Introduction
Institutional investors manage wealth on behalf of the shareholders and include various types of organizations such as pension funds (defined benefit plans and defined contribution plans), endowments, sovereign wealth funds, insurers, and banks. On a global scale, total investable assets of the institutional investors amount to 70 Trillion U.S. dollars out of which 9 Trillion are the net financial assets held by banks and insurance (Berkelaar, Misic and Stimes, 2020). Insurers perform three functions in the economy including risk-bearing, risk pooling, and financial intermediation. First, the risk-bearing function is when insurers provide mechanisms for individuals and organizations to transfer the risk related to loss of life, health, or loss of property, usually called the underwriting risk, in exchange for a premium. The second function of insurers is that they diversify the risks of the individual policies by pooling them in one portfolio. The third function of the insurers is that they use the funds that they generate from a specialized form of debt contract to purchase financial assets and make a profit from the spread between the assets’ returns and the liabilities’ cost (Cummins, Phillips, Smith, 1997).
Insurers can be either life insurance, property and casualty insurance or a combination thereof. Each of these businesses has its own dynamics in terms of assets and liabilities management. Life insurer can, for instance, underwrite term life insurance that pays death benefits or annuities that pay regular income either immediately or in the future. These types of liabilities are subject to financial and non-financial risks. Financial risk is related to interest rate risk, in the sense that if the interest rate decreases, the liabilities fair value increases (This sensitivity to the interest rate is called duration). Financial risk is also related to liquidity risks which relate to the cash flows from the claims not having enough cash inflows to cover. Non-financial risks of life insurance liabilities, on the other hand, for example, are the exposure of life insurance to mortality risk while annuities are exposed to longevity risk. Overall, life insurance liabilities are usually long term with predictable probabilities. As compared to life insurers, property and casualty (PC) insurers underwrite general liability insurance policies that cover, among others, property, general, engineering, marine, and motors policies. These types of policies, similar to life policies, are exposed to liquidity risk. However, their exposure to interest rate risk is lower as they are usually of the shorter term. Further, these liabilities are less predictable in terms of their severity and probability.
The liabilities of the insurers are not managed in isolation of the related investment assets. They are managed under an asset-liability management framework. Insurers are highly regulated companies and usually have proper internal governance structures. Such a governance structure may require having a dedicated asset-liability committee (ALCO) that is in charge of the management of the investment decisions of the assets and liabilities of the insurer. From an asset-liability management perspective, insurers seek to find an asset portfolio that mimics the performance of the liabilities and ensure managing the liabilities risk exposures such as interest rate, mortality, surrender, lapse, and liquidity. This portfolio can also be called the reserve portfolio as compared to the surplus portfolio. The insurer’s objective is to grow the surplus portfolio to enable better pricing of the new underwritten policies. Mathematically, insurers seek to match the duration of the assets and liabilities. The matching ensures lower equity duration exposure and therefore increases shareholder value. However, the duration is a good measure of sensitivity to the interest rate when the rate changes are small and does not perform a good job if the changes in the interest rate are high due to convexity (convexity is the change in duration due to changes in interest rates) (Cummins et al., 1997 and Berkelaar et al., 2020). As an alternative to duration, Berkelaar et al. (2020) suggest using a mathematical formula that measures the volatility of the equity returns of the insurer by linking it to the following: The volatilities in the assets and liabilities’ returns, the leverage, the change in liabilities’ yield compared to the assets’ yield and the correlation between the assets and liabilities’ returns. The bottom line is that, provided all other variables held constant, the closer the correlation between the assets and the liabilities’ returns is to 1, the lower the volatility of the equity returns. Regardless of the method used to minimize the risk to the shareholders, the management of the risk exposures of the liabilities in terms of assets is an important function that insurers cannot discard.
Tucker, Thompson, Dicks, Kling, Pryde, and Burger (2020) argue that the matching of the assets and liabilities cash flows is called the economic hedge. Economic variables affect the assets differently from how they affect the liabilities, resulting in an economic mismatch. Insurers take risk management strategies that aim at reducing this economic mismatch using for instance derivatives or other financial instruments. However, even with economic matching, the recognition and measurement of the financial instruments used for risk mitigation may be different from the recognition and measurement used for insurance contracts, resulting in accounting mismatch. For instance, derivatives change in fair value is recognized in profit or loss while the underlying asset being hedged by those derivatives may be measured at FVTOCI. This article is intended to discuss the possible solutions to this accounting mismatches from the perspective of the IFRS 9 and IFRS17. The article was inspired by a publication by PwC regarding this subject (see, Tucker et al., 2020).
The article is organized as follows: First, the article discusses hedge accounting under IFRS 9. Second, the article discusses IFRS 17 main topics that are linked to the discussion of hedging. Third, the article discusses the possible options available under IFRS 9 and IFRS 17 to reduce the accounting mismatches under miscellaneous scenarios. Finally, the article concludes with a summary.
IFRS 9 hedge accounting
What is hedging?
Hedging is a risk management strategy that aims to mitigate risks. Financial risks include liquidity, credit, price, foreign exchange, and interest rate risks. To manage these financial risks an entity would need to take a counter-position to protect against the risk exposure in its existing position. For instance, if an entity has a variable-interest liability, the entity is at risk of variable cash outflows. Therefore, the entity can mitigate this risk by entering into a swap contract that pays fixed and receive variable interest. The entity can design the swap contract such that the variable interest received is equal to the variable interest obligation under the liability contract as well as setting the notional amount of the swap contract to equal to the liability amount. Hedging using derivatives requires consideration of the following: the counterparty credit risk if the derivative is over-the-counter or exchange-traded, the premium paid as the cost of entering the contract, and finally to consider if the contract is a right only or a right and obligation. An example of the former is the option contract while an example of the latter is the forward and futures contracts. IFRS 9 is the standard that regulates the financial reporting requirements related to hedging. The objective of the hedge accounting model in IFRS 9 is to present, in the financial statements, the effect of the entity’s risk management activities that use financial instruments to manage risks (BDO, 2014).
What are hedge accounting models?
IAS 39 was dealing with hedge accounting until IFRS 9 hedging rules were implemented. Under IFRS 9 there are two accounting policy choices to make: First, to apply IFRS 9 hedge accounting rules in full. Second, to apply IAS 39 hedge accounting rules in full and consider the nuances applied by IFRS 9 and not by IAS 39. If one elected to implement IFRS 9 in full, then IAS 39 rules related to fair value interest rate macro hedging model can be also applied. In clarifying the macro hedge accounting model, BDO (2014) indicate that there are two models for hedge accounting: The first one is the macro hedge accounting model which is usually used by financial institutions. Under this model, the financial institution manages interest rate risk exposure of the portfolio of fixed-rate financial assets and liabilities (net position), and the amounts of the hedging instrument and the hedged item change constantly. The second model for hedge accounting is the general model that is applied to either static or dynamic hedging. Static hedging is when the designated volumes of the hedged item and hedging instrument are fixed at initiation and documented, while the dynamic is when delta-hedge is used i.e. when the volumes are altered to increase hedge effectiveness.
Is hedge accounting mandatory and what are the type of hedges under IFRS 9?
Hedge accounting is optional under IFRS 9 and IAS 39. Under both standards, there are three hedges: The fair value, the cash flow, and the foreign operation net hedges. Basically, a fair value hedge is applicable to hedging of existing assets or liabilities or an unrecognized firm commitment. The cash flow hedge applies to the hedge of existing assets or liabilities and to highly probable forecast transactions. Net foreign operation hedge applies to hedging of florigen currency exposure in a parent net investment in a foreign subsidiary. In general, the fair value changes of the hedged item and hedging instrument are recognized in profit or loss under the fair value hedge. Under cash flow hedge, for the effective portion of the hedge, the fair value changes of the hedging instrument are recognized in OCI and released to profit or loss in the same period or periods the underlying asset or liability are recognized in profit or loss. The same treatment of the cash flow hedge applies for hedging of the net investment in a foreign subsidiary.
How does the hedge operate from IFRS 9 point of view?
