Wednesday, October 4, 2017

New hedging standard - Nonfinancial Hedges

For cash flow hedges of nonfinancial items, an entity may designate the variability in cash flows attributable to changes in a contractually specified component as the hedged risk. This would be good news for manufacturers who buy raw materials and lock in the prices with derivatives.

Current GAAP: Total-Price-Risk Hedge·        Except for foreign exchange risk, an entity is prohibited from designating changes in fair value or cash flows of a component of a nonfinancial item as the hedged risk. For example, if an entity wants to hedge the price risk related to the forecasted purchase or sale of a commodity, it is required to designate changes in the total price of the commodity as the hedged risk.
·        Because derivative instruments are often only available at the component level, the total-price-risk hedge results in hedge ineffectiveness being recorded in current period earnings.
·        Portfolio hedging of commodities on a total-price-risk basis is extremely challenging, particularly for situations in which an entity has suppliers for the same commodity in various locations. Although the contracts are priced based on the same traded commodity, the basis differentials related to the location and/or the grade of the commodity involved (e.g., transportation costs, quality, supply and demand) often create too much variability on a total-price-risk basis to enable an entity to hedge these forecasted purchases on a portfolio basis. As a result, many entities choose not to hedge at all because of the cost and effort of separately hedging each contract from each supplier.
New Standard: Specific Risk Component Hedge·        An entity may designate the variability in cash flows attributable to changes in a contractually specified component as the hedged risk for cash flow hedges of nonfinancial items (e.g., forecasted purchase or sale of a nonfinancial item).
·        This avoids the hedge ineffectiveness that results from basis differentials because the entity could hedge just the portion of the purchase that is linked to a base price or market index (e.g., New York Mercantile Exchange or the London Metals Exchange) for which there is a matching derivative that would create the “perfect hedge.”
·        For portfolio hedging of commodities, an entity would more easily be able to designate the variability in cash flows attributable to changes in a contractually specified component from multiple suppliers as the hedged risk, which would potentially reduce the entity’s costs and more closely align hedge accounting with its risk management activities.
·        An entity is even allowed to apply cash flow hedge accounting to a not-yet-existing contract (that is, beyond the contractual period during which the nonfinancial items are expected to be sold or purchased) as long as the requirements in paragraph 815-20-25-22A will be met in the future contract and all other requirements for cash flow hedge accounting are met.

815-20-25-22AIf the price for the purchase or sale of a nonfinancial asset includes a contractually specified component, the variability in cash flows attributable to changes in that component may be designated as the hedged risk in a cash flow hedge if all of the following are met:
a.      The purchase or sale contract for the nonfinancial asset creates an exposure related to the variability in cash flows attributable to changes in the contractually specified component throughout the life of the hedging relationship.
1.      If the variability in cash flows attributable to changes in the contractually specified component of the hedged forecasted transaction is limited by a cap or floor, an entity may designate a derivative as the hedging instrument that does not have a limited exposure to the contractually specified component risk. However, to make that designation, the entity shall establish that the hedging relationship is expected to be highly effective in achieving offsetting changes in cash flows attributable to changes in the contractually specified component during the period in which the hedging relationship is designated in accordance with paragraph 815-20-25-75.
b.     The stated components of the price of the nonfinancial contract all relate to the cost of purchasing or selling the nonfinancial asset in the normal course of business in a particular market. The following are examples of items that may be individually stated price components or aggregated to form a single stated price component:
1.      Transportation costs
2.      Labor costs
3.      Quality or grade differentials between the hedged component and standard market prices that are quoted in purchases or sales contracts for the nonfinancial asset in the normal course of business
4.      Local supply and demand factors for the purchase or sale of the nonfinancial asset in the normal course of business.
c.      All of the stated components of the price of the nonfinancial contract reflect market conditions at contract inception. For example, labor costs stated in the contract are in line with local markets, and transportation costs reflect market conditions for the distance between the supplier and the customer.
Source:Proposed Accounting Standards Update—Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging ActivitiesFASB in FocusTentative Board Decisions Reached to Date (as of June 7, 2017)Need to Know: The Upcoming Hedging Standard

Thursday, September 7, 2017

FASB Issues New Hedging Standard

On August 29, 2017, the FASB issued a final ASU that will improve and simplify accounting rules around hedge accounting. The ASU is effective for public companies in 2019 and private companies in 2020. Early adoption is permitted in any interim period or fiscal years before the effective date of the standard (i.e., as early as in the current quarter, Q3’17).

