Key Balance Sheet Assets (1)Cash and balances held at central banks Low yields, held to meet statutory liquidity requirements Highly liquid assets covered in statutory liquidity requirements: Cash and balances held at central banks, government securities, repo securities Opportunity cost between low yields and interbank lending rate factored in cost of funding to the users of funds Formula to factor this cost in cost of funds = [100% x original cost of funds – 10% x (yield of liquid assets – interbank lending rate)]/(100% - 10%) This assumes statutory liquid asset requirement to be 10%.
Key Balance Sheet Assets (2)Trading assets Held for trading and fair valued under IAS 39 and FAS 115 accounting standard classifications e.g. equity and debt securities, reverse repos, loans traded in market (3)Financial assets designated at fair value Elected/designated for fair valuation under IAS 39 and FAS 159 Financial assets e.g. available for sale (AFS) securities, securities held for repurchase/resale, loans held for sale, equity investments and loan commitments (4)Financial Investments Held for maturity securities (debt & equity)
Key Balance Sheet Assets (5)Loans and Advances Loans and advances to banks and non-banks Includes repos and reverse repos – collateralized borrowing and collateralized lending "Repo 105 in Lehman treated as sale of inventory on basis of overcollateralization, to reduce leverage ratios. Net carrying amount shown as principal amounts less loan loss allowances/provisions.
Accounting standards (Securities) IAS 39 & FAS main categories: (a) Held to maturity: management has intent to hold securities to maturity, security is accounted for at amortized cost, interest accrued, realized gains/losses on sale of securities, (b) Trading: security held for short term sale purposes, security accounted for under fair value accounting, (c) Available-for-sale: neither held for trading or to maturity (statutory liquidity requirements), changes in fair values recognized in other comprehensive income & transferred to earnings upon sale of security -Impairment test: if decline in asset deemed to be other than temporary, impairment charge made to income statement.
Accounting standards (Fair Value Measurement) FAS 157 (exit price in principal or most advantageous market) Level 1 assets - most liquid asset, observable market prices e.g. quoted equities, quoted bonds, spot FX Level 2 assets - market prices of assets not directly observable, but fair values can be derived from models using directly observable market inputs such as interest rate yield curves and option volatilities e.g. convertible bonds, interest rate swaps, FX swaps Level 3 assets - valuation model uses unobservable market data e.g. MBS Fair value adjustments for levels 2 & 3 assets: bid-offer spreads, liquidity premium.
Accounting standards (Fair Value Measurement) IAS 39 Active versus Inactive markets Assessment criteria: a)levels of volume and activity, b)if transaction prices are stale, c)consistency in price quotes from brokers/market makers, d)correlations among similar assets, e)price levels that may indicate liquidity concerns, f)bid/offer spreads beyond normal dealer profits
Accounting standards (Fair Value Measurement) Orderly or disorderly transaction Assessment criteria (a transaction is deemed disorderly if a condition is satisfied): a)Structured product had no sufficient exposure to the market based on usual marketing period, b)If product has been marketed to single buyer, c)If seller is in state of insolvency, d)Transaction price is outlier compared to prices of similar products If market is inactive and transaction is disorderly, Mark to model is used.
Accounting standards (Fair Value Option) FAS Intention is to reduce financial statement volatility and reduce onerous documentation requirements under FAS Management given substantial discretion to elect fair value e.g. assets classified as held to maturity or available for sale, but funded by derivatives. IAS 39 - Revision in 2005 allows a firm to designate a financial asset or a financial liability on initial recognition as one to be measured at fair value. - Designation is irrevocable. Conditions include: a)selected financial asset/liability must contain embedded derivatives, b)selected financial liability with amounts contractually linked to valuation of asset at fair value, c)changes in financial instrument value offset changes in fair values of financial assets/liabilities such as derivatives.
Accounting standards (Derivative accounting) IAS 39 & FAS Trading derivative fair values recognised in income statement. - Derivatives designated as hedging, accounting treatment as follows: a)Fair value hedge - derivatives hedge the exposures to changes in fair value of fixed rate exposures; derivatives gains/losses recognised in earnings. b)Cash flow hedge – derivatives hedge cash flows of forecasted transactions (floating rate exposures); derivatives gains/losses recognised in other comprehensive income. c)Derivatives hedge foreign currency exposures of net investments in foreign operations, derivatives gains/losses recognised in other comprehensive income. Tests of hedge effectiveness based on fair value correlations between hedging and hedged items.
Accounting standards (Derivative accounting) IAS 39 & FAS 133 Derivatives embedded in financial instruments (e.g. dual currency deposits), bifurcation required if embedded derivatives are not related to underlying host instrument: a)Host instrument is interest rate related while derivatives are foreign exchange or equity related such as dual currency deposits, equity linked deposits; b)If embedded derivatives are interest rate related, the investor may not recover substantially the initial investment or the returns of structured product is at least twice that without the embedded derivatives e.g. range accrual deposits.
Accounting standards (Loan Loss Provisions) IAS 39 & FAS Incurred loan loss allowances/provisions method requires specific and general provisions. - Objective evidence of loss event for specific provisions e.g. payment defaults. - Evaluation criteria for general provisions: a)Risk ratings (external e.g. Moodys and internal), b)Loan types (e.g. credit cards versus loans to small corporate), c)Product lines/industries of borrowers (e.g. volatile industries such as construction or industries in downturn) d)Geographical segments e)Economic conditions (current and forecasted) f)Estimated delinquencies and payment histories g)Credit scores of retail customers h)Foreclosure rates for mortgage loans.
Accounting standards (Loan Loss Provisions) IAS 39 & FAS 114 Loan future cash flows discounted at original effective rates to derive the loan asset value and provisions to be recorded. E.g. 5 year loan of £15k to be received at end of each year at original effective interest rate of 7%. One year before maturity, evidence of impairment and expected cash flow is £7.5k. PV of loan = £7.5k discounted at 7% = £7k Impairment loss = £15k - £7k = £8k. Interest accrual = £7k x 7% = £490. Incurred loan loss accounting method severely criticised for delaying recognition of loan losses and being pro-cyclical (Financial Stability Forum 2009; Turner, 2010).
Accounting standards (Securitization) Securitization: sale of loans and receivables to investors 4 players in securitization market: a) Banks – originators of loans b) Securitizers – separate securitization entities that house securitized assets c) Investors in securitized assets d) Guarantors – that provide guarantees or liquidity support Key accounting question: Should securitized assets in the securitization entity be consolidated? Securitization entity consolidated with issuer when former does not have legal right to foreclose on the securitized assets. Rapid growth in securitization many securitization entities which do not have such rights were not consolidated. (Ryan, 2008)
Reform of Accounting standards Revisions to IAS 39 in the following phases (IFRS 9): Phase 1 – derecognition criteria (ED – April 2009) Existing derecognition conditions: a)any substantial transfer of risks and rewards, b)who has control over assets, c)whether transferor has continuing involvement in assets. Revisions – simplify the conditions and use the key tests of control. Phase 2 – classification & measurement criteria (ED – July 2009) Eliminate bifurcation between financial host product & embedded derivative. 2 conditions of measuring financial asset at amortised cost: a)when instrument has basic loan features b)when instrument is managed on contractual basis.
Reform of Accounting standards Phase 3 – amortised cost & impairment Expected loan loss model Future expected cash flows (factor expected credit loss over life of the loan) at original effective interest rates Recognition threshold of loss event removed. Key argument against use of fair valuation for mortgage loans is that they are expected to be held for long term & accounting mismatches against the liabilities (causes earnings volatility that are not related to economics). Phase 4 – hedge accounting (ED - 1H 2010) Phase 5 – classification & measurement of liabilities (ED not released yet)
Base case example: 5 year fixed rate loan with principal £1m, coupon rate 10%, 5% expected loss on maturity Comparison of Expected Loan Loss versus Incurred Loan Loss models Deloitte, 2010
Scenario 1: At start of year 2, expectation of loss revised to be 10% at maturity Comparison of Expected Loan Loss versus Incurred Loan Loss models Deloitte, 2010
Scenario 2: At start of year 2, expectation of loss revised to be zero at maturity Comparison of Expected Loan Loss versus Incurred Loan Loss models Deloitte, 2010
Reform of Accounting standards ICAEW proposals (ICAEW, 2010) -Auditors may provide assurance on new summary risk statements of banks. -Banks should confirm that key areas of judgement discussed with auditors are set out in critical accounting estimates of financial statements. Auditors to be involved in reporting on front sections of annual reports. -Regular dialogue between auditors and banking supervisors. -Supervisors should tap auditors expertise as part of their monitoring regime.
