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IFRS 9 Implementation Challenges IFRS 9 Implementation Challenges

IFRS 9 Implementation Challenges - PowerPoint Presentation

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IFRS 9 Implementation Challenges - PPT Presentation

wwwpwciebanking 22 October 2014 Agenda Background to IFRS 9 The project and timetable for implementation Classification and measurement Overview of Expected credit losses in IFRS 9 Implementation ID: 381478

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Slide1

IFRS 9 Implementation Challenges

www.pwc.ie/banking

22 October 2014Slide2

Agenda

Background to IFRS 9: The project and timetable for implementation

Classification and measurementOverview of Expected credit losses in IFRS 9Implementation ChallengesConclusionsSlide 222 October 2014IFRS 9 Implementation ChallengesSlide3

Background to IFRS 9:

The project and timetable for implementation

1Slide 322 October 2014IFRS 9 Implementation ChallengesSlide4

Effective date and transition

Overview

The effective date will be for annual periods starting on or after 1 January 2018.Retrospective application is required except:If on transition application requires undue cost or effort, operational simplifications are provided.No requirement to restate comparatives.Slide 422 October 2014IFRS 9 Implementation ChallengesSlide5

How well are banks positioned currently?

IFRS 9 - current status and emerging practice

Having established an effective date for IFRS 9, banks are taking stock on the impact of IFRS 9 and their approach to implementationEU / EFRAGEmerging PracticeIASBIASB published IFRS 9 on 24 July 2014IFRS 9 is mandatory from

1 January 2018

IFRS 9 needs to be applied in entirety, except for the OCI treatment of OCS of financial liabilities in FVOEarly application is allowed (endorsement required in the EU)

Endorsement process not yet started

EFRAG/EU are currently constituting the respective bodies

Endorsement process not expected to start before the end of 2014

Endorsement process of comprehensive standards such as IFRS 9 usually takes 12 months or longer

The level of effort to date has been mixed

. Most banks have closely followed the development of IFRS 9

Many banks, particularly in Germany, have already conducted high-level impact assessments on IFRS 9 Classification & Measurement and ECL. Many banks are now starting implementation projects.

Others are adopting a wait-and-see approach.

Slide

5

22 October 2014

IFRS 9 Implementation ChallengesSlide6

Classification and measurement

2

Slide 622 October 2014IFRS 9 Implementation ChallengesSlide7

Amortised cost

FV-PL

FV-OCI

Key question is where these lines are drawn.

Amortised cost

Hold to collect; and

Solely payments of principal and interest.

Fair value – OCI

Hold to collect and sell; and

Solely payments of principal and interest.

Fair value – P&L

Residual category.

Classification and measurement of financial assets

Overview of three categories

Slide

7

22 October 2014

IFRS 9 Implementation ChallengesSlide8

Why is classification & measurement important to Expected Credit Loss determination?

Classification

under IFRS 9 for investments in debt instruments is driven by the entity’s business model for managing financial assets and their contractual cash flow characteristics.A financial asset is measured at amortised cost if both of the following criteria are met:The asset is held to collect its contractual cash flows; andThe asset’s contractual cash flows represent ‘solely payments of principal and interest’ (‘SPPI’)Key issues impacting on ECL:Reclassifications of assets and/or portfolios are highly likely to occur, as the criterial for classification & measurement are very different.A single entity can have more than one business model for managing similar financial instruments. For example, an entity can hold one portfolio of mortgages in order to collect contractual cash flows and another portfolio of mortgages (with similar characteristics) that it manages in order to sell/or to realise fair value changes.Classification changes, especially from AC to FVOCI

or FVTPL will directly impact on the determination

ECL

and thus impact regulatory capital.

Slide

8

22 October 2014

IFRS 9 Implementation ChallengesSlide9

Key challenges for IFRS 9 implementation

C&M Considerations

Definition of BM by senior management

Selling decisions with impact on accounting

Processes and systems required to document BM and reasons for sales

Use of existing BM documentation and portfolio structures as starting point

Informing SM about requirements and strategic options (e.g. on transition date)

C

hallenges

Mitigation

SPPI assessment at instrument level

Required information not available

Business units to be included

Improvement

/

implementation of systems

Clustering & use of efficient questionnaires

Training of business units

Business model

Contractual

cash flows

High quality FV needed for (structured) loans

FV needed for modified loans

May result in

P&L

and Equity volatility

Implementation of FV models for loans

Improvement of existing IT systems

Fair value measurement

Availability of

data on transition

Determining opening position impacts

FV

may be needed for loans currently at

amortised

cost

Identify data gaps and capacity of

existing IT systems

Deploy simulation tools to identify and quantify impacts

Develop, build and test FV models for loans

Transitional impacts

Reconciliation between

IAS

39 measurement and

new measurement categories under IFRS 9.

Additional qualitative

and quantitative information

is required to be

disclosed.

Need to communicate clearly to investor base.

Mock up of disclosures

Regular contact with regulators and investors

Potential for national disclosures and / or guidelines

Disclosures

Slide

9

22 October 2014

IFRS 9 Implementation ChallengesSlide10

Overview of Expected credit losses in IFRS 9

3

Slide 1022 October 2014IFRS 9 Implementation ChallengesSlide11

IFRS 9 Expected credit loss model

Scope

Financial assets at amortised cost Financial assets (debt instruments) at FVOCILoan commitmentsFinancial guarantee contractsLease receivables and trade receivables or contract assets Modified financial assetsOverviewIFRS Expected loss model not same as Regulatory EL model (i.e. not TTC).Responsive to changes in information that impact credit expectations.It is inappropriate to recognise full lifetime expected credit losses on initial recognition of financial instruments, except for the simplified approach for trade and lease receivables.Significant increase in credit risk leads to recognition of lifetime losses.

IFRS 9 EL model is data intensive.

Convergence between US GAAP and IFRS has not been achieved.

Slide

11

22 October 2014

IFRS 9 Implementation ChallengesSlide12

Expected credit losses

General model

Effective interest on gross carrying amount12 month expected credit lossesRecognition of expected credit lossesInterest revenueChange in credit quality since initial recognitionStage 1Stage 2

Stage 3

Performing

(Initial recognition*)

Underperforming

(Assets with significant

increase in credit risk since initial recognition*)

Non-performing

(Credit impaired assets)

Effective interest on gross carrying amount

Lifetime expected

credit

losses

Effective interest on amortised cost carrying amount

(

i.e. net of credit allowance)

Lifetime

expected

credit losses

*Except for purchased or originated credit impaired assets

Slide

12

22 October 2014

IFRS 9 Implementation ChallengesSlide13

Expected credit losses

General model

12-month expected credit lossesAre a portion of the lifetime expected credit losses and represent the amount of expected credit losses that result from default events that are possible within

12 months after the reporting date.

Lifetime expected credit losses

The

expected credit losses

that result from all possible default

events over the life of the financial instrument.

Credit loss

The difference between all principal

and interest cash flows that are due to an entity in accordance with the contract and all the cash flows the entity expects to receive discounted

at

the original EIR.

Expected credit losses

The

weighted average of credit losses.

Definitions

Slide

13

22 October 2014

IFRS 9 Implementation ChallengesSlide14

Expected credit losses

General model

Expected credit lossesFinancial assetsECL represent a probability-weighted estimate of the difference over the remaining life of the financial instrument, between:Undrawn loan commitmentsECL represent a probability-weighted estimate of the difference over the remaining life of the financial instrument, between:Present value of cash flows according to contract Present value of cash flows the entity expects to receivePresent value of cash flows if holder draws down

Present value of cash flows the entity expects to receive if drawn down

Slide

14

22 October 2014

IFRS 9 Implementation ChallengesSlide15

Expected credit losses

General model

Assessment of a significant increase in credit risk

Absolute probabilities are not sufficient

Variation between reporting date and initial recognition

Probability of Default

(‘PD’)

12 months unless lifetime assessment is necessary

Counterparty assessment

Maximum

credit risk for a portfolio

Slide

15

22 October 2014

IFRS 9 Implementation ChallengesSlide16

Expected credit losses

General model

Expected credit lossesAn entity’s estimate of expected credit losses must reflect: the best available information.an unbiased and probability-weighted estimate of cash flows associated with a range of possible outcomes (including at least the possibility that a credit loss occurs and the possibility that no credit loss occurs).the time value of money. Various approaches can be used.An entity should apply a default definition that is consistent with internal credit risk management purposes and take into account qualitative indicators of default when appropriate.However…90 days past due rebuttable presumptionSlide 16

22 October 2014

IFRS 9 Implementation ChallengesSlide17

Changes in operating results

Expected

credit lossesGeneral modelChanges in external market indicatorsChanges in credit ratingsChanges in internal price indicatorsChanges in business

Other qualitative inputs

30 days past due rebuttable presumption

However

….

Information to take into account for assessment of increased credit risk

Slide

17

22 October 2014

IFRS 9 Implementation ChallengesSlide18

Expected credit losses

General model

Regulatory PD vs IFRS 9 PDRegulatory PDIFRS 9 PDThrough the cycle(‘TTC’)Point in time(‘PiT’)

Hard to reconcile both!

Slide

18

22 October 2014

IFRS 9 Implementation ChallengesSlide19

Expected credit losses

General model

Discount rate and operational simplificationsDiscount rate for calculating the expected credit lossesEffective interest rate or an approximation thereof.Operational simplificationsLow credit risk: the loss allowance for financial instruments that are deemed low credit risk at the reporting date would continue to be recognised at 12-month ECL.Simplified approach for lease and trade receivablesFor trade receivables or contract assets that do not contain a significant financing component: Relief from calculating 12-month ECL and to assess when a significant increase in credit risk occurred. Lifetime ECL throughout the trade receivable’s life.For lease receivables and trade receivables or contract assets that contain a significant financing component: Accounting policy choice to apply simplified approach to measure loss allowance at lifetime ECL on initial recognition.Slide 1922 October 2014IFRS 9 Implementation ChallengesSlide20

Expected credit losses

Disclosures

QuantitativeQualitative

Reconciliation of opening to closing amounts of loss

allowance showing

key drivers of change

Write

off, recovers and

modifications

Reconciliation of opening to closing amounts of gross carrying amounts showing key drivers of change

Gross carrying amounts per credit risk grade

Inputs, assumptions

and estimation

techniques for estimating ECL

Write

off policies, modification policies and

collateral

Inputs, assumptions and estimation techniques to determine significant increases in credit risk and default

Inputs, assumptions and techniques to determine credit impaired

Slide

20

22 October 2014

IFRS 9 Implementation ChallengesSlide21

Implementation Challenges

4

Slide 2122 October 2014IFRS 9 Implementation ChallengesSlide22

Impairment: Implementation challenges

Components

Implementation challenges

Portfolio segmentation

Determine segmentation

criteria.

Consider existing

models and data availability for various portfolios

Criteria for low credit risk

Transfer criteria

Definition of trigger events

Significant deterioration

in

credit

Maturity

Contractual

term

Vs

behavioral

Consideration of prepayments and others

Expected

loss

modeling

Determination

of

models for 12 month and lifetime expected loss

Discount

rate

Forward looking data

Economic

overlay

Slide

22

22 October 2014

IFRS 9 Implementation ChallengesSlide23

Impairment: Key

considerations

Technical analysis and interpretationModelling assumptions/inputs, validation and outputsDisclosuresGovernanceControls considerations

Lack of comparability / benchmarks

Views of regulators

Others

Slide

23

22 October 2014

IFRS 9 Implementation ChallengesSlide24

Impairment : Models to be developed

Portfolio

coverage (by model)Expected loss – 12 months EL, lifetime ELSignificant deterioration of credit

Important questions

Has the entity appropriately segmented its portfolios?

How

is it determined that

the

various models are appropriate?

How strong is the model governance framework?

Is there a consistent basis for model development, validation and documentation?

Is there an appropriate benchmark?

Slide

24

22 October 2014

IFRS 9 Implementation ChallengesSlide25

Impairment :

Level of modelling

Basic approach (?)A simplified approach to ECL by using management judgment to determine provision rates

Specific issues

How to evaluate that management judgment is accurate and correlated to historical data

Is it acceptable under the standards and with the regulators ?

Intermediate approach (?)

Model PD using simple statistical averages.

LGD assumptions are flat

Loss curves are generated using external benchmarks

Economic forecasts included as a management overlay

Specific issues

Substantiate

economic overlays

Insufficient

details in d

evelopment of PD

Advanced

approach

Robust models to incorporate forecasts of macroeconomic conditions used to adjust loss curves.

Loss curves exist for PD, LGD and EAD and are updated both by internal and external data

Specific issues

Challenging

to explain to senior management and investors

Consistence roll out of economic scenarios

Significant overheads

Basic

Intermediate

Advanced

2

3

1

1

2

3

Slide

25

22 October 2014

IFRS 9 Implementation ChallengesSlide26

Impairment :

Leveraging existing credit infrastructure

Banks will consider leveraging existing infrastructureImproves efficiency and minimise rework Align with regulatory model Leverage internal control frameworkTransfer criteriaSignificant deterioration

Economic overlays

Consider economic forecasts based on past events, current conditions and reasonable forecasts of future events

Term structures

Development of lifetime EL, term structure for PD, LGD and correlation

Specific issues and audit concerns

What is considered as significant credit deterioration ?

How can you demonstrate

consistency?

What are the controls over application of significant deterioration?

How to model life time PD and LGD leveraging on existing regulatory and credit models?

How

to

perform back testing with limited availability of data ?

How to determine what economic overlays to be applied ?

How do you judge and evidence the “right economic conditions” and forecasts of the future?

Slide

26

22 October 2014

IFRS 9 Implementation ChallengesSlide27

Impairment -

Leveraging existing Basel methodologies

IFRS 9Basel IIIPD estimated over 12-month horizon for Stage 1; Lifetime loss calculation for Stages 2 and 3

PD estimates are ‘point-in-time’ measures

Definition of default - may adopt regulatory definitions

Considers forward looking estimates at balance sheet date

12-month PD estimation

PD estimates is mostly based on ‘through-the-cycle’ measures

Regulatory overrides

Routine use of stress testing and scenario

analysis to calibrate

IFRS 9

Basel III

Current LGD

Discount rate should be at effective interest rate

Collateral valuation and disclosures for financial instruments with inherent objective evidence of impairment.

Downturn LGD estimates

Consideration of certain costs and LGD floors

Discount rate based upon weighted average

cost of capital or risk-free rate

Treatment of collateral is subject to detailed rules, haircuts etc

Loss Given

Default

('LGD')

Probability of

Default

('PD')

Slide

27

22 October 2014

IFRS 9 Implementation ChallengesSlide28

Impairment –

Data requirements

Key considerationsHow has firm developed processes to collate data from the other systems?Has finance engaged with other business unit to understand the data impact?

Has

the

firm determined the level of automation required to produce the required disclosures in the financial statements ?

Has

the firm

considered the controls over

systems typically outside the statutory audit ?

How to develop process to maintain and update the newly required qualitative/assumption disclosures ?

How comfortable is the firm with the completeness and accuracy of loan level data?

Identify the new data

requirements

Which systems will the data come from - existing

finance reporting

systems and others

?

Data sourcing from

different systems may not be subject to same level of controls and

governance

Identification of appropriate data from right systems

Slide

28

22 October 2014

IFRS 9 Implementation ChallengesSlide29

Business

model

Business models reflect the impact of the IFRS 9ECL models feedback into other strategic processes (e.g. capital management, pricing, stress testing, etc).SystemsAlignment of risk and finance systems?Remapping of lines and accounts within the general and sub ledgersCommon chart of accounts and data definitions across all parts of the business. Data quality

Single data source at required granularity, with full drill down capability and validation of data

Frequent

testing and maintenance of n

ew data models

Automation of data controls

Process

Fully defined processes for identifying the provisions

and how they relate to the business units,

product pricing and strategy.

New credit risk monitoring processes to incorporate system solution to the generation of

accounting information.

Controls and Governance

Circulation

of management reports in a timely manner

Governance and controls over areas not currently subject to statutory

audit

(e.g. Risk and

regulatory data)

Impairment -

Control and governance considerations

Slide

29

22 October 2014

IFRS 9 Implementation ChallengesSlide30

Conclusions

Slide

3022 October 2014IFRS 9 Implementation ChallengesSlide31

Key challenges for IFRS 9 implementation

Quality of implementation

Systems and data landscapeResources and timingMateriality OverallStrategic decisionsAffected functions

Full transparency of external and internal factors to be able to make the right decisions

C

hallenges

Mitigation

IFRS 9 impacts the whole group: Group Finance,

Risk

, GTO, r

egional finance, legal entities, business units (CB&S

, GTB, PBC,

AWM, NCOU), senior management

Early inclusion of all potentially affected functions

Clear responsibilities, communication and understanding of impacts

IAS 39

burdens

IFRS 9 phrases certain requirements more clearly than IAS 39 (e.g. modifications)

IFRS 9 implementation could be used to solve issues existing under IAS 39

Identification of requirements and chances to improve accounting

Solving overlaps with other requirements (e.g. forbearance, post AQR topics)

Manage “scope creep”

Interactions

with

other projects

Technical overlaps (e.g. with

FinRep

, BCBS239, CRD IV,

IT

projects)

Potential resource conflicts

Unaligned

project time lines

Identification of all technical and content overlaps

Integrated project set

up

Early decisions on interdependencies and leverage

Capital impacts

IFRS 9 impacts the accounting and regulatory capital

Simulations and strategic policy and business choices

Project set up

Project governance

Budgeting & timing (target application date)

Communication and presentation of strategy

Data

Availability and collection of data

Data definitions

Control and assurance environment

Early data gap and quality analysis

Ability to leverage existing data and processes

Slide

31

22 October 2014

IFRS 9 Implementation ChallengesSlide32

Key lessons learned from on-going engagements with our clients

Lessons learned from the implementation projects completed to date:

Simulation of the quantitative impacts is complex but necessary. The data required to run a fully compliant IFRS 9 EL model is considerable. PwC have experience of running our diagnostic Simulation Tool in over 35 banks of different environmental complexity with varying levels of available data.The transfer between buckets is highly judgmental. Banks need to develop practical policies and guidelines to inform these judgements. Identification of data gaps is critical. The EL model is data intensive. Early effort is needed to identify data gaps and then consider practical solutions to collect and control the necessary data; IFRS 9 impacts are pervasive. IFRS 9 impacts on lending, underwriting and pricing, accounting and reporting, capital and return on equity. Potential to release synergies and efficiencies. It may be possible to leverage existing credit risk methodologies and processes to comply with IFRS 9 requirements without incurring undue cost or effort. Implementation needs to be controlled. PwC

has in-depth IFRS 9 project

management experience and skills, including role allocation and issue resolution experience. We can help you ensure implementation is controlled and achieved in an orderly and efficient manner.

IFRS 9 is of strategic importance.

The strategic impacts of IFRS 9 can be considerable and therefore it is important to understand the impact on the banks business and plan potential responses.

Slide

32

22 October 2014

IFRS 9 Implementation ChallengesSlide33

Questions?

Slide 33

22 October 2014IFRS 9 Implementation ChallengesSlide34

This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PwC does not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.

© 2014 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.

Thank you for your attentionJohn KellySenior Manager, Banking & Capital MarketsT: +353 (1) 792 8903M: +353 (87) 244 0162john.j.kelly@ie.pwc.com