Monday, August 21, 2017

New hedging standard - Benchmark Interest Rates

Under the current guidance [ASC 815], companies are limited to hedging the following benchmark interest rates only:

·         Interest rates on direct Treasury obligations of the U.S. government (the U.S. Treasury Rate)
·         London Interbank Offered Rate (LIBOR) Swap Rate
·         Fed Funds Effective Swap Rate (also referred to as the Overnight Index Swap Rate or OIS)

The new hedging standard will newly allow i) any contractually specified interest rates and ii) Securities Industry and Financial Markets Association (SIFMA) Municipal Swap Rate to be designated as the hedged interest rate risk.

i) Cash flow hedges of variable-rate financial instruments

·         The concept of benchmark interest rate will be eliminated.
·         An entity may designate any contractually specified interest rate as the hedged risk in cash flow hedges of interest rate risk. For example, a bank could hedge the variability in cash flows of a variable-rate loan based on its own prime rate as long as the rate is contractually specified in the loan.
·         An entity may designate as the hedged risk only the change in cash flows of the contractually specified interest rate index, not an implied rate embedded in the interest rate index. For example, if an entity issues variable-rate debt based on its own prime rate, it cannot designate the change in cash flows of the Fed Funds Target rate or the Wall Street Journal prime rate as the hedged risk.

ii) Fair value hedges of fixed-rate financial instruments

·         The concept and definition of the term benchmark interest rate and list of the current eligible benchmark interest rates (see above) is retained.
·         The SIFMA Municipal Swap Rate is added to the list of permissible benchmark rates, which would allow an entity that issues or invests in fixed-rate tax-exempt financial instruments to designate as the hedged risk changes in fair value attributable to interest rate risk related to the SIFMA Municipal Swap Rate rather than overall changes in fair value.
·         SIFMA is the average rate at which high-credit-quality U.S. municipalities may obtain short-term financing and currently is the predominant rate referenced in issuances of variable-rate municipal bonds. For that reason, the FASB believes that it should be considered a benchmark rate.

·         If an entity modifies a tax-exempt financial instrument’s hedged risk from total price risk to interest rate risk related to the SIFMA Municipal Swap Rate, the modification would be considered a dedesignation and immediate redesignation of the hedging relationship. In this situation, the cumulative basis adjustment of the hedged item from the dedesignated hedging relationship would be amortized to earnings over the remaining life of the hedged item on a level-yield basis.

Heads-up: New hedging standard coming your way

During the third quarter of 2017, the Financial Accounting Standards Board (FASB) is expected to issue a new standard that will improve and simplify hedge accounting. The new standard will take effect for public companies in 2019 and private companies in 2020. Early adoption will be permitted upon issuance. Companies may want to evaluate whether the early adoption is feasible and the benefit of applying the new guidance (even those that do not currently apply hedge accounting).

The new guidance will:

·         Expand hedge accounting for nonfinancial and financial risk components to allow entities to qualify for hedge accounting for more of their risk management activities;
·         Decrease the complexity of preparing and understanding hedge results by eliminating the separate measurement and reporting of hedge ineffectiveness;
·         Enhance transparency, comparability, and understandability of hedge results through enhanced disclosures and changing the presentation of hedge results to align the effects of the hedging instrument and the hedged item; and
·         Reduce the cost and complexity of applying hedge accounting by simplifying the way assessments of hedge effectiveness may be performed.

The new standard will include a number of changes that will impact all areas of hedge accounting, including (but not limited to) financial and nonfinancial hedges, the timing of documentation, effectiveness testing, and presentation and disclosure. Summarized below are some of the key changes:

·         Benchmark Interest Rates
·         Nonfinancial Hedges
·         Recognition and Presentation of Changes in the Fair Value of Hedging Instruments
·         Fair Value Hedges of Interest Rate Risk
·         Shortcut Method and Critical Terms Match (CTM) Method
·         Documentation and Effectiveness Testing
·         Disclosures
·         Transition