Sociological Perspectives of Risk Management & Control The Risk Management of Everything (Power, 2004) 1.Rise of Internal Control – critical events: Cadbury Code in 1992 due to collapse of Maxwell Empire, COSO document in US Internal controls turned from private organizational practices to regulatory objects e.g. Sarbanes-Oxley Act in US (turning organizations inside out) 2.Invention of Operational Risk – focus on fraud and infrastructure risk issues under Basel II; Barings case help sell the idea - policy question of implementation effectiveness because mainly on low impact high probability (deviation from norm), not high impact, low probability events - myth of controllability especially in areas such as management culture, tone at the top
Sociological Perspectives of Risk Management & Control 3. Making Risk Auditable: Legalization & Organization pressures on organizations to manage all risks (more litigious environment) managers of risks more concerned about protecting their own risks experts made accountable for too much uncertainties, things they do not know dangerous flight from judgment and culture of defensiveness e.g. debated tick-box mentality of auditors not exercising professional skepticism The Risk Management of Nothing (Power, 2009) challenges the mere use of metrics in enterprise risk management (ERM) and not recognizing that risk appetite is dynamic organizational process involving values and the interconnectedness of risks with external states of world.
Sociological Perspectives of Risk Management & Control How evaluation practices of ABS/MBS and CDOs lead to arbitrage and credit crisis (Mackenzie, 2010) 1. Historical path-dependency of evaluation practices CDO – primary object is default MBS – primary object is prepayment risk (3 government sponsored agencies: Ginnie Mae, Fannie Mae, Freddie Mac seen as backing the mortgages) - Minimal prepayment penalty high prepayment risk - Prepayment option reduces value of MBS - Key skill in evaluation is on prepayment risk
Sociological Perspectives of Risk Management & Control 2. Evaluation practices oriented towards credit correlation -Influence the creation of tradable credit indices 3. Evaluation practices become different organization routines in different parts of the same organization (banks, rating agencies) -e.g. ABS and CDO evaluated by different sections of rating agencies; for ABS CDO, treated as variant of CDO, based on underlying ABS ratings 4. Ratings encode default probability and become rules for institutional investors – 74% of US and 78% of European fund managers use minimum rating buying requirement - In US, 100 federal laws & 50 regulations incorporate ratings
Sociological Perspectives of Risk Management & Control 5. Ratings black-boxed complexities of complex instruments -spreads can be compared across instruments based on spread- rating relationships -design of instruments driven by how they will be evaluated by rating agencies 6. Different evaluation practices allow arbitrage -tranches of CDO at A, AA, AAA give higher yields than corresponding corporate or asset-backed derivatives -default probability & recovery rate of CDO based on ABS ratings and defaults -ABS correlations hard to obtain (lack of markets & defaults were rare) -Judgment & consistency with ABS correlation, plus competition lead to 0.3 correlation factor by S&P, Moodys
Sociological Perspectives of Risk Management & Control -Diversifications at ABS level and at CDO level incorporated twice in ratings 7.Traditional buyers of mezzanine (BBB rated) ABS tranches displaced by ABS CDO managers. ABS CDO managers need to buy raw materials (ABS) Demand for ABS > Supply Lend to securitize Loosening of lending standards
References 1.Deloitte, IFRS 9 proposals: Accounting for financial instruments following a financial crisis. 2.Epstein, Nach, Bragg, GAAP 2009 Interpretation and Application of Generally Accepted Accounting Principles. John, Wiley & Sons, Inc. 3.Financial Stability Forum, Reporting of the Financial Stability Forum on Addressing Procyclicality in the Financial System. 4.HSBC, Annual Report..http://www.hsbc.com 5.ICAEW, Audit of Banks: Lessons From The Crisis. 6.International Accounting Standards Committee (IASC), International Accounting Standard MacKenzie, D., The Credit Crisis as a Problem in the Sociology of Knowledge. Working Paper. 8.Power, M., The risk management of everything. Demos publication. 9.Power, M., The risk management of nothing. Accounting, Organizations and Society 34, Ryan, S., G., Accounting in and for the Subprime Crisis. The Accounting Review 83, Turner, A., Financial Services Authority Chairman address to the Institute of Chartered Accountants in England and Wales (ICAEW) in London.