Hedging As amended by ASU 2017-12 Handbook US GAAP September 2018 kpmg.com/us/frv Contents Foreword ...................................................................................................... 1 About this publication .................................................................................. 2 1. Executive summary ........................................................................... 4 2. General hedging requirements .......................................................... 14 3. Qualifying criteria for fair value hedges ............................................. 155 4. Accounting for fair value hedges ....................................................... 211 5. Qualifying criteria for cash flow hedges ............................................ 293 6. Accounting for cash flow hedges ...................................................... 379 7. Hedging foreign currency exposures ................................................ 479 8. Net investment hedges ..................................................................... 595 9. Hedge effectiveness ......................................................................... 642 10. Private companies ............................................................................. 843 11. Effective dates and transition ............................................................ 865 Appendices .................................................................................................. 897 Index of Q&As ................................................................................... 897 Index of examples ............................................................................. 919 KPMG Financial Reporting View .................................................................. 927 Acknowledgments ....................................................................................... 928 © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 1 Foreword Perspectives on a complex area When the first comprehensive hedge accounting guidance was issued in 1998, the accounting requirements in this area were widely acknowledged as the most detailed and complex in US GAAP. Since then, we have seen ongoing changes made to the requirements. For a long time, the changes added to the rules and complexity. But more recently, the changes have been focused on reducing operational burden, expanding the use of hedge accounting and better reflecting risk management practices. Throughout all of these changes, one constant has been that hedge accounting itself has remained optional. Even after electing to apply hedge accounting, optionality has been a hallmark of the underlying accounting requirements. The guidance in this area has always included various alternatives for different strategies and methods for aspects such as measuring and assessing hedging relationships – and now those options have expanded. Our objective with this publication is to help you focus effectively and efficiently on the hedge accounting alternatives and requirements. We provide you with insights, examples and perspectives based on our years of experience in this area – so you can understand your options and decide which alternatives are right for you. Kimber Bascom and Mark Northan Department of Professional Practice, KPMG LLP © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 2 About this publication About this publication The purpose of this Handbook is to assist you in understanding the new hedging standard following the targeting improvements issued in August 2017. Accounting literature and scope This Handbook focuses on hedge accounting under ASC 815, Derivatives and Hedging, as amended by Accounting Standards Update No. 2017-12, Targeted Improvements to Accounting for Hedging Activities, which was issued in August 2017 and first becomes effective in 2019. The scope of ASC 815 (including the definition of a derivative) and embedded derivatives will be addressed in future updates to this Handbook. In the meantime, guidance on these topics is included in KPMG’s publication, Derivatives and hedging (pre-ASU 2017-02), which provides guidance for entities that have not yet adopted 2017-12. In addition, KPMG’s publication on the targeted improvements to hedge accounting under ASU 2017-12 provides a focused discussion of the specific amendments in the ASU. Organization of the text Each chapter of this Handbook includes excerpts from FASB’s Accounting Standards Codification® and overviews of the relevant requirements. Our in- depth guidance is explained through Q&As that reflect the questions we are encountering in practice. We include observations and examples to explain key concepts. Our commentary is referenced to the Codification and to other literature, where applicable. The following are examples. — 815-20-25-3 is paragraph 25-3 of ASC Subtopic 815-20. — ASU 2017-12.BC148 is paragraph 148 of the basis for conclusions to ASU 2017-12. — FAS 133.BC423 is paragraph 423 of the basis for conclusions to FASB’s Statements of Financial Accounting Standards No. 133, Accounting for Derivative Instruments and Hedging Activities. — DIG Issue is in relation to the Derivative Implementation Group — 2006 AICPA Conf is the 2006 AICPA National Conference on Current SEC and PCAOB Developments. These references are hyperlinked to the source material on the SEC’s website. © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 3 About this publication Pending content In some cases, the Codification is subject to content that becomes effective after ASU 2017-12. For example, ASU 2016-13, Financial Instruments—Credit Losses (Topic 326), includes consequential amendments to Topic 815. When an excerpt from the Codification is affected by pending content: — the specific sentences that have been superseded are struck out and the added text is underlined; and — the amended sentences are marked as pending content. Future developments As more people turn their attention to the application of the new hedging standard, more questions are arising and the interpretations of the principles in the standard continue to evolve. This means that some positions may change, and positions on new issues will emerge, as we get closer to implementation. For the Questions in this Handbook where we are aware of ongoing discussions and the potential for a position to change, we have indicated that in our interpretive response. In addition, the FASB is currently working on a project to provide further guidance on when an entity would be able to change the hedged risk and/or the hedged forecasted transaction when the guidance on cash flows hedging is applied. This project has the potential to significantly impact our guidance for cash flow hedges. Currently the FASB is collecting external feedback related to this project. Summaries of the potential Codification improvements discussed at the March 2018 Board meeting are included in chapters 2, 5 and 6 (see Future Developments). Abbreviations We use the following abbreviations in this Handbook. AFS Available-for-sale AOCI Accumulated other comprehensive income CTA Cumulative translation adjustment DIG Derivatives Implementation Group FCD Foreign currency denominated HTM Held-to-maturity LIBOR London Interbank Offered Rate NYMEX New York Mercantile Exchange OCI Other comprehensive income PEH Perfectively effective hypothetical (derivative) SIFMA Securities Industry and Financial Markets Association © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 4 1.Executive summary 1. Executive summary Topic 815 provides guidance on accounting for derivative instruments and hedging activities. Derivative instruments are assets or liabilities that are recorded on the balance sheet at fair value. If the derivative instrument does not qualify for hedge accounting, changes in fair value are recorded in earnings. Hedge accounting is designed to allow an entity to hedge risks inherent in certain transactions by using derivative instruments. It is elective and subject to several criteria. If a hedging relationship meets these criteria, the accounting varies based on the type of risk(s) being hedged and the type of hedge. Topic 815 provides for three different types of hedges. Fair value hedge. A hedge of the exposure to changes in the fair value of a recognized asset or liability, or of an unrecognized firm commitment, that is attributable to a particular risk. Cash flow hedge. A hedge of the exposure to variability in the future cash flows of a recognized asset or liability, or of a forecasted transaction, that is attributable to a particular risk. Net investment hedge. A hedge of the exposure to foreign currency risk of a net investment in a foreign operation. General qualifying criteria Hedge accounting is permitted only if all applicable criteria are met. There are five general criteria that apply to fair value hedges and cash flow hedges, some of which also apply to net investment hedges. Criterion 1 Criterion 2 Criterion 3 Criterion 4 Eligibility of Eligibility of Eligibility of Hedge hedged items hedging hedged risk(s) effectiveness or transactions instruments Criterion 5: Formal documentation There are also specific qualifying criteria based on the type of hedge and the type of risk(s) being hedged. Topic 815 also specifically prohibits certain items and transactions from hedge accounting. If any eligibility criteria cease to be met, the hedging relationship must be discontinued – i.e. hedge dedesignation. Read more: chapter 2 © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 5 1. Executive summary Qualifying criteria for fair value hedges In addition to the general qualifying criteria, Topic 815 specifies certain items, risks and hedging instruments that are eligible to be designated in a fair value hedge. Criterion 1: Items eligible for fair value hedges Only recognized assets or liabilities, or unrecognized firm commitments, are eligible to be designated as the hedged item in a fair value hedge. Topic 815 allows different strategies when hedging certain risks. Individual recognized assets and Firm commitments liabilities Portfolios of similar assets and liabilities Portion (or percentage) of hedged item Hedging only Partial-term Residual benchmark hedge of Embedded put Last-of-layer value in a interest rate interest rate or call option method lease component risk Criterion 2: Risks eligible for fair value hedges The risks eligible to be designated in a fair value hedge are different for financial and nonfinancial items. Financial items Nonfinancial items Interest Changes in the Not applicable. rate risk benchmark interest rate for recognized fixed- rate financial instruments. Credit Includes: Not applicable. risk — changes in the obligor’s creditworthiness; and — changes in the credit spread over the benchmark interest rate. Foreign — Changes in the related — Changes in the related currency foreign currency foreign currency risk exchange rates. exchange rates if the firm commitment is denominated in a foreign currency. © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 6 1.Executive summary Financial items Nonfinancial items Price risk — Total change in the fair — Total change in the fair value. value. Criterion 3: Hedging instruments eligible for fair value hedges There are no additional eligibility criteria or limitations specific to fair value hedges, other than fair value hedges involving foreign currency risk. Read more: chapter 3 Accounting for fair value hedges The fair value hedge accounting model can change how the hedged item is measured on the balance sheet. Hedged items are subject to other applicable US GAAP – e.g. an asset or liability measured at amortized cost. However, the hedging instrument is measured at fair value with changes in fair value reported in earnings. This creates a mismatch between the measurement of the hedged item and hedging instrument. Fair value hedge accounting allows an entity to measure the hedged item at fair value based on changes in the hedged risk. In general, the fair value hedge accounting model has two main elements. Hedging instrument Hedged item A derivative hedging instrument is Changes in the fair value of the hedged recognized at fair value on the balance item that are attributable to the hedged sheet with changes in fair value risk are recognized as an adjustment to recognized in earnings, other than the amortized cost basis of the hedged amounts related to excluded item. The offsetting entry is a gain or components that are recognized through loss that is recognized in earnings. an amortization approach. The following diagram shows the general accounting and presentation for a highly effective fair value hedge (assuming there are no excluded components). Hedging instrument Hedged item Changes in fair value Gain or loss recognized Change in value attributable to in earnings hedged risk recognized in earnings Income statement presentation Recorded in the same income statement line item where the earnings effect of the hedged item is presented © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 7 1. Executive summary The effect is to offset gains or losses on the hedging instrument with gains or losses on the hedged item that are attributable to the hedged risk within one line item of the income statement. The adjustment to the amortized cost basis of the hedged item from applying fair value hedge accounting is referred to as a basis adjustment. Basis adjustments are accounted for in the same manner as other components of the amortized cost basis of the hedged item. Read more: chapter 4 Qualifying criteria for cash flow hedges In addition to the general qualifying criteria, Topic 815 specifies certain transactions, risks and hedging instruments that are eligible to be designated in a cash flow hedge. Criterion 1: Transactions eligible for cash flow hedges Cash flows from existing recognized assets or liabilities or forecasted transactions are eligble to be designated as the hedged transaction in a cash flow hedge. Cash flows from existing recognized Forecasted transactions – e.g. forecasted assets and liabilities purchases or sales Group of similar forecasted All-in-one hedge transactions Criterion 2: Risks eligible for cash flow hedges The risks eligible to be designated in a cash flow hedge are different for financial and nonfinancial assets and liabilities. Financial assets and Nonfinancial assets and liabilities liabilities Inter est Eithe r: Not applicable. ra te risk — chan ges in a contractually specified interest rate for variable-rate financial instruments or forecasted issuances or purchases of variable- rate financial instruments; or — changes in the benchmark interest rate for forecasted issuances or purchases of fixed-rate financial instruments. © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Hedging 8 1. Executive summary Financial assets and Nonfinancial assets and liabilities liabilities Cred it Inclu des : Not applicable. ri sk — risk of de fault; — changes in the obligor’s creditworthiness; and — changes in the credit spread over the contractually specified interest rate or the benchmark interest rate. Foreign — Changes in the related — Changes in the related currency foreign currency foreign currency risk exchange rates. exchange rates of foreign currency denominated forecasted transactions or firm commitments. Price risk Total change in the Either: cash flows related to all changes in the the asset or liability – purchase price or sales e.g. all changes in the price of the asset – i.e. purchase price or sales price risk; or price. changes in a contractually specified component – i.e. a component of price risk. Criterion 3: Hedging instruments eligible for cash flow hedges In addition to the general qualifying criteria and limitations of hedging instruments, there are eligibility criteria specific to cash flow hedges. This includes additional requirements that must be met in order to designate a basis swap as the hedging instrument in a cash flow hedge. Read more: chapter 5 Cash flow hedge accounting The cash flow accounting model allows changes in the fair value of the derivative instrument to be recorded in OCI instead of earnings. Hedged transactions are probable future transactions that are not yet recognized on the balance sheet or in earnings. Instead of recognizing the forecasted transaction in advance, cash flow hedge accounting defers the recognition of changes in the fair value of the derivative instrument. In general, the cash flow hedge accounting model works as follows. — A derivative hedging instrument is recorded at fair value in the balance sheet. Changes in its fair value that are included in the assessment of hedge effectiveness are reported in OCI. © 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
Description: