Chapter 26
Accounting for Derivatives: A Primer
26.2 Definition of a Derivative
26.4 Embedded Derivative Instruments
(i) Exposures That Qualify for Cash Flow Hedge Accounting
(iii) Prerequisite Requirements
(v) Internal Derivatives Contracts
(iii) Prerequisite Requirements
(c) Hedges of Net Investments in Foreign Operations
(e) Speculative Trades or Trades Not Qualifying for Hedge Accounting
26.7 International Financial Reporting Standards and Derivatives
26.8 Sources and Suggested References
It would be easy for us to dismiss [derivatives] as [investment products] only sophisticated investors use minimizing any impact to our economy.…If we think back to the collapse of Enron, or even farther back to Long-Term Capital Management, we understand how the abuse of derivatives can have a negative impact not only on the parties to the contract, but also on the market and the economy.
—Rep. Richard Neal, D-Mass., chairman of the House Ways and Means Select Revenue Measures Subcommittee, at a March 5 (2008) hearing on tax treatment of derivatives
Originally issued as Financial Accounting Statement (FAS) No. 133, Accounting for Derivative Instruments and Hedging Activities, the rules for accounting for derivatives and hedging transactions are found under the Accounting Standard Codification (ASC) 815, Derivatives and Hedging. This chapter an overview of these rules. It is designed to highlight only the more critical features of the standard, and it may omit relevant guidance for specific situations.
The single inviolate accounting requirement for derivatives is that they must be marked to market and recorded as assets or liabilities on the balance sheet. Beyond that, the accounting treatment will depend on the intended use of the derivative and/or whether specific conditions have been satisfied.
For speculative purposes, derivative gains or losses must be marked to market, and gains or losses are recorded in the current period's income. When hedging exposures associated with the price of an asset, liability, or a firm commitment, accounting for the derivative is the same as it is for speculative uses. In addition, however, the underlying exposure must also be marked to market due to the risk being hedged; and these results must flow through current income as well. This treatment is called a fair value hedge.
A hedge of an upcoming, forecasted event would be a cash flow hedge. For cash flow hedges, derivative results must be evaluated, with a determination made as to how much of the result is effective and how much is ineffective. The ineffective component of the hedge results must be recorded in current income while the effective portion is initially posted to other comprehensive income (OCI) and later reclassified to income in the same time frame in which the forecasted cash flow affects earnings. Importantly, as of this writing, the Financial Accounting Standards Board (FASB) recognizes hedges as being ineffective for accounting purposes only when the hedge effects exceed the effects of the underlying forecasted cash flow, measured on a cumulative basis; however, this asymmetric provision is under consideration and is subject to change.
Finally, the last category qualifying for special accounting treatment is the hedge associated with the currency exposure of a net investment in a foreign operation. Again, the hedge must be marked to market. This time, the treatment requires effective hedge results to be consolidated with the translation adjustment in OCI. Any excess of hedge results relative to the risk being hedged would be recorded in earnings.
According to ASC 815-10-15, a qualifying derivative must satisfy three criteria:
Complicating the process for assessing whether any contractual arrangement qualifies as a derivative is the fact the FASB has scoped out a host of situations that might otherwise appear to satisfy the given definition (see Accounting Standards Codification (ASC) 815-10-15). For example:
Embedded derivatives are components of contractual arrangements that, by themselves (i.e., on a stand-alone basis), would satisfy the criteria in the definition of a derivative. Embedded derivatives are often present in structured note contracts and other debt obligations, but they may also be found in such contracts such as leases, purchase agreements, insurance contracts, guarantees, and other tailored arrangements. Embedded derivatives reside in host contracts; and the combined instrument (i.e., the host and the embedded derivative) is referred to as the hybrid instrument. An example of an embedded derivative is a convertible bond. The host security is the debt instrument, and the embedded derivative is the option to convert the bond.
In general, embedded derivatives must be separated from the host contract for accounting purposes. Provided they meet the qualifying criteria for being a derivative under the FASB criteria, embedded derivatives must be accounted for as if they were free-standing derivatives, unless (1) the characteristics and risks of the embedded derivative are clearly and closely related to those of the host, or (2) the hybrid instrument is remeasured at fair value with changes reported in earnings.
According to ASC 815-15-25, if the embedded derivative incorporates a leverage factor or if an investor may not recover substantially all of the initial recorded investment, the embedded derivative would be required to be accounted for separately from the host.
ASC 815-10-15 states that interest-only and principal-only strips are specifically exempted from being treated as derivatives, provided that (1) the original securities from which these derivatives were constructed have no embedded derivatives that would otherwise be covered under FAS 133, and (2) the strips do not contain any features that were not initially a part of the original instrument.
ASC 815-15-10 also states that embedded foreign currency derivatives are exempt from treatment as a derivative if (1) the host is not a financial instrument and settlements are required in the functional currency of any substantial party to the contract, or (2) the settlements are denominated in the currency of the price that is routinely used for international commerce of the underlying good or service.
The accounting treatment that applies to any given derivatives position may vary, depending on whether the derivative is used as a hedging instrument or not. Even assuming the derivative is intended as a hedge, one cannot simply elect to apply special hedge accounting. The exposure being hedged must qualify as a permissible hedged item, and the intended hedging relationship much be documented as such. If this documentation is not complete as of the trade date of the derivative contract, the hedge could not be applied, and the derivative would have to be marked to market through earnings. Critically, failure to have the documentation in place when the derivative is traded does not preclude drafting this documentation later, at which time hedge accounting could be instituted.
With the determination that the derivative is to be used as a hedge and with all the necessary prerequisites satisfied, the appropriate accounting treatments would depend on the nature of the hedge. Three different types of hedge treatments are cash flow hedges, fair value hedges, and hedges of net investments in foreign operations.
Derivatives that are not intended to serve as hedges—or derivatives that fail to qualify for hedge accounting treatment—must be accorded the regular accounting treatment, which is generally referred to as accounting for speculative derivative transactions.
A hedge of an upcoming, forecasted event is a cash flow hedge. To qualify for cash flow hedge treatment, a key requirement is that exposure involves the risk of an uncertain (i.e., variable) cash flow. Derivative results must be evaluated, with a determination made as to how much of the result is effective and how much is ineffective. The ineffective component of the hedge results must be reported in current income, while the effective portion is initially posted to OCI and later reclassified to income in the same time frame in which the forecasted cash flow affects earnings.
For purposes of determining the amount that is appropriate to be posted to OCI, this assessment must be made on a cumulative basis. According to ASC 815-30-35, contributions to earnings are currently required only if the derivative results exceed the cash flow effects of the hedged items. This provision is currently under consideration and subject to change, whereby ineffective earnings amounts would be determined symmetrically, reflecting either excess hedge results or shortfalls.
Cash flow hedge accounting is not automatic. Specific criteria must be satisfied both at the inception of the hedge and on an ongoing basis. If, after initially qualifying for cash flow accounting, the criteria for hedge accounting stop being satisfied, hedge accounting is no longer appropriate. According to ASC 815-30-40, with the discontinuation of hedge accounting, any accumulated OCI would remain there, unless (except in extenuating circumstances) it is probable that the forecasted transaction will not occur by the end of the originally specified time period or within an additional two-month period of time thereafter.
ASC 815-30-40 indicates that reporting entities have complete discretion to undesignate cash flow hedge relationships at will and later redesignate them, assuming all hedge criteria are again (or still) satisfied. This provision is also under consideration and subject to change. While such flexibility affords management the opportunity to most fairly present the financial numbers in economic terms, such flexibility can also lead to accounting manipulation.
Examples of exposures that qualify for cash flow hedge accounting include:
The risk being hedge in a designated hedging relation must be explicitly stated in the hedge documentation. The following details explicit risk categories that are permitted to be afforded hedge accounting (ASC topic 815-20-25)
To qualify for cash flow accounting treatment, ASC 815-20-25 states that these prerequisites apply:
According to ASC 815-20-25, cash flow accounting may not be applied under the following circumstances:
Except in the case when currency derivatives are used in cash flow hedges, derivatives between members of a consolidated group (i.e., internal derivatives) cannot qualify as hedging instruments in the consolidated statement, unless offsetting contracts have been arranged with unrelated third parties on a one-time basis (ASC topic 815-20-25).
For an internal currency derivative to qualify as a hedging instrument in a consolidated statement, it must be used as a cash flow hedge only for a foreign currency forecasted borrowing, a purchase or sale, or an unrecognized firm commitment, , subject to the following conditions:
When hedging exposures associated with the price of an asset, liability, or a firm commitment, the total gain or loss on the derivative is recorded in earnings. In addition, the carrying value of the underlying exposure must be adjusted by an amount attributable to the risk being hedged; and these results flow through current income as well. This treatment is called a fair value hedge. Hedgers may elect to hedge all or a specific identified portion of any potential hedged item.
According to ASC 815-25-40, fair value hedge accounting is not automatic. Specific criteria must be satisfied both at the inception of the hedge and on an ongoing basis. If, after initially qualifying for fair value accounting, the criteria for hedge accounting stop being satisfied, hedge accounting is no longer appropriate. With the discontinuation of hedge accounting, gains or losses of the derivative will continue to be recorded in earnings but no further basis adjustments to the original hedged item would be made.
ASC 815-25-40 states that reporting entities have complete discretion to dedesignate fair value hedge relationships at will and later redesignate them, assuming all hedge criteria remain. As noted earlier, this provision is under reconsideration and subject to change.
According to ASC 815-25-40, these exposures may qualify for fair value hedge accounting:
These are examples of risks that can qualify for fair value hedge accounting (ASC 815-20-25):
According to ASC 815-20-25, to qualify for fair value accounting treatment these prerequisites must be satisfied:
Fair value hedge accounting is permitted when cross-currency interest rate swaps result in the entity being exposed to a variable rate of interest in the functional currency
ASC 815-20-25 states that fair value accounting may not be applied in these situations:
Special hedge accounting is appropriate for hedges of the currency exposure associated with net investments in foreign operations, which give rise to translation gains or losses that are recorded in the currency translation account (CTA) in shareholders' equity. ASC 815-20-25-66 states that derivatives and nonderivatives (i.e., assets or liabilities denominated in the same currency as that of the net investment) may be designated as hedges of these exposures. According to ASC 815-20-35-1, effective results of such hedges are recognized in the same manner as a translation adjustment. Ineffective portions of hedge results are recognized in earnings.
Hedge accounting for net investments in foreign operations is not automatic. Specific criteria must be satisfied both at the inception of the hedge and on an ongoing basis. If, after initially qualifying, the criteria for hedge accounting stop being satisfied, hedge accounting is no longer appropriate. With the discontinuation of hedge accounting, gains or losses of the derivative will be recorded in earnings.
Reporting entities have complete discretion to hedge relationships at will and later redesignate them, assuming all hedge criteria remain satisfied.
As noted above, to qualify for special hedge accounting, ASC 815-20-25-79 states that hedge effectiveness must be assessed prospectively (i.e., before the fact) and retrospectively (after the fact, but no less frequently than quarterly). The methods used to for these effectiveness assessments must be defined with the hedge documentation; and these methods must be applied as prescribed. If the entity decides to improve on these methods, the original hedge must be dedesignated and a new hedge relationship needs to be stipulated. According to ASC 815-20-25-81, if the same method is not applied to similar hedges, a justification for using differing methods is required.
Entities may elect to exclude specific components of hedge results from the hedge effectiveness assessment. ASC 815-20-25-82 indicates that allowable excluded items are (1) differences between spot and forward (or futures prices), if the derivative is or contains a forward or futures contract; or (2) the time value or the volatility value of options, if the derivative is or contains an option contract.
As a rule, whenever the underlying exposure relates to a price, interest rate, or currency exchange rate that is not precisely identical to the underlying of the associated hedging derivative, some degree of hedge ineffectiveness must be expected. According to ASC 815-20-25-84, however, when entities are able to clearly identify and enter into a hypothetical derivative—that is, a derivative that perfectly offsets the changes in fair values or cash flows of the designated hedged item—they can and should expect the hedge to perform perfectly, generating no earnings impacts attributable to hedge ineffectiveness.
The FASB has not sanctioned any particular methodology for assessing hedge effectiveness, and devising such tests is often nontrivial. Hedging entities are encouraged to discuss their intended approaches with their external auditors prior to initiating any hedging transactions.
The accounting treatment is the same for derivatives intended for speculative purposes or for situations in which the prerequisite hedge criteria are not satisfied. Derivatives are recorded on the balance sheet at fair market value, and gains and losses are realized in earnings. The objective for using the derivative contract(s) must still be disclosed.
ASC 815-50-10-1 states that all reporting entities that use derivative instruments must disclose:
Qualitative disclosures are encouraged.
ASC 815-50-10-4 states that if derivatives are used in hedging relationships, the next issues must be disclosed:
According to 815-25-50, there are specific disclosure requirements for fair value hedges, such as disclosing the place on the income statement where derivative gains or losses are reported. When a firm commitment no longer qualifies as a hedged item, the net gain or loss recognized in earnings must be disclosed.
According to ASC 815-30-50, there are specific requirements for cash flow hedges:
There are specific requirements for hedges of net investments in foreign operations. Entities must disclose the amount of the derivatives' results that is included in the cumulative translation adjustment during the reporting period.
As is true with most accounting areas of complexity, the march toward international standards is dotted with potholes and issues. While some features of International Accounting Standard (IAS) No. 39, Financial Instruments: Recognition and Measurement and U.S. generally accepted accounting principles (GAAP) are shared, some differences will need to be resolved as countries move toward congruence. Generally the IAS tracks GAAP in the criteria used to qualify a hedge, but in a cash flow hedge, U.S. GAAP treats unrealized gains and losses as part of equity (OCI) until realized. Under IAS No. 39, that change in value is recorded as an adjustment to the value of the hedged item. As another example, GAAP does not permit the hedging of a portion of the cash flows, but International Financial Reporting Standards (IFRS) do. These and other differences mean that more thinking on the best accounting in this critically important area2 is forthcoming.
American Institute of Certified Public Accountants. Auditing Derivative Instruments, Hedging Activities, and Investments in Securities. AICPA Audit Guide. New York, AICPA April 2011.
Banks, E. Exchange Traded Derivatives. Hoboken, NJ: John Wiley & Sons, 2002.
Financial Accounting Standards Board. Statement of Financial Accounting Standards No. 133, Accounting for Derivative Instruments and Hedging Activities. Stamford, CT: Author, 1998.
_____. Statement of Financial Accounting Standards No. 157, Fair Value Measurement. Norwalk, CT: Author, 2006.
_____. Statement of Financial Accounting Standards No. 159, The Fair Value Option for Assets and Liabilities. Norwalk, CT: Author, 2007.
_____. Accounting Standards Update (ASU No. 2011-04), Fair Value Measurement (Topic 820)—Amendments to Achieve Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRS. Norwalk, CT: Author, 2011
_____. Accounting Standards Update No. 2010-11, Derivatives and Hedging (Topic 815) Scope Exception Related to Embedded Credit Derivatives. Norwalk, CT: Author, 2011.
Flavell, R. Swaps and Other Derivatives. Hoboken, NJ: John Wiley & Sons, 2010.
Heye, P., “How to Manage Fluctuations in Foreign Currency Rates,” Journal of Accountancy (April 2011).
Kawaller, I. www.kawaller.com/articles.shtml (link to the extensive published literature and articles by the author of this chapter)
Kolb, R., and J. Overdahl (eds.). Financial Derivatives: Pricing and Risk Management. Hoboken, NJ: John Wiley & Sons, 2009.
1 While the underlying is the variable in a derivative, the notional amount is the fixed amount or quantity that determines the size of the change caused by the movement of the underlying. Examples include the stated principal amount in an interest rate swap, the stated number of bushels in a wheat futures contract, and the contracted amount of euros in a foreign currency forward.
2 It is reported that at the end of 2009, there were around $450 trillion in derivative contracts in play. See P. Eavis, “Bill on Derivatives Overhaul Is Long Overdue,” Wall Street Journal, April 4, 2010.
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