MyCIMA

Accounting should reflect the business model not determine it

Nick Topazio's picture

A post on the FT Alphaville blog on Tuesday September 15 caught my eye ‘How accounting changes can create a world of investment banks’.   Tracy Alloway’s blog refers to a speech by Elizabeth A Duke, governor of the US Federal Reserve Bank, in which the governor raised several concerns with proposals by the IASB and the FASB on accounting for financial instruments.

To recap these proposals, the IASB is suggesting that financial instruments that have basic loan features (payments represent interest and capital) and are managed on a contracted yield basis should be accounted for using the amortised cost model rather than fair value.  Showing that we still have some way to go before US GAAP and IFRS are converged, FASB wants to measure all financial instruments at fair value.  Ms Duke believes that neither of these approaches accurately reflect the traditional commercial banking model and would favour, in her words ‘originate to distribute’ rather than ‘originate and hold’ lending models.

CIMA’s Financial Reporting Development Group considered the IASB proposals earlier this week and concluded that the primary consideration for determining the classification of financial instruments should be the way they are managed.  If the financial instrument is being managed on the basis that it is being held to maturity then the amortised cost model would seem more appropriate than the fair value model.  As I said in my comment on Tracy Alloway’s post ‘it is of key importance that accounting reflects the business model rather than determines it’ and this is equally important outside of the banking sector.

CIMA’s response to the IASB proposals also pointed out that it is important not to lose sight of the historic gain or loss as a key performance measure. The income statement as distinct from the statement of other comprehensive income (OCI) can play an important part here as we believe that only realised gains and losses should be recognised in the income statement. Unrealised gains and losses should be taken to OCI and then recycled to the income statement when realised.

It will be interesting to see how this project proceeds; I just hope that the IASB doesn’t lose sight of the overriding need which is to simplify the accounting for financial instruments.

A principle

PAIB(IFAC) can benefit from the same principle, 'costing (in this case) reflects the business model', Simply put costing refelcts how the business is managed. Best regards Cliff Moggs

Two points

I don't see a huge change arising from the basic loan features proposal, as most bonds and debt instruments (in investment funds in any case) as currently valued at amortised cost anyway - or value them with amortised cost as the best estimate of fair value. I think the wider proposal to eliminate the multiple categories of fair value is a good one though; "basic loan features" seems to be the current held-to-maturity category, and the treatment of instruments currently categorised as available for sale will be simplified under the proposals by just making them FVTP&L. It's interesting to see the suggestion that all unrealised gains or losses go through OCI rather than the income statement, what is your rationale for that?

Unrealised Gains and Losses

The rationale of CIMA's Financial Reporting Development Group for the idea that unrealised gains and losses should go through OCI rather than the income statement stems from a desire to try to separately disclose realised and unrealised items. I think ideally the group would prefer some form of side by side presentation but as this is not likely to be possible they would prefer as many unrealised items as possible to be shown in the OCI initially and then subsequently recycled to the P&L.