For a long time, IAS39 has been widely criticized for its overly complex rules and large room for profit management. The outbreak of the international financial crisis in 2008 promoted the introduction and implementation of IFRS9.

Zhang Jiqiang S0570518110002 Researcher

Zhang Liang S0570518110005 Researcher

Zhao Tiantong S0570519070002 Researcher

Wang Wanting S0570520020001 Researcher

Report Release Time: November 9, 2020

Excerpt

core view

For a long time, IAS39 has been widely criticized for its overly complex rules and large room for profit management operations. The outbreak of the international financial crisis in 2008 promoted the introduction and implementation of IFRS9. According to the current relevant documents, listed insurance companies should implement the new accounting standards for at the latest from 2023. The main change in IFRS9 is that financial instruments have become three categories, and the impairment method adopts the "expected credit loss model". Under IFRS9, the proportion of insurance companies' FVTPL has increased, and profit fluctuations have intensified. At this time, it is expected that insurance funds investment will be more stable, reducing the allocation of equity assets and low-rated credit bonds, and increasing the proportion of blue-chip stocks, interest rate bonds and high-rated credit bonds. In addition, insurance companies have previously adjusted the space for profit reduction through fund dividends and other forms, and amortized cost valuation products may become their important allocation products. The background and implementation process of IFRS9 has always been criticized by investors, regulators and intermediary institutions for its overly complex rules and large room for profit management. The outbreak of the international financial crisis in 2008 once again exposed many problems in the fair value accounting system represented by IAS39. Against this background, IASB initiated the research and development of IFRS9. Specifically, the replacement of new and old standards is divided into three stages: classification and measurement of financial assets and financial liabilities, hedging accounting, and impairment methods. In order to ensure the continued convergence between the accounting standards for enterprises in my country and international standards, the Ministry of Finance issued three accounting standards for financial instruments, including "Enterprise Accounting Standard No. 22 - Financial Instrument Confirmation and Measuring" in March 2017. According to current relevant documents, listed insurance companies should implement the new accounting standards by the latest from 2023.

IFRS9 main content

According to the business model of enterprise management of financial assets and the current flow characteristics of financial assets, the new accounting standards divide financial assets into three categories: financial assets (AC) measured at amortized cost, measured at the fair value of and its changes are included in other comprehensive income (FVTOCI), and measured at fair value and its changes are included in the current profit and loss (FVTPL). From the perspective of common investment assets, under IFRS9, ordinary bonds will be classified as AC or FVTOCI, and will be reserved for impairment , which will have little impact on profits; while equity-inclusive bonds and equity must be classified as FVTPL, aggravating profit fluctuations. In addition, the new accounting standards adopt the "expected credit loss model" to impair financial assets. The principles of the expected credit loss model of different institutions are similar, but they are different in practice.

FVTPL has exacerbated profit fluctuations, and the coverage of asset impairment has expanded

Under the new accounting standards, AFS assets have been most affected. The proportion of financial assets (FVTPL) measured at fair value and their changes are included in the current profit and loss in financial institutions will increase, which further aggravates the profit fluctuations of financial institutions. In addition, the adoption of the "Expected Credit Loss Model" expands the coverage of asset impairment in financial institutions. AC, FVTOCI's debt instruments, accounts receivable, lease receivables, contract assets, as well as most loan commitments and financial guarantee contracts all require impairment losses. In the short term, the impairment scale before and after the switching between new and old standards may change significantly. In the long term, financial statements can better reflect the risk conditions faced by enterprises and help avoid the rapid deterioration of financial assets and the cliff-like decline in company performance during the economic depression.

insurance funds investment will be more stable

IFRS9, insurance companies' current profits are more sensitive to changes in fair value changes in financial assets . In order to avoid excessive fluctuations in profits, their financial asset allocation will also undergo corresponding marginal changes.Specifically, the proportion of allocation of insurance companies to stocks and equity funds may be marginally reduced; for stock assets classified as FVTPL, they will prefer blue-chip stocks or cash bull companies with stable dividends and low-risk dividends; for debt assets, they will prefer interest rate bonds with less risk and high-rated credit bonds; amortized cost valuation products may become an important allocation product for insurance companies. Overall, under IFRS9, the investment style of insurance institutions will be more stable.

Risk warning: The implementation date requirements of the new standard have been adjusted, the returns of investment assets do not match the risks, and whether there are unified requirements for the provision of impairment losses. The background and implementation process of IFRS9's release and implementation process

International Financial Reporting Standards is a constantly changing and developing system. Since its establishment in 2001, the International Accounting Standards Board (IASB) has begun to develop and issue an international general accounting standard system and revise it in line with the times based on the economic environment and market situation. The "International Financial Reporting Standards No. 9 - Financial Instruments" (IFRS9) issued in July 2014 is one of its latest achievements.

IFRS9 Issuance Background

Before the International Accounting Standards Council formulated and implemented IFRS9, "International Accounting Standards No. 39 - Financial Instruments: Recognition and Measuring" (IAS39) was widely used in accounting practices of various countries. However, under IAS39, the classification and measurement of financial instruments are too complex to make it difficult for statement users and other stakeholders to understand and use. The large space for earnings management often leads to low transparency and poor comparability of financial information, