November

Notes from the IASB-FASB financial crisis roundtable in London

17 Nov 2008

In response to the challenges caused by the current market conditions the IASB and the FASB have decided to hold a series of roundtables to gather views from constituents on the most urgent accounting issues and how to approach them.

The first roundtable was held in London on 14 November 2008. The second will be at the FASB's office in Norwalk, CT USA, on 25 November 2008. The final roundtable will be on 3 December 2008 at the offices of the Accounting Standards Board of Japan in Tokyo. Presented below are the preliminary and unofficial notes taken by Deloitte observers at the London roundtable.

Notes from the IASB-FASB Global Financial Crisis RoundtableLondon 14 November 2008

The London roundtable was divided into two 2.5 hour sessions. IASB Board Member John Smith chaired both sessions. The 44 participants were drawn from a wide range of constituents. It was noted that all next steps, in response to calls from constituents, will be considered jointly by IASB and FASB and following due process and, therefore, no decisions were taken at these roundtable meetings.

For the roundtable in London the following topics were discussed based on submissions from participants received:

  • Impairment of financial assets
  • Reclassification of financial instruments designated under the fair value option
  • Fair value measurement
  • Disclosures
  • Other issues

Impairment of financial assets

The chairman introduced the topic highlighting that the guidance for impairment both regarding triggers and measurement is different in IFRS and US GAAP.

Much of the discussion focussed on the different impairment models that exist in IFRS and US GAAP, particularly for impairment of debt instruments. Many participants believe there should be convergence. They commented most frequently on the differences between loan loss impairment for a debt instrument measured at amortised cost compared to one measured at fair value as an available-for-sale (AFS) investment. Recent market events had resulted in the latter being recognised at an amount significantly lower than if it has been measured under an amortised cost model due to the current market's assessment of credit and liquidity risk compared to an impairment that would have been recognised had the impairment been calculated using the original effective interest rate. Some participants put forward the idea that impairment of an AFS debt instrument should be recognised on the same basis as if the asset was measured at amortised cost. If that is done, differences due to liquidity risk or credit risk in excess of the incurred loss model would be recognised in other comprehensive income, rather than currently recognised in profit or loss. This led to a broader question about what impairment in income is meant to represent – loss of recoverable cash flows or loss in fair value.

Some participants raised a number of interpretative issues with the current model of impairing AFS debt instruments. Specifically, if an AFS debt instrument is impaired, are further declines in fair value considered as further impairments, or does this depend on whether further fair value declines are derived from movements in the risk-free rate as opposed to further declines in credit quality, or whether further declines in fair value are impairment losses only if there are further impairment triggers?

There was feedback from user groups as to whether impairment losses based on the incurred loss concept were useful even if the loss recognised in profit or loss is based on fair value. Some participants noted that fair value is a good predictor of real cash losses. It was also highlighted while there is a difference between impairment and fair value volatility, markets are usually better than individuals in predicting the performance of an instrument.

There was discussion of whether for equity securities an impairment loss should be allowed to be reversed through profit or loss – currently it is not. Some argued that as the trigger event is a significant or prolonged decline in fair value below cost, then should this trigger event no longer apply, the impairment should be reversed through profit or loss.

The Boards will consider whether amendments to the existing measurement guidance for impairment is needed, or alternatively whether further disclosure in the short term could be introduced to align the different impairment approaches. The chairman noted that the challenges resulting from the current guidance are rooted in the fact that there are different measurement classification categories within IFRS and US GAAP. Aligning the classification categories would address many of these issues.

Many of the participants agreed with this conclusion.

Reclassification of financial instruments designated under the fair value option

The roundtable then discussed the use of the fair value option and possible reclassifications out of this designation. Some participants sympathised with revising the conditions for invoking the fair value option to achieve convergence with US GAAP (that is, so the fair value option under IFRS is unrestricted) and widening the fair value option for certain arrangements over non-financial items not currently in IAS 39. Others proposed allowing reclassification out of the fair value option in case where conditions for invoking the fair value option are no longer met. Participants holding this view felt this was appropriate in the case of an accounting mismatch that existed when the fair value option was invoked which no longer applied, for example:

  • where financial assets were matching insurance liabilities and the continuation of the fair value option created more of an accounting mismatch, or
  • when the fair value option was used instead of fair value hedge accounting and the mismatch failed due to changes in fair value of the assets due to credit and prepayment risk, or
  • when the entity ceased to manage the financial instruments on a fair value basis due to difficulties in establishing fair value in the current markets.

Concern was raised that to allow an entity to reclassify in such circumstances would require further rules as what would be a permitted reclassification.

Fair value measurement

Regarding how to determine fair value, it was noted there was a recent submission to the IFRIC on how to include liquidity spreads in valuation when the market is no longer active. While many participants agreed that determining fair value is more challenging in inactive markets, it is not appropriate to normalise values or use liquidity spreads that do not reflect a current market participant's view of spreads. It was noted the view expressed in the IFRIC submission was not in accordance with IAS 39. Others referred to the work done by the IASB Experts Advisory Panel and that this guidance should indeed be authoritative (and not voluntary as it is at the moment).

The roundtable participants discussed the procyclical effects of fair value accounting. There seemed to be agreement that it is not the purpose of financial reporting to report 'regulatory numbers' that avoid overly positive or negative market movements. It was noted that within the European Union, ECOFIN has established a working group to analyse the roots of procyclicality and that Bob Herz (FASB chairman) and Sir David Tweedie (IASB chairman) would be on a Financial Stability Forum working party looking at procyclicality.

Disclosures

The chairman introduced this topic by presenting the various projects on the boards' agendas on the topic of disclosures. User groups were concerned that the IAS 39 amendment on reclassifications of financial assets issued in October 2008 only amended IFRS 7, which only deals with disclosure in annual accounts. User groups stated that there are widely different variations in the amount of disclosure in interim financial statements for entities that reclassified financial assets in Q3 and proposed that the additional disclosures included in IFRS 7 should be required in interims.

Other issues

The roundtable discussed the issue of accounting for synthetic Collateralised Debt Obligation (CDO) structures. Many speakers highlighted that there is a divergence between IFRS and US GAAP as to whether credit-related embedded derivatives require separation or not in the instance when the instrument is not fair valued through profit or loss. It was noted that both the IASB and FASB would consider this issue.

It was noted that clarification is needed on whether embedded derivatives need to be assessed if an entity reclassified an asset out of fair value through profit or loss as a result of the IAS 39 amendment issued last month. Some IASB Board members noted that the IAS 39 amendment was not intended not to require assessment of embedded derivatives. Participants noted that IAS 39/IFRIC 9 was not as clear as it could be in this respect. Staff from the IASB indicated that this would be addressed in the future, and the chairman stated that should the IASB issue a clarification it would most likely state that assessment of embedded derivatives would be required at the date of reclassification and it would be applied retrospectively.

One participant noted that the IASB and FASB projects on derecognition and consolidation did not seem to be aligned, and a request was made that they should be.

The chairman asked participants if there were other issues the boards should address. No participant raised other issues.

This summary is based on notes taken by observers at the Roundtable and should not be regarded as an official or final summary.

Updated summary of IFRIC agenda rejections

16 Nov 2008

We have updated our Summary of Issues Not Added to IFRIC's Agenda to reflect the IFRIC's final decisions at its November 2008 meeting not to add the following topics to its agenda.

Our summary now includes nearly 140 issues:
  • IAS 39 – Valuation of restricted securities
  • IFRIC 14 – Stable workforce assumption

 

Report of the G20 Summit

16 Nov 2008

The meeting of the G20 Heads of State and leaders of the World Bank, the International Monetary Fund, the United Nations, and the Financial Stability Forum has concluded.

The participants published a Declaration of the Summit on Financial Markets and the World Economy (PDF 50k). The Declaration sets out both immediate actions (by 31 March 2009) and medium-term actions that should be taken to strengthen the global economy and reform the world's financial markets. The leaders agreed on a set of common principles for market reforms, including the following principle for strengthening transparency and accountability:

We will strengthen financial market transparency, including by enhancing required disclosure on complex financial products and ensuring complete and accurate disclosure by firms of their financial conditions. Incentives should be aligned to avoid excessive risk-taking.

The excerpts below are the recommendations most directly related to the IASB and IFRSs.

Strengthening Transparency and Accountability

Immediate Actions by March 31, 2009:

  • The key global accounting standards bodies should work to enhance guidance for valuation of securities, also taking into account the valuation of complex, illiquid products, especially during times of stress.
  • Accounting standard setters should significantly advance their work to address weaknesses in accounting and disclosure standards for off-balance sheet vehicles.
  • Regulators and accounting standard setters should enhance the required disclosure of complex financial instruments by firms to market participants.
  • With a view toward promoting financial stability, the governance of the international accounting standard setting body should be further enhanced, including by undertaking a review of its membership, in particular in order to ensure transparency, accountability, and an appropriate relationship between this independent body and the relevant authorities.
  • Private sector bodies that have already developed best practices for private pools of capital and/or hedge funds should bring forward proposals for a set of unified best practices. Finance Ministers should assess the adequacy of these proposals, drawing upon the analysis of regulators, the expanded FSF, and other relevant bodies.

Medium-term actions:

  • The key global accounting standards bodies should work intensively toward the objective of creating a single high-quality global standard.
  • Regulators, supervisors, and accounting standard setters, as appropriate, should work with each other and the private sector on an ongoing basis to ensure consistent application and enforcement of high-quality accounting standards.
  • Financial institutions should provide enhanced risk disclosures in their reporting and disclose all losses on an ongoing basis, consistent with international best practice, as appropriate. Regulators should work to ensure that a financial institution's financial statements include a complete, accurate, and timely picture of the firm's activities (including off-balance sheet activities) and are reported on a consistent and regular basis.

Reinforcing International Cooperation

Medium-term actions:

  • Authorities, drawing especially on the work of regulators, should collect information on areas where convergence in regulatory practices such as accounting standards, auditing, and deposit insurance is making progress, is in need of accelerated progress, or where there may be potential for progress.

Mexico plans move to IFRSs in 2012

16 Nov 2008

On 11 November 2008, the Mexican Banking and Securities Commission (Comisión Nacional Bancaria y de Valores, or CNBV) announced that all companies listed on the Mexican Stock Exchange will be required to use IFRSs starting in 2012.

Listed companies will have the option to use IFRSs earlier – even as early as 2008 – subject to requirements that will be established by the CNBV.

Mexican Financial Reporting Standards, developed by the Consejo Mexicano para la Investigación y Desarrollo de Normas de Información Financiera (CINIF), will continue to be required for non-listed Mexican entities. CINIF has stated that it will continue its programme for converging Mexican standards with IFRSs. Click for:

Co-chairs of IASB-FASB crisis advisory group

15 Nov 2008

Hans Hoogervorst, Chairman of the Netherlands Authority for the Financial Markets (AFM, the Dutch securities regulator) and Harvey Goldschmid, former Commissioner of the United States Securities and Exchange Commission, have agreed to co-chair the high-level advisory group formed jointly by the IASB and the FASB to consider financial reporting issues arising from the global economic crisis.

Click for Press Release (PDF 51k).

 

EITF Snapshot for November 2008

15 Nov 2008

We have posted the November 2008 edition of EITF Snapshot summarising the 13 November 2008 meeting of FASB's Emerging Issues Task Force.

EITF Snapshot, published by Deloitte & Touche LLP (USA), enables readers to identify relevant topics and to understand quickly the meeting's outcome. Click to view the November 2008 issue of EITF Snapshot (PDF 146k).

This EITF Snapshot covers the following issues discussed by the EITF at the meeting:

  • Issue 08-1 Revenue Arrangements With Multiple Deliverables – Consensus-for-exposure
  • Issue 08-9 Milestone Method of Revenue Recognition – Tentative conclusion reached
  • Issue 08-6 Equity Method Investment Accounting Considerations – Final consensus
  • Issue 08-7 Accounting for Defensive Intangible Assets – Final consensus
  • Issue 08-8 Accounting for an Instrument (or an Embedded Feature) With a Settlement Amount That Is Based on the Stock of an Entity's Consolidated Subsidiary – Final consensus
  • Issue 08-10 Selected Statement 160 Implementation Questions – Consensus-for-exposure

Initial EITF consensuses (known as 'consensuses-for-exposure') are exposed for a comment period after ratification by the FASB. At its first scheduled meeting after the comment period, the EITF considers comments received and, as warranted, affirms its consensuses-for-exposure as final consensuses. Those consensuses are then provided to the Board for final ratification.

SEC plans 'mark-to-market' roundtable

15 Nov 2008

The US Securities and Exchange Commission (SEC) will hold its second roundtable on 'mark-to-market' accounting on 21 November 2008 at 9:30 am ET at its offices in Washington.

This roundtable, along with the previous one hosted on 29 October 2008, will provide input to the SEC as part of a Congressionally mandated study pursuant to the Emergency Economic Stabilization Act of 2008. This roundtable will consist of a single panel, which will focus on potential improvements to the current accounting model and implications of possible changes. Click for press release (PDF 27k).

FAF letter to President Bush on standard setting

15 Nov 2008

In a letter to US President George W Bush in advance of the upcoming G20 summit meeting, the Financial Accounting Foundation has urged the President to support independent accounting standard setting and open due process that is 'free from political interference'.

Click to download the FAF letter to President Bush (PDF 1,616k). Here is an excerpt:

We understand that current issues relating to international accounting standards will be discussed at this meeting as part of a comprehensive examination of the global financial crisis. The FAF believes that the complex task of setting accounting standards is best done by the experts who comprise the FASB and the International Accounting Standards Board (IASB). We believe the integrity and independence of the accounting standard setting process is of critical importance to investors worldwide. We support the joint commitment of the FASB and the IASB to work in unison to develop and implement a consistent response to global financial reporting issues emanating from the current financial crisis.

National standard setters communique to IASB

15 Nov 2008

Twenty members of the National Standard Setters Group (NSS) have sent a communique to the IASB and the IASCF Trustees expressing support for the IASB's efforts to achieve true global financial reporting standards.

The NSS members mention the Request by the European Commission asking the IASB to amend or interpret IAS 39 to ensure that three specific matters are addressed in time for year-end 2008 financial reports. The NSS members state that:

  • It is important that the IASB follows appropriate due process.
  • While appropriate due process should allow constituents ample time to consider and comment on any changes, it may be, in these extraordinary times, that due process will need to be shortened. Should this be the case we stand ready to assist the IASB to achieve the most effective due process possible. For instance we could stimulate debate among our national constituents, hold round tables on the technical issues involved and act as focal points for comments.
  • We urge those adopting international financial reporting standards to accept the decisions of the IASB if they are made with adequate due process and deliberation, taking into account the impacts on markets and the economy.

Click for Communique to the IASB (PDF 18k).

The twenty signatories to the Communique are:
  • Ian Mackintosh, Chairman, Accounting Standards Board, UK
  • Amarjit Chopra, Chairman, Accounting Standards Board, India
  • Chungwoo Suh, Chairman, Korean Accounting Standards Board
  • Conrad C. Chang, Chairman, Taiwan Financial Accounting Standards Committee
  • Paul F, Winklemann, Chairman, Financial Reporting Standards Committee, Hong Kong
  • Bruce Porter, Acting Chairman, Australian Accounting Standards Board
  • Jean-Francois LePetit, Chairman, French Accounting Standards Board
  • Alex Watson, Chairman, Accounting Practices Committee, South Africa
  • Paul Cherry, Chair, Canadian Accounting Standards Board
  • Anders Ullberg, Chairman, The Swedish Financial Reporting Board
  • Stig Enevoldsen, Chairman, European Financial Reporting Advisory Group
  • Massimo Tezzon, Secretary General, Organismo Italiano Contabilita
  • Hans de Munnick, Chair, Dutch Accounting Standards Board
  • C.P.C. Felipe Perez Cervantes, President, Mexican Accounting Standards Board
  • Joanna Perry, Chairman, Financial Reporting Standards Board, New Zealand
  • Asad Ali Shah, President, Institute of Chartered Accountants of Pakistan
  • Ikuo Nishkawa, Chairman, Accounting Standards Board of Japan
  • Liesel Knorr, President, German Accounting Standards Board
  • Erland Kvaal, Chairman, Norwegian Accounting Standards Board
  • Gerhard Prachner, Chairman, Austrian Accounting Standards Board

UK groups reaffirm their support for the IASB

15 Nov 2008

A group of constituents of the IASB from the United Kingdom has published a letter in the 'Financial Times' urging that the European Commission continue to support the IASB as Europe's accounting standard setter and not to reject or change any IASB standards.

The signatories represent UK preparers, auditors, and users of accounts and include Ken Wild, head of Deloitte's IFRS Global Office. Copies of the letter were sent to the European Commission and the IASB.

The EU has the ability not to accept international standards for use in Europe, or to change them. We strongly believe that these powers should only be used in the most exceptional circumstances and that the present situation does not justify their use. We would not support another carve-out.

IFRS is becoming the world's global accounting standard, and the EU has played a very important part in this convergence. If Europe in any way adopts its own version of IFRS, we not only lose the advantages of global comparability, we also risk detaching ourselves from this global movement and sacrificing our position of influence for one on the sidelines, just at a point when the global economy needs strong leadership in all areas, including accounting.

Click to view the letter (PDF 12K).

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