1. Overview of Bank Accounting Chu Yeong, Lim

2. Bank Balance Sheet Composition
Main assets
Loans & advances (includes interbank) : 45%
Trading securities & securities at FV: 20%
Financial investments held to maturity : 15%
Derivatives : 10%
Main liabilities
Customer deposits : 50%
Interbank borrowing : 5%
Trading interbank & customer deposits & debt securities issued : 20%
Shareholder’s equity : 6%
HSBC annual report (2009)

3. Key Balance Sheet Assets
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%.

4. 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)

5. 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.

6. Accounting standards (Securities)
IAS 39 & FAS 114
3 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.

7. 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.

8. Accounting standards (Fair Value Measurement)
IAS 39
Active versus Inactive markets
Assessment criteria:
levels of volume and activity,
if transaction prices are stale,
consistency in price quotes from brokers/market makers,
correlations among similar assets,
price levels that may indicate liquidity concerns,
bid/offer spreads beyond normal dealer profits

9. Accounting standards (Fair Value Measurement)
Orderly or disorderly transaction
Assessment criteria (a transaction is deemed disorderly if a condition is
satisfied):
Structured product had no sufficient exposure to the market based on usual marketing period,
If product has been marketed to single buyer,
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.

10. Accounting standards (Fair Value Option)
FAS 159
- Intention is to reduce financial statement volatility and reduce
onerous documentation requirements under FAS133.
- 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:
selected financial asset/liability must contain embedded derivatives,
selected financial liability with amounts contractually linked to valuation of asset at fair value,
changes in financial instrument value offset changes in fair values of financial assets/liabilities such as derivatives.

11. Accounting standards (Derivative accounting)
IAS 39 & FAS 133
- Trading derivative fair values recognised in income statement.
- Derivatives designated as hedging, accounting treatment as follows:
Fair value hedge - derivatives hedge the exposures to changes in
fair value of fixed rate exposures; derivatives’ gains/losses recognised in
earnings.
Cash flow hedge – derivatives hedge cash flows of forecasted
transactions (floating rate exposures); derivatives’ gains/losses
recognised in other comprehensive income.
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.

12. 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:
Host instrument is interest rate related while derivatives are foreign
exchange or equity related such as dual currency deposits, equity linked
deposits;
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.

13. Accounting standards (Loan Loss Provisions)
IAS 39 & FAS 114
- 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:
Risk ratings (external e.g. Moody’s and internal),
Loan types (e.g. credit cards versus loans to small corporate),
Product lines/industries of borrowers (e.g. volatile industries such as construction or industries in downturn)
Geographical segments
Economic conditions (current and forecasted)
Estimated delinquencies and payment histories
Credit scores of retail customers
Foreclosure rates for mortgage loans.

14. 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).

15. 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)

16. Reform of Accounting standards
Revisions to IAS 39 in the following phases (IFRS 9):
Phase 1 – derecognition criteria (ED – April 2009)
Existing derecognition conditions:
any substantial transfer of risks and rewards,
who has control over assets,
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:
when instrument has basic loan features
when instrument is managed on contractual basis.

17. 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)

18. Comparison of Expected Loan Loss versus Incurred Loan Loss models
Base case example: 5 year fixed rate loan with principal £1m, coupon rate 10%, 5% expected loss on maturity
Deloitte, 2010

19. Comparison of Expected Loan Loss versus Incurred Loan Loss models
Scenario 1: At start of year 2, expectation of loss revised to be 10% at maturity
Deloitte, 2010

20. Comparison of Expected Loan Loss versus Incurred Loan Loss models
Scenario 2: At start of year 2, expectation of loss revised to be zero at maturity
Deloitte, 2010

21. 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.

22. Sociological Perspectives of Risk Management & Control
The Risk Management of Everything (Power, 2004)
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)
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”

23. 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.

24. 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

25. 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

26. 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, Moody’s

27. Sociological Perspectives of Risk Management & Control
Diversifications at ABS level and at CDO level incorporated twice in ratings
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

28. References
Deloitte, IFRS 9 proposals: Accounting for financial instruments following a financial crisis.
Epstein, Nach, Bragg, GAAP 2009 Interpretation and Application of Generally Accepted Accounting Principles. John, Wiley & Sons, Inc.
Financial Stability Forum, Reporting of the Financial Stability Forum on Addressing Procyclicality in the Financial System.
HSBC, Annual Report. <
5. ICAEW, Audit of Banks: Lessons From The Crisis.
6. International Accounting Standards Committee (IASC), International Accounting Standard 39.
7. 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,
10. Ryan, S., G., Accounting in and for the Subprime Crisis. The Accounting Review 83,
11. Turner, A., Financial Services Authority Chairman address to the Institute of Chartered Accountants in England and Wales (ICAEW) in London.