(Decision-making sessions)
The IASB met on 21 and 23 September 2015 to continue its discussions regarding the possible accounting consequences of the different effective dates of IFRS 9 Financial Instruments and the new insurance contracts Standard.
Feedback from user outreach and submissions (Agenda Paper 14A)
The IASB considered feedback received from users of financial statements on the different effective dates of IFRS 9 and the new insurance contracts Standard. No decisions were made.
The Overlay Approach (Agenda Paper 14B)
Financial assets eligible for the overlay adjustment (eligible financial assets)
At this meeting, the IASB continued to discuss the overlay approach which it tentatively decided to propose in July 2015. The overlay approach would permit an entity to adjust profit or loss and other comprehensive income (OCI) to remove from profit or loss the effect of newly measuring financial assets at fair value through profit or loss (FVPL) in accordance with IFRS 9. The IASB tentatively decided that:
- a reporting entity should be permitted to make an overlay adjustment in respect of financial assets that meet both of the following criteria:
- the financial assets are designated by the entity as relating to contracts that are within the scope of IFRS 4 Insurance Contracts; and
- the financial assets are classified as FVPL in accordance with IFRS 9 and would not have been classified as FVPL in their entirety in accordance with IAS 39 Financial Instruments: Recognition and Measurement.
- an entity may change the designation of financial assets as relating to contracts within the scope of IFRS 4 only if there is a change in the relationship between the financial assets and contracts that are within the scope of IFRS 4.
All thirteen IASB members present agreed with this decision. One IASB member was absent.
Redesignation of financial assets
The IASB tentatively decided that:
- an entity should be permitted to apply the overlay approach prospectively to financial assets when the eligibility criteria are met;
- an entity should be required to cease applying the overlay approach when financial assets no longer meet the eligibility criteria. Any accumulated balance of OCI relating to the overlay adjustment should be immediately reclassified to profit or loss (recycled).
All thirteen IASB members present agreed with this decision. One IASB member was absent.
Transition
The IASB tentatively decided that:
- an entity should be permitted to apply the overlay approach only when it first applies IFRS 9, including if it chooses to apply IFRS 9 early.
- an entity should apply the overlay approach retrospectively to eligible financial assets on transition to IFRS 9. The entity should recognise as an adjustment to the opening balance of OCI an amount equal to the difference between the fair value of financial assets and their amortised cost or cost carrying amount determined in accordance with IAS 39 immediately prior to transition to IFRS 9.
- an entity should restate comparative information to reflect the overlay approach if, and only if, the entity also restates that comparative information in accordance with IFRS 9.
- an entity should stop applying the overlay approach when it applies the new insurance contracts Standard and would be permitted to stop applying the overlay approach in any reporting period.
- when an entity stops applying the overlay approach it should reclassify any balance of the prior periods’ overlay adjustments accumulated in OCI to retained earnings at the later of:
- the beginning of the earliest reporting period presented; or
- the beginning of the reporting period when the overlay approach was first applied.
All thirteen IASB members present agreed with this decision. One IASB member was absent.
Presentation
The IASB tentatively decided that an entity that applies the overlay approach should present a single line item for the amount of the overlay adjustment in the profit or loss or the OCI section of the statement of comprehensive income or both. An entity may disaggregate the amount of the overlay adjustment in profit or loss.
Eight of the thirteen IASB members present agreed with this decision and five IASB members disagreed. One IASB member was absent.
Disclosures
The IASB tentatively decided that entities that apply the overlay approach should disclose in each period:
- the fact that the entity has made an overlay adjustment, and the financial assets to which the overlay adjustment relates.
- the entity’s policy for determining the financial assets for which an overlay adjustment is made;
- an explanation of the amount of the total overlay adjustment in each period in a way that enables users of the financial statements to understand how it is derived. In particular, an entity should disclose the following in respect of intra-group transfers and re-designation of financial assets:
- the amount of overlay adjustment in profit or loss and OCI relating to financial assets that are newly within the scope of the overlay approach;
- the amount of overlay adjustment that would have arisen in profit or loss and OCI in a period if financial assets had not been removed from the scope of the overlay approach; and
- the amount of overlay adjustment due to the reclassification of amounts in accumulated OCI to profit or loss in respect of financial assets removed from the scope of the overlay approach.
- the effect of the overlay adjustment on line items in profit or loss, to the extent that they are not separately identified on the face of the profit or loss account.
Nine of the thirteen IASB members present agreed with this decision and four IASB members disagreed. One IASB member was absent.
The Deferral Approach (Agenda Paper 14C)
The IASB discussed details of the deferral approach. The IASB tentatively decided that, if the deferral approach is proposed:
- the deferral of the effective date of IFRS 9 should be permitted for an entity that issues contracts within the scope of IFRS 4, if that activity is predominant for the reporting entity, and would apply to all financial assets held by the reporting entity (ie at the ‘reporting entity level’). Twelve IASB members agreed that the deferral should be permitted instead of required and two IASB members disagreed. All fourteen IASB members agreed that the deferral should be at the reporting entity level instead of being below the reporting entity level.
- an entity should be required to initially assess whether insurance activities are predominant for the entity based on the level of gross liabilities arising from contracts within the scope of IFRS 4 relative to the entity’s total liabilities at the date when the entity would otherwise be required to initially apply IFRS 9, ie for annual periods beginning on or after 1 January 2018. Thirteen IASB members agreed with this decision and one IASB member disagreed.
- there should be no quantitative threshold for the assessment of predominance of insurance activities, however, the Basis for Conclusions for the potential amendments to IFRS 4 should include an example specifying the levels at which an entity’s activities would not be considered predominant for the purpose of this assessment. The IASB indicated that the example should indicate a predominance threshold that is higher than in the example discussed in Agenda Paper 14C. Thirteen IASB members agreed with this decision and one IASB member disagreed.
- an entity should be required to reassess whether insurance activities are predominant for the entity at subsequent annual reporting dates if there is a demonstrable change in the corporate structure of the entity (for example, an acquisition or disposal of a business) that could result in a change of the predominant activities of the entity. Thirteen IASB members agreed with this decision and one IASB member disagreed.
- if an entity were to conclude that insurance activities are no longer predominant for the entity as a result of that reassessment, an entity should be required to apply IFRS 9 from the beginning of the next annual reporting period, and to disclose in the reporting period in which the reassessment took place:
- the fact that the entity is no longer eligible for deferral.
- the reason why it is no longer eligible.
- the date on which the change in corporate structure took place that resulted in the entity no longer meeting the predominance condition. Thirteen IASB members agreed with these decisions and one IASB member disagreed.
- an entity that has previously applied IFRS 9 is not permitted to stop applying IFRS 9 and revert to applying IAS 39. Thirteen IASB members agreed with this decision and one IASB member disagreed.
Presentation and disclosures
The IASB tentatively decided that an entity applying the deferral approach should disclose:
- the fact that the entity has chosen to delay application of IFRS 9;
- an explanation of how the entity concluded that it is eligible for the deferral; and
- information about the characteristics and credit quality of financial assets, for example disclosure of:
- the fair value of financial assets that would not meet the ‘solely principal and interest’ characteristics test in IFRS 9, and so are mandatorily measured at FVPL in accordance with IFRS 9; and
- credit risk information about the financial assets that would not be mandatorily measured at FVPL in accordance with IFRS 9 (such as the credit risk grades of such financial assets).
The IASB concluded that providing full information about how financial assets would have been classified if IFRS 9 had been applied was hypothetical in some cases and therefore likely to be of limited usefulness in those cases.
Thirteen IASB members agreed with these decisions and one IASB member disagreed.
Transition
The IASB tentatively decided that:
- an entity should:
- be permitted to stop applying the deferral approach and apply IFRS 9 at the beginning of any annual reporting period before the new insurance contracts Standard is applied; and
- be required to stop applying the deferral approach from the beginning of the annual reporting period when the new insurance contracts Standard is initially applied.
- when an entity applies the deferral approach, the entity applies IFRS 9, including the applicable transition requirements, to the extent needed to provide the disclosures required under the deferral approach; and
- when an entity ceases to apply the deferral approach and applies IFRS 9 for the first time, the entity should follow the transition provisions in IFRS 9 and stop providing disclosures required under the deferral approach.
All fourteen IASB members agreed with these decisions.
Proposing the deferral approach
Seven IASB members voted to defer the effective date of IFRS 9 for specified entities that issue contracts within the scope of IFRS 4 until the new insurance contracts Standard is applied (ie for the deferral approach). Seven IASB members voted against.
On 23 September 2015, the Chairman confirmed his additional casting vote, making the vote 8-7 in favour of the deferral approach.
Due process and permission to ballot (Agenda Paper 14E)
On 23 September 2015, the IASB tentatively decided that the Exposure Draft (ED) to amend IFRS 4 should propose:
- an effective date for the proposed amendments for reporting periods beginning on or after 1 January 2018;
- to permit early adoption of the proposed amendments if an entity adopts IFRS 9 early; and
- to specify an expiry date of the deferral approach for no later than reporting periods beginning on or after 1 January 2021, and confirm that after this date an entity could choose to apply the overlay approach.
All thirteen IASB members present agreed with this decision. One IASB member was absent.
The IASB reviewed the due process steps that it has taken in developing the ED. All thirteen IASB members present confirmed that they are satisfied that the IASB has completed the necessary due process steps on the project to date and therefore instructed the staff to commence the balloting process for the ED. One IASB member, out of the thirteen IASB members present, plans to dissent from the proposals in the forthcoming ED to amend IFRS 4. One IASB member was absent.
Next steps
The IASB will discuss the comment period for the forthcoming ED to amend IFRS 4 at a future meeting. The IASB plans to publish the ED in late 2015.