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Accounting treatment for derivatives

Sunil Talati

The accounting of financial instruments is based on whether those are used for hedging or not. Where they are not used for hedging they could fall under any of the four categories: (i) Financial asset/liability at fair value through profit and loss account (ii) Held-to-maturity investments (iii) Loans and receivables and (iv) Available for sale.

Financial asset/liability at fair value through profit and loss account would generally cover trading items and those that management voluntarily wishes to classify under this category. All the fair value changes in the financial asset/liability are taken to the income statement and consequently the income statement would become highly volatile.

Derivatives would fall under this category, unless they are used for hedging purposes in which case hedge accounting would apply.

Held-to-maturity financial assets are those investments where there is positive intention to hold those assets till the maturity period. They do not include derivatives since they are included in the first category. A financial asset that fulfills the definition of loans and receivables are also not included.

Besides an investment which is otherwise held-to-maturity may be classified voluntarily by the management in the fair value category or available for sale category.

Held-to-maturity investments are accounted for through the effective interest rate method and the consequent gains and losses are recognised in the income statement.

Getting Ready

The markets for derivatives have been remarkable and continued growth over the past decade. This reflects the increasing use of such instruments by business, either for speculation or hedging purposes. Accordingly, the accounting treatment for derivatives and hedging activities has taken on a high degree of importance.

Hedge accounting does not sit well with the standard setters’ desired goal for financial instrument accounting, i.e. a full fair value model. Further, hedge accounting relies on management intent to link for accounting purposes what the standard setters see as two or more separate transactions. It also overrides accounting requirements that would otherwise apply to those transactions when viewed separately.

Standard setters believe that separate accounting is the best way to “tell it as it is”, in other words, to apply the full fair value model. However, the wider financial reporting community could not be persuaded to accept the abolition of hedge accounting. Accounting Standard AS-30 on Financial Instruments-Recognition and Measurement has been issued by the institute as published in January 2008 journal.

This Accounting Standard will become mandatory in respect of accounting period commencing on or after April 1, 2011, for all commercial, industrial and business entities except to a small and medium size entity.

Correspondingly, a limited revision has also been made to AS-11 so as to withdraw the requirements concerning forward exchange contracts from that Standard. ICAI is also in process of formulating a separate Accounting Standard AS-32 on Financial Instruments-Disclosures. As such AS-30 deals with Recognition and Measurement, and AS-32 deals with exclusively on Disclosure.

Hedge Accounting

As required by the standard, on the date of this standard becoming mandatory, an entity should; measure all derivatives at fair value; and eliminate all deferred losses and gains, if any, arising on derivatives that under the previous accounting policy of the entity were reported as assets or liabilities.

Any resulting gain or loss (as adjusted by any related tax expense/benefit) should be adjusted against opening balance of revenue reserves and surplus.

On the date of this standard becoming mandatory, an entity should not reflect in its financial statements a hedging relationship of a type that does not qualify for hedge accounting under this standard (for example, hedging relationships where the hedging instrument is a cash instrument or written option; where the hedged item is a net position; or where the hedge covers interest risk in a held-to-maturity investment). However, if an entity designated a net position as a hedged item under its previous accounting policy, it may designate an individual item within that net position as a hedged item under Accounting Standards, provided that it does so on the date of this standard becoming mandatory.

It, before the date of this standard becoming mandatory, an entity had designated a transaction as a hedge but the hedge does not meet the conditions for hedge accounting in this standard, the entity should apply paragraphs 102 and 112 to discontinue hedge accounting. Transactions entered into before the date of this standard becoming mandatory should not be retrospectively designated as hedges.

Embedded Derivatives

As entity that applies this standard for the first time should assess whether an embedded derivative is required to be separated from the host contract and accounted for as a derivative on the basis of the conditions that existed on the date it first became a party to the contract or on the date on which a reassessment is required by appendix A paragraph A56, whichever is the later date.

Recent Announcement

Notwithstanding the applicability of AS-30, it is very important to understand the impact and effect of this announcement. The announcement on accounting for derivatives issued by ICAI on March 29, 2008, clarifies the best practice treatment to be followed for all derivatives is as follows:

(i) All derivatives except forward contracts covered by AS 11, can be accounted for on the basis of the requirements prescribed in AS 30, Financial Instruments: Recognition and Measurement.

(ii) In case an entity does not follow AS 30, keeping in view the principle of prudence as enunciated in AS 1, ‘Disclosure of Accounting Policies’, the entity is required to provide for losses in respect of all outstanding derivative contracts at the balance sheet date by marking them to market.

The effect of the above announcement is as follows:

(i) In case an entity does not follow AS 30, the losses in respective of derivative contracts at the balance sheet date have to be provided for and disclosed.

(ii) In case an entity follows AS 30, then the effect will be broadly as follows:

In case the derivatives do not meet the hedge accounting criteria as laid down in AS 30, the gains or losses in respect thereof will have to be recognised in the statement of profit and loss. The derivatives will have to be shown as financial assets or financial liabilities on the balance sheet, as the case may be, as per the requirements of the accounting standard.

In case the hedge accounting criteria, e.g., hedge effectiveness, qualifying hedges, documentation etc, as laid down in AS 30 are met, the entity will have to consider, keeping in view the requirements of AS 30, whether the hedge is a fair value hedge or cash flow hedge.

‘Fair value hedge’ and ‘cash flow hedge’ have been explained in AS 30 as follows:

(a) Fair value hedge: A hedge of the exposure to changes in fair value of a recognised asset or liability or an unrecognised firm commitment, or an identified portion of such an asset, liability or firm commitment, that is attributable to a particular risk and could affect profit or loss.

(b) Cash flow hedge: A hedge of the exposure to variability in cash flows that (i) is attributable to a particular risk associated with a recognised asset or liability (such as all or some future interest payments on variable rate debt) or a highly probable forecast transaction and (ii) could affect profit or loss.

As per the standard, a hedge of the foreign currency risk of a firm commitment may be accounted for as a fair value hedge or a cash flow hedge.

Fair value hedges are accounted for as follows:

The gain or loss for re-measuring the derivative hedge instruments at fair value should be recognised in the statement of profit and loss, and

The gain or loss on the hedged items (the underlying) should adjust the carrying amount of the said items and be recognised in the statement of profit and loss.

Cash flow hedges are accounted for as follows:

(i) In case of effective cash flow hedges, the gain or loss on the hedging derivative is recognised directly in an appropriate equity account, say, hedge reserve account (the ineffective hedge portion is recognised in the statement of profit and loss account).

(ii) If a hedge of a forecast transaction subsequently results in the recognition of a financial asset or a financial liability, the associated gains or losses that were recognised directly in the appropriate equity account in accordance should be reclassified into, i.e., recognised in the statement of profit and loss in the same period or periods during which the asset acquired or liability assumed affects profit or loss (such as in the periods that interest income or interest expense is recognised).

(iii) If a hedge of a forecast transaction, subsequently results in the recognition of a non-financial asset or a non-financial liability, or a forecast transaction for a non-financial asset or non-financial liability becomes a firm commitment for which fair value hedge accounting is applied, then the entity should adopt (a) or (b) below:

(a) It reclassifies, i.e., recognises, the associated gains and losses that were recognised directly in the appropriate equity account into the statement of profit and loss in the same period or periods during which the asset acquired or liability assumed affects profit or loss (such as in the periods that depreciation expense or cost of sales is recognised).

(b) It removes the associated gains and losses that were recognised directly in the equity account, and includes them in the initial cost or other carrying amount of the asset or liability.

An entity should adopt either (a) or (b) as its accounting policy and should apply it consistently to all hedges to which (iii) above relates.

(iv) For cash flow hedges, other than those covered by paragraphs (ii) and (iii) above, amounts that had been recognised directly in the equity account should be reclassified into, i.e., recognised in the statement of profit and loss in the same period or periods during which the hedged forecast transaction affects profit or loss (for example, when a forecast sale occurs).

The above is only a summary. For the detailed application, Accounting Standard (AS) 30 should be referred to.

(The author is Past President of ICAI.)

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