Interest Rate Benchmark Reform – Phase 2, Proposed amendments to IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 (the ED) The comment period for the ED
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Issue 172 / July 2020
IFRS Developments
What you need to know
On 25 June 2020, the IASB
held the first of two meetings to discuss the comments received on the phase two ED and tentatively agreed responses to be reflected in the final amendments.At its July meeting
, theIASB plans to complete
redeliberations on the ED. It will discuss feedback on the phase two proposals as they relate to qualifying hedging relationships and hedges of groups of items.The phase two amendments
will address the accounting issues that arise when financial instruments that referenceIBORs transition to alternative
nearly risk free rates.The phase two amendments are
expected to be finalised and published in Q3 or Q4 2020.The proposed effective date is
for annual periods beginning on or after 1 January 2021, but earlier application is permitted.Introduction
On 25 June 2020, the International Accounting Standards Board (IASB or the Board) held its first discussion on the feedback received on the Exposure Draft, Interest Rate Benchmark Reform - Phase 2, Proposed amendments to IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 (the ED). The comment period for the ED closed on 25 May 2020 and, at its June meeting, the IASB considered the analysis of responses to the majority of its questions and tentatively agreed the responses to be included in the final amendments.In this publication, we summarise the
decisions taken by theIASB and provide our views.
Following the decision taken by global regulators to replace Interbank OfferedRates (IBORs) with
alternative nearly risk-free rates (RFRs), in 2018, the IASB commenced work to address the effects of IBOR reform on financial reporting.The IASB divided its work into two phases: Ź Phase one addressed issues affecting financial reporting in the period before
the replacement of an existing interest rate benchmark with an RFR. Ź Phase two is focused on issues that affect financial reporting when an existing
interest rate benchmark is replaced with an RFR. The IASB completed phase one with the publication, in September 2019, of Interest Rate Benchmark Reform, Amendments to IFRS 9, IAS 39 and IFRS 7. In April 2020, the IASB published the ED with a forty-five day comment period. At the June meeting, the IASB tentatively agreed responses to comments on the majority of the questions in the ED. In July, the IASB will discuss comments on the ED's proposals for qualifying hedging relationships and groups of items, and any remaining issues. After the July meeting, the IASB will finish drafting, then publish the phase two amendments in the third or fourth quarters of this year. The IASB will then have completed its project in response to IBOR reform.For the background to the
IASB's project, see our publications, IFRS Developments144 and 145; we describe the phase one amendments in IFRS Developments 152
and summarise the ED in IFRS Developments 165. These publications can be found at www.ey.com/ifrs.IBOR reform: IASB responds to comments on phase two exposure draft2 IBOR reform: IASB responds to comments on phase two exposure draft
1.Modifications of financial assets and
financial liabilities The Board agreed to retain the proposals for modifications required as a direct consequence of IBOR reform, with some minor drafting amendments to ensure the reliefs can be applied as the IASB intended.For such modifications, the ED proposed a
practical expedient to allow contractual changes or changes to cash flows to be treated as changes to a floating interest rate, equivalent to a movement in a market rate of interest. The Board will consider whether 'necessary due to' IBOR reform rather than 'required as a direct consequence of' better reflects the intended scope of the reliefs. To apply the practical expedient, the transition from an IBOR to an RFR should take place on an 'economically equivalent' basis, which the IASB will clarify should be assessed qualitatively rather than quantitatively.2. Amendments to hedging relationships
Some minor amendments were agreed to ensure permitted changes to hedge documentation include all aspects that could be affected by IBOR reform. Clarification was requested by some respondents that on transition from IBOR, a hedged portion could be amended to include the basis spread between the IBOR and RFR which is present at the time the RFR is designated as the hedged risk. The Board considered an example of a loan issued with a rate fixed at 6% when the equivalent IBOR rate was 5% . The entity designated the hedged portion in a fair value hedge, as the coupon cash flows equivalent to 5% plus the principal on the loan. If at the date the hedge designation is changed, IBOR is 4% and the RFR is10 basis points less than IBOR at 3.9%, the entity could change the hedged portion
to the equivalent of 4.9% plus the principal on the fixed rate debt. To ensure this is clear in the final amendments, the Board agreed to include a specific reference to changes to the hedged portion.The Board
responded to the concern that making the changes to hedge documentation 'as and when' the uncertainty arising from IBOR reform is resolved, might not be practicable where large volumes of hedging relationships transition from IBOR to RFRs. Entities will, therefore, have until the end of the reporting period during which the uncertainty for a particular hedging relationship is resolved, to update the hedge documentation.The Board agreed to
clarify the treatment for derivatives that may be replaced rather than modified as a result of IBOR reform, such as those transacted via central clearing houses. Provided the transition from IBOR to RFR satisfies the 'required as a direct consequence of' and 'economically equivalent' principles described above, any corresponding hedging relationships may continue. 3.Designation of risk components and portions
The ED proposed that upon designation of a hedge, provided the entity reasonably expects the RFR risk component to become separately identifiable within the next 24-months, the separately identifiable requirement is deemed to be met.