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Compatibility of IFRS and Compatibility of IFRS and

Compatibility of IFRS and - PowerPoint Presentation

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Compatibility of IFRS and - PPT Presentation

R egulation D e al ing with L oan L oss P rovisioning Presentation for the seminar CREDIT RISK MANAGEMENT AND REGULATORY PROVISIONING IN AN IFRS ENVIRONMENT ID: 461151

100 regulation regulatory provisioning regulation 100 provisioning regulatory ifrs profit accounting year due bank 1000 npv compulsory prudential 5000 npl reporting banking

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Slide1

Compatibility of IFRS and Regulation Dealing with Loan Loss Provisioning

Presentation for the seminar: CREDIT RISK MANAGEMENT AND REGULATORY PROVISIONING IN AN IFRS ENVIRONMENT

Vienna

,

October

21, 2014Slide2

Regulatory Framework for NPL Recognition and Provisioning – the Case of CroatiaSlide3

Run-up to Crisisthe Croatian National Bank traditionally applies a wide array of prudential regulation established through subordinate legislation (“decisions”)signed by the governor; the adherence of banks to the decisions is supervised by the banking supervision departmentsprudential regulation is created based on experience with the 1998-2000

crisis, when a significant part of the banking system collapsed or was bailed out through massive and extremely costly government supportthat situation created public and political awareness about risks associated with banking operations

in the 2000-2006

period

, due to positive market development

s

and consistent regulation, bank portfolios were mopped up from

the

crisis impact: NPLs decreased below 5%

,

and they were

provisioned for

by 60%

the

effects of prudential regulation improved

due to

active application of macro-prudential measures Slide4

Regulatory Framework the Accounting Act – introduces IFRS as standard accounting practice in Croatia (especially for banks)the Credit Institutions Act & the Act on the Croatian National Bank – give supervisory and regulatory powers to the CNB the Decision on the Classification of Placements and Off Balance Sheet Liabilities

– creates operational framework for supervision and accounting of credit riskSlide5

Basic Accounting & Prudential Framework before 2013NPL definition:non-collateralised: 90 days past duecollateralised: loans which will not be fully recovered, depending on the estimation of cash flows, but at the latest two years after taking legal actions by activating collateral

provisioning based on IAS 39 modified by:compulsory classification as NPL (with at least minimal provisions) 90 days past due if no legal action was taken30% compulsory

provisioning

two years after legal action

was taken to collect the loan

for non-collateralised loans prescribed provisioning depending on past-due time buckets:

90 – 180 days past due, up to 30%

180 – 270 days past due, 30% up to 70%

270 – 365 days past due, 70% up to 100%

more than 365 days past due, 100%

the

interest on NPLs

is recognised only if

collected

(not based on accrual)Slide6

Dynamics of NPL and Provision Coverage 2005-2014decrease of coverage is the consequence of inflow of fresh, low provisioned NPLs, but also of sometimes quite imaginative

and very brave collection planson-site examination was used as an auxiliary tool with some success; the majority of coverage increase in 2011 and 2012 was its contribution; active resistance of banks to risk recognition created extremely high workload for both staff and management of the CNB

the l

ack of standard NPL definition increased the problem, as banks claimed that our NPL definition is stricter than in other jurisdictions, so coverage rates are not comparable

From 2007

until 2010

NPL

coverage

radically

decreased

in spite of stable regulation.

As coverage stagnated subsequently, in 2012 it became obvious that prudential regulation isn’t getting proper traction. Slide7

Comparative Dynamics ISource: IMF, FSI TablesSlide8

Comparative Dynamics IISource: IMF, FSI TablesSlide9

Issues Notedmajor weaknesses recognized in accounting practices were:30% provisioning was required two years after taking legal action to collect the loan; to avoid it, banks simply didn’t take legal action (initiate foreclosure)after 30% provisioning no additional provisioning was compulsory in spite of process duration and complexity“

running two year gap” – cash flow from collateral was always expected two years from now; typical IAS 39 based evaluation was based on the best case scenario; in supervised banks all estimates of time and sale price of real estate collateral proved drastically wrong

in evaluation,

the

real estate value is average of

the following

three

components

: market value, replacement value and present value

;

m

arket value was based on the last known similar transaction (frequently before 2008)discontinued projects were evaluated as completed auditors confirmed everything, providing that it could technically be presented under IFRS frameworkfindings of on-site examinations and shareholders' reactions to these findings made obvious that the management and the owners jointly pursue a strategy of optimistic valuation and that auditors are ready to support itSlide10

Change of Regulation in 2013 amendments to the Decision on the classification of placements were adoptedthose amendments made the following changes:compulsory provisioning was regulated in detail:compulsory 10% provisioning 90 days past due (delinquency), if no collateral was activated

compulsory 20% provisioning one year after delinquency, if adequate collateral was not activatedcompulsory 30% provisioning two years after delinquency, regardless of legal action taken to activate a collateral;after accounting for 30%, each 6 months an additional 5%

compulsory provisioning

minimum of 1% provisions was established for NPLs

regulation of restructured loans (how to treat them after restructuring, criteria for their rehabilitation into performing loans)

compulsory minimum haircuts and collection periods

were introduced for real estate and movable property

consecutive compulsory provisions (10%, 20%, 30%) were aimed

at

motivat

ing

banks to timely start foreclosure, while the additional 5% provisioning was a kind of “lump sum” correction for all other noticed aberrations from best practice

; others are meant to adjust NPL & forbearance definition to the new definition approved by EBA BoS (ITS on supervisory reporting regarding forbearance and non-performing exposures)Slide11

Impact of Regulationthe introduction of the Decision amendments was designed to have full accounting impact by end-2013the consequences were obvious:the cost of provisioning increased from 4 to 6 billion kuna – roughly for 0,5% of total assets, reaching 89% of operational results

the coverage of NPLs by value adjustments increased from 42,6% to 46,2%but:the banking system remained overall

profitable

workout

operations and sale of NPLs

intensified

banks’ overall and operational results in 1H2014 improved significantly compared with

the

same period last year in spite of stricter regulationSlide12

International Financial Reporting Standards (IFRS) and Prudential RegulationSlide13

IFRSIFRS offer standardised reporting framework they facilitate transparency of markets and comparability of different investment opportunitiesthe optimal allocation of capital depends on proper application of IFRS

The valuation of certain asset classes under IFRS is sensitive to assumptions appliedSlide14

When Arbitrary decisions influence IFRS reports?core portfolios, such as performing loans and all positions created through arms length transactions are evaluated based on “pure” IFRSprudential regulation interferes only with “marginal” high risk portfolios: NPL & problem loans, litigations, regulatory breaches and deviations from good corporate governance

the valuation of such positions is based on subjective judgment about future outcome. the implementation of prudential standards limits subjective judgment, increasing comparability of banks’ accountsprudential reports will materially deviate from IFRS reporting only if the bank has a very risky business profile

.

Reporting is the

responsibility

of the

management

. If they find

the

regulatory requirements misleading, they

should adjust

the regulatory reporting through a “

statement of differences” for tax and shareholders reporting purposes. Slide15

Preconditions for IFRS Effectivenessthe precondition for accurate accounting is an active supervision of management reporting by shareholders motivated to recognize the real value of their assetsin banking, regulation could strongly

influence the rational behavior of shareholders, making them more relaxed toward overvaluation of bank’s assetsIn certain circumstances rational shareholders would

motivate

management and auditors

to apply

optimistic assumptions

in valuation of bank’s assets. If so, IFRS lo

o

se its major purpose – providing comparable accountsSlide16

Shareholders’ Benefits from Optimistic Valuationif an institution is close to a regulatory minimum, rational shareholders would attempt to fulfill

the regulatory requirement with “ghost capital”. the “ghost capital” created through optimistic valuation would improve regulatory compliance and, due to avoidance of dilution, (modeled in appendix), increase the expected RoE

; a

dditionally, it would create immediate material benefits for managers

without regulatory interference, such a

strategy is financially superior

to prudent accounting

in

extreme cases

such motivation did create “

moral hazard

without effective regulatory checks an obvious temptation does exist; to increase the robustness of the system, the regulation should establish the minimum required level of prudenceIAS 39 offers the possibility to increase the capital buffer through

an

optimistic valuation of NPL/problem loans. Slide17

Protecting Public Interestprudent bank accounting protects the key public interest because:banking is a critical infrastructure of the economy and its robustness depends on proper

accountingin several countries banks’ managers recently acted as “fiscal agents”, effectively ruining or at least hampering the fiscal positionproperly acting supervisors/regulators decrease fiscal risks and improve the

financial stability

Historical

l

y,

financial impact

of too

optimistic

banking

accounting

is obvious and significant, most likely

exceeding any potential adverse impact of prudential regulation Slide18

Conclusiondoes prudential regulation distort financial reporting to the level hampering transparency of financial markets?we argue that, banks’ management, shareholders and auditors have common incentive to use “income smoothing”, achieved through optimistic discretion within IFRS framework; incentives strengthen if bank approaches the regulatory limits

by limiting such behavior banking regulation improves comparability of accountsbanks’management has tools to rectify the requirements of prudential regulation in reporting to shareholdersprudential regulation is public and transparent, so it can’t distort public information; anyway, if distortion appears, its potential adverse effect is only speculative and obviously smaller than potential effects of improper banking accounting

IFRS shouldn’t be a straightjacket for banking regulation.

Their

subjective elements open a possibility for the banks to overestimate capital, potentialy creating a significant fiscal impact! Slide19

Thank you for your attention!Slide20

AppendixSlide21

Comparative NPV – Retained EarningsYear 0

Bank has regulatory capital 100 and annual AT profit 10.

Bank has 100 shares.

Discounting factor for calculation of NPV is 5%

All profit goes to retained earnings.

prudent accounting

 

 

 

optimistic accounting

profit AT

Equity

profit

per

share

NPV

profit AT

Equity

profit per share

NPV

0

-50,00

100,00

-0,5000

0

10,00

110,00

0,1000

1

11,00

111,00

0,0550

1

10,00

120,00

0,1000

2

11,22

122,22

0,0561

2

10,20

130,20

0,1020

3

11,44

133,66

0,0572

3

10,40

140,60

0,1040

4

11,67

145,34

0,0584

4

10,61

151,22

0,1061

5

11,91

157,24

0,0595

5

-50,00

101,22

-0,5000

 

 

 

 

 

 

 

 

Stock price

 

1,1907

0,9329

Stock price

 

2,1620

1,6940

Scenario:

Scenario:

In year 0 due to increased risk

No recognized risks in year 0

recognized one off provisioning

Loss recognized in year 5 and covered from reserves

cost 60 creating loss 50.

Loss is covered from existent

equity.

Capital shortage was covered

through public issuance of shares.

Fresh capital increased profit for 1

Stock price in year 6 is 20 *PPS (profit per share adjusted for one-off items)Slide22

Comparative NPV – Dividend PayoutYear 0

Bank has regulatory capital 100 and annual AT profit 10.

Bank has 100 shares.

Discounting factor for calculation of NPV is 5%

All profit goes to dividend.

prudent accounting

optimistic accounting

profit AT

Equity

profit per share

dividend

NPV

profit AT

Equity

profit per share

dividend

NPV

0

-50,00

100,00

-0,5000

0,0000

0,0000

0

10,00

100,00

0,1000

0,1000

0,1000

1

11,00

100,00

0,0550

0,5000

0,0524

1

10,00

100,00

0,1000

0,1000

0,0952

2

11,00

100,00

0,0550

0,5000

0,0499

2

10,00

100,00

0,0980

0,1000

0,0889

3

11,00

100,00

0,0550

0,5000

0,0475

3

10,00

100,00

0,0980

0,1000

0,0847

4

11,00

100,00

0,0550

0,5000

0,0452

4

10,00

100,00

0,0980

0,1000

0,0806

5

11,00

100,00

0,0550

0,5000

0,0431

5

-50,00

100,00

-0,5000

-0,5000

-0,3918

 

 

 

 

 

0,2381

 

 

 

 

 

0,0576

Stock price

 

1,1000

 

0,8619

Stock price

 

2,0000

 

1,5671

NPV CF

1,1000

NPV CF

1,6247

Scenario:

Scenario:

In year 0 due to increased risk

No recognized risks in year 0

recognized one off provisioning

Loss recognized in year 5 and covered by shareholders

cost 60 creating loss 50.

Loss is covered from existent

equity.

Capital shortage was covered

through public issuance of shares.

Fresh capital increased profit for 1

Stock price in year 6 is 20 *PPSSlide23

BibliographyVincent Bouvatier, Laetitia Lepetity

, Frank Strobelz “Bank income smoothing, ownership concentration and the regulatory environment”; November 19, 2013

Laeven

, L., Levine, R., “Bank governance, regulation and risk taking”., Journal of Financial Economics 93, 259.275. 2009.

Morgan, D. “Rating banks: risk and uncertainty in an opaque industry.”, The American Economic Review 92, 874.888. ., 2002

Chen, Linda H., Income Smoothing, Information Uncertainty, Stock Returns, and Cost of Equity (October 1, 2012). Review of Pacific Basin Financial Markets and Policies (RPBFMP),

Chen, Tai-Yuan and Chin, Chen-lung and Wang,

Shiheng

and Yao, Chun, The Effect of Mandatory IFRS Adoption on Bank Loan Contracting (January 8, 2013). Available at SSRN:

http://ssrn.com/abstract=2159001

Calomiris

, Charles

W , Haber, Stephen H.”Fragile by Design”, Princeton University Press, (2014),ISBN 978-0-691-15524-1