
Instruments with conversion features
Instruments with option to extend the termof debt
Index linked payments
Purchase or sale of contracts in foreign / third currency (other than currency ofmajor party, or currency in which thecontract is normally denominated)
When to separate?
The embedded derivative is notclosely related to economic
characteristics and risks of the host
(e.g. leverage, optionality feature);
Embedded derivative would be a
derivative if it was freestanding; and
The host contract is not carried at fair
value through profit or loss
An embedded derivative is a component of a hybrid (combined)instrument that also includes a non-derivative host contract,where some of the cash flows of the combined instrument vary ina way similar to a stand-alone derivative.
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The effectiveness test itself must be stated upfront in the hedgedocumentation. This means that it must be designed and tested toensure that it provides a suitable solution before the hedge commences
There are two components to an effectiveness test:
the prospective test
the retrospective test
Following criteria to be fulfilled at inception & during the life of the hedge
Hedge is expected to achieve offsetting changes in fair value / cash flows
attributable to the hedged risk
Comparing past changes in fair value / cash flows
High statistical correlation between hedged item and hedging instrument
Actual results of hedge are within a range of 80%-125%
52 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Hedge effectiveness…
Hedging instrument - 120
Hedged item + 100
computed effectiveness is within a range of 80% -125% (83% /
120% in this case)
the hedge relationship is highly effective
nevertheless a loss of 20 has to be recorded in profit and loss
due to ineffectiveness
the fact that the hedge relationship is highly effective does not
lead to ignore the loss incurred due to ineffectiveness
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53 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Transitional Provisions
Designation and Measurement of existing Financial Assetand Financial Liability.
Change the designation and measurement as per the standard.
Adjust resultant gain or loss
To the extent of P&L impact, from the opening Revenue Reserve.
To the extent of ‘equity’ impact to recognize in equity account.
Derecognition of Financial Assets and Financial LiabilitiesRequirements of the Standard to be applied prospectively.
Can be applied retrospectively provided the information needed wasobtained at the time of initially accounting for these transactions.
If chosen to apply retrospectively, it should be done for all FA & FL.
54 Ashutosh Pednekar, Partner, M. P. Chitale & Co.
Hedge Accounting :
Measure all derivatives at fair value.
Eliminate all deferred losses and gains if any, arising onderivatives which under the previous accounting policy of theentity were reported as assets or liabilities.
Adjust any resulting gains or losses (as adjusted by any relatedtax expense / benefit) against opening balance of revenuereserves and surpluses.
Embedded Derivatives
an entity to assess whether an embedded derivative is to beseparated from the host contract and accounted for as derivative.
Transitional Provisions…
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