The basic elements of hedge accounting are to identify three things: First, the hedged item which could be designated as the asset or liability being hedged, the risk component of the asset or liability that is being hedged e.g. interest rate risk of a loan portfolio. The aggregated exposure of an asset or liability with a derivative can also be designated as a hedged item and similarly, an equity instrument classified at FVTOCI can be designated as hedge item when the hedging instrument fair value changes are recognized in OCI as well. The second element of hedge accounting is to identify the hedging instrument which could be a derivative or part of a derivative. The latter includes cases such as designated as a hedging instrument, the intrinsic value of an option contract, the spot rates of a forward contract, and the FX basis spread of the foreign currency swap. The time value of the option, the forward rate of the forward contract and the FX basis spread of the swap are recognized in OCI and amortized later over the term of the hedging relationship. The hedging instrument can also be a financial asset or liability measured at FVTPL (exception is the financial liabilities that are designated at FVTPL for which changes in fair value are due to the entity’s own credit risk are recognized in OCI). The third element of the hedge accounting is to ensure that a relationship exists between the hedged item and the hedging instrument and that this relationship meets three conditions (Singh, 2018): First, an economic relationship exists between the hedged item and the hedging instrument i.e. the hedged item and the hedging instrument move in the opposite directions in fair value. The second condition is that the credit risk is not a dominant factor in the fair value changes of the hedged item and hedging instrument and finally that the hedge ratio used for risk management purposes is the same as the one used for accounting purposes (Hedge ratio is the percentage of the volume of the hedging instrument used versus the hedged item). This hedge ratio can be rebalanced throughout the life of the hedge if the underlying economic relations change without the need to terminate the hedging relationship (BDO, 2014).
As an additional risk component that can be designated as a hedged item, IFRS 9 allows under specific circumstances to designate inflation risk which was previously prohibited under IAS 39 for such designation. Moreover, financial institutions can designate as FVTPL a loan portfolio as a hedged item for which the bank has designated a credit default swap as the hedging instrument. Thus, reducing the volatility in profit or loss.
The entity applying IFRS 9 hedge accounting, should prepare documentation of the hedging relationship, hedge strategy (high-level documents identifying the risks facing the entity and how risk management activities are to address those risks) and hedge objectives (a hedge level relationship that clarifies the hedging relationship and how a particular hedging instrument is designated to a specific hedged item). (Ernst and Young, 2014).
Is the discontinuation of hedge accounting optional?
There are certain circumstances under which one can cease to apply the hedge accounting including First, a change in the entity risk management objectives, second the hedged item or hedging instrument no longer exist, third there is no longer an economic relationship between the hedged item and hedging instrument, and finally the effect of credit risk starts to dominate the value changes that result from the economic relationship. (BDO, 2014)
What are IFRS 17 important points to remember?
The major change brought by IFRS 17 is the introduction of three approaches for insurance contracts accounting including First, Building Blocks Approach “BBA” or the General Model, mandatory and is applied to all insurance contracts issued except those for which the entity applies either of the VFA or the PAA approaches mentioned below. The second approach is the Variable Fee Approach “VFA”. This approach is mandatory and applies to direct participating contracts where the policyholder is entitled to a significant share of the profit from a clearly identified pool of investment assets (underlying item). Therefore, the liability is measured based on the obligation to pay the policyholder an amount equal to the value of the underlying item net of the investment management fee (Variable fee) charged by the insurance company. The third approach is the Premium Allocation Approach “PAA” which is a simplified form of BBA, optional and is supposed to cover insurance contracts that span over one year or less or for those insurance contracts where the application of PAA approach will not result in Liability of remaining coverage to be materially different from applying the BBA approach.
On initial recognition, an entity shall measure a group of insurance contracts at the total of the fulfillment cash flows (FCF) (includes cash flows for future service of the contract discounted at a current interest rate (PV) and adjusted for non-financial risk (RA)) and contractual service margin (CSM). Subsequent to initial recognition. The liabilities related to the insurance contracts take two forms including First, the liabilities of remaining coverage (LRC) which represents the liability related to unexpired risks (i.e. the insurer liability to service the claims to be raised in the future). The second form is the liability of incurred claims (LIC) which represents the expired risk and includes incurred and reported claims and incurred and not reported claims along with related expenses. What is important in this section of the paragraph, as related to hedging of insurance contracts, is to highlight that the financial risk of the insurance contracts has been considered by the discount rate used in calculating the present value of the FCF. Figure (1) below provide a visual presentation of the insurance contract liabilities under IFRS 17 versus old standards and the position of the cash flows.
According to IFRS 17, the insurance finance income represents the income related to the financial investments and the interest accretion related to the reinsurance contracts. On the other hand, insurance finance expense relates to the accretion of interest on the insurance contract liabilities. Figure (2) below presents an example of how the insurance finance expense and income are presented showing the source of each of them and linking them to each line of business.
According to IFRS 17, the insurance finance income and expenses can be either elected to be recognized to profit or loss or to split them between profit or loss and OCI. The insurer also has a risk mitigation option under the VFA approach wherein the insurer can recognize the changes in the FCF or the changes in the fair value of the underlying asset to profit or loss instead of adjusting the CSM. This latter option is available provided that the insurer has a documented risk strategy and risk management objectives that demonstrate how that the entity mitigates the financial risk using derivatives, financial instruments measured at FVTPL, or reinsurance contracts held. The understanding of the aforementioned options under IFRS 17 is important to see, as discussed subsequently in this article, how they will be employed for hedging without the need for using hedge accounting i.e. avoiding the complex requirement of hedge accounting.
Scenarios of economic risks and economic hedge and the solutions possible under IFRS 9 and IFRS 17
This section provides a tabular description of multiple scenarios that show the economic risk, the economic hedge applied the accounting mismatch, and how it can be solved under options available under IFRS 9 and IFRS 17 along with the benefits and limitations of each solution. This section is heavily dependent on Tucker et al (2020).
Scenario one
Scenario two
Scenario three
Scenario four
Scenario five
Summary
Insurers have many options to mitigate liabilities risks represented by interest rates and cash flows. From an economic perspective, the hedges might match the risk fully or partially due to the influence of other risks on the liability such as inflation, mortality, lapse, and longevity or the mismatch between the fair value and cash flows changes of the insurance contract liabilities and the backing assets. However, economic hedging activities may yield a corresponding accounting mismatch. This is due to differences between the economic matching method used and how those methods are accounted for under IFRS 9 and IFRS 17. Both standards have options available to the preparers to consider. The selection of some combination of these options may be a valuable tool to bridge the gap between economic hedging and hedge accounting. This article discussed the hedge accounting under IFRS 9 and the hedge relevant topics under IFRS 17. Moreover, the article discussed the options available under IFRS 9 and IFRS 17 with regards to multiple scenarios of economic hedging that exhibit an accounting mismatch. The important points to emphasize are that the insurers should be aware of all the options available under both standards and make use of those options to reduce accounting mismatch while keeping their economic risk managed within the context of their risk strategy and risk management objectives. Moreover, planning should better start as early as possible to see what are the current balance sheet exposures and design the proper actions to be implemented that are commensurate with the implementation of the IFRS 17.
Reference
- Berkelaar, A., Misic, K and Stimes, P, C (2020) Portfolio Management for institutional investors, CFA institute refresher reading Level III, p.p. 1-106.
- BDO (2014) Need to know hedge accounting (IFRS 9 Financial Instruments), BDO publications, p.p. 2-53, available at: https://www.swisstreasurer.ch/wp-content/uploads/2015/09/Need-to-Know-Hedge-Accounting-IFRS-9-print.pdf, [accessed on 14 July 2020].
- Cummins, J, D., Phillips, R, D., Smith, S, D (1997) Corporate Hedging in the insurance industry: the use of financial derivatives by U.S. insurers, North American Actuarial Journal 1, p.p. 13-49.
- Ernst and Young (2014) Hedge accounting under IFRS 9, EY publications, available at: Here, [accessed on 14 July 2020].
- Tucker, G., Thompson, S., Dicks, E., Kling, M., Pryde, A., and Burger, G (2020) Minimising accounting mismatches relating to financial risk for insurers, PwC publications, available at: https://www.pwc.com/gx/en/services/audit-assurance/ifrs-reporting/ifrs-17.html, [accessed on 14 July 2020].
- PwC (2019) IFRS 17, Insurance Contracts: An illustration, PwC publications, available at: https://www.pwc.com/id/en/publications/assurance/ifrs-17-insurance-contracts.pdf, [accessed on 15 July 2020].
- Singh, J, P (2018) On hedge effectiveness assessment under IFRS 9, Audit financiar, XVI, Nr. 1(149), p.p. 157-170
- Thompson, S and Di Paola, S (2017) In-depth: Achieving hedge accounting in practice under IFRS 9, PwC publications, available at: https://www.pwc.com/gx/en/audit-services/ifrs/publications/ifrs-9/achieving-hedge-accounting-in-practice-under-ifrs-9.pdf, [accessed on 15 July 2020].