IFRS 9 Will Impact Banks’ Provisions

By Cayetano Gea-Carrasco

May 2015

As Published In: Moody's Analytics Risk Perspectives | Risk Data Management | Volume V | May 2015

Enterprise Risk

International Financial Reporting Standard 9 (IFRS 9) will soon replace International Accounting Standard 39 (IAS 39). The change will materially influence banks’ financial statements, with impairment calculations affected most. IFRS 9 will cover financial institutions across Europe, the Middle East, Asia, Africa, and Oceania.

IFRS 9 will align measurement of financial assets with the bank’s business model, contractual cash flow of instruments, and future economic scenarios. In addition, the IFRS 9 provision framework will make banks evaluate how economic and credit changes will alter their business models, portfolios, capital, and the provision levels under various scenarios.

Given the IFRS 9 requirements in terms of classification, measurement, and impairment calculation and reporting, banks should expect to be required to make some changes to the way they do business, allocate capital, and manage the quality of loans and provisions at origination. Banks will face modeling, data, reporting, and infrastructure challenges in terms of both:

Reassessing the granularity (e.g., facility-level provisioning analysis) and/or credit loss impairment modeling approach (e.g., consistency regarding the definition of default between Basel and IFRS 9 models).
Enhancing coordination across their finance, risk, and business units.

Effectively addressing these challenges will enable bank boards and senior management to make better-informed decisions, proactively manage provisions and effects on capital plans, make forward-looking strategic decisions for risk mitigation in the event of actual stressed conditions, and help in understanding the evolving nature of risk in the banking business. In the end, a thoughtful, repeatable, consistent capital planning and impairment analysis should lead to a more sound, lower-risk banking system with more efficient banks and better allocation of capital.

To help minimize the challenges faced by financial institutions when transitioning to IFRS 9, we conducted the Moody's Analytics 2015 IFRS 9 Survey to give practitioners a snapshot of the "current state" of the industry. Moody's Analytics has also included a series of comments on best practices and industry trends.

Survey Findings: Implications for Financial Institutions

IFRS 9 will affect the business models, processes, analytics, data, and systems across several dimensions.

Capital, lending, underwriting, and origination

Provision levels are expected to substantially increase under IFRS 9 versus IAS.
Further equity issuances may be needed, with the potential for greater pro-cyclicality on lending and provisioning owing to IFRS 9. Capital levels and deal pricing will be affected by the expected provisions, but must be evaluated under different economic cycles and scenarios.
Banks will have to estimate and book an upfront, forward-looking expected loss over the life of the financial facility and monitor for ongoing credit-quality deterioration.
Rating and scoring systems may have to be updated, especially for those banks without Internal Ratings-Based (IRB) models.

Asset reclassification, reconciliation, and measurement

Banks will need to reclassify assets and reconcile them with IAS. They will also need to map products that can be categorized before the calculation (contractual cash flow test) or create a workflow to capture the purpose (business model test). An additional effort could be required to identify those products that can be considered out of scope (e.g., short-term cash facilities and/or covenant-like facilities).
Institutions will have to align, compare, and reconcile metrics consistently (e.g., Basel vs. IFRS 9).

Cross-coordination across risk, finance, and business units

Financial institutions will have to coordinate finance, credit, and risk resources for which current accounting systems are not equipped.

Credit impairment calculation and valuation

The IFRS 9 provision model will make banks evaluate, at origination, how economic changes will affect their business models, capital plans, and provisioning levels.
A methodology to calculate a forward-looking measurement will have to be developed and/or updated (e.g., transformation from TTC to PiT), while the cash flow valuation analysis must be scenario-driven.
IFRS 9 will affect the existing documentation and hedge accounting frameworks.

Data, systems, processes, reporting, and automation

Systems will need to change significantly to calculate and record changes requested by IFRS 9 in a cost-effective, scalable way.
Data requirements will increase to meet IFRS 9-related calculations and ongoing monitoring.
Retrieval of old portfolio data will also be needed, especially for the transactions originated before the A-IRB models have been introduced.
IFRS 9 impairment calculation requires higher volumes of data than IAS, which may substantially increase the performance and computational requirements of a credit-loss impairment calculation engine.
Financial reporting and reconciliation will be needed to align with other regulatory requirements.

Documentation and governance

IFRS 9 makes the provisioning exercise a cross-functional activity, with coordination needed across the risk, finance, accounting, and business functions.

IFRS 9 is a Game Changer

IFRS 9 is the International Accounting Standards Board’s (IASB) response to the financial crisis, aimed at improving the accounting and reporting of financial assets and liabilities. IFRS 9 replaces IAS 39 with a unified standard. In July 2014, IASB finalized the impairment methodology for financial assets and commitments. The mandatory effective date for implementation is January 1, 2018; however, the standard is available for early adoption (e.g., via local endorsement procedures).

IFRS 9 introduces changes across three areas with profound implications for financial institutions:

The classification and measurement of financial assets
The introduction of a new expected-loss impairment framework
The overhaul of hedge accounting models to better align the accounting treatment with risk management activities

Replacing IAS 39 with IFRS 9 will significantly impact banks’ financial statements, the greatest impact being the calculation of impairments:

IAS 39 – A provision is made only when there is a realized impairment. This results in “too little, too late” provisions and does not reflect the underlying economics of the transaction.
IFRS 9 – Aligns the measurement of financial assets with the bank’s business model, contractual cash flow characteristics of instruments, and future economic scenarios. Banks may have to take a “forward-looking provision” for the portion of the loan that is likely to default, as soon as it is originated.

IFRS 9 has also several common characteristics with the Financial Accounting Standards Board’s (FASB) Current Expected Credit Loss (CECL) model provisioning framework to be implemented in the US.

Who will be subject to IFRS 9?

IFRS 9 will be required for financial institutions in Europe, the Middle East, Asia, Africa, and Oceania. Specifically:

Companies listed on EU stock markets and EU banks must use IFRS reporting standards in preparing their consolidated financial statements.
Europe: More than 230 banks (banks of significant importance)
Asia, Americas (excluding the US), Oceania, and Africa will be implementing IFRS either through a local-endorsement process or convergence of the respective country-specific standard.
Asia and the Middle East: More than 370 banks (banks of significant importance)

Institutions in the US will not be subject to IFRS 9 (GAAP is mandatory for those institutions). However, FASB will introduce a similar analytical framework (CECL) if the current proposal is approved under the proposed form without major modifications.

Industry Snapshot: Current State

With all eyes on IFRS 9, Moody’s Analytics carried out our first IFRS 9 survey to help practitioners better understand how their peers are preparing for the implementation. Overall, banks that participated in the survey are accelerating their planning, budgeting processes, and road-mapping activities for full-scale implementation projects, given the finalization of the IFRS 9 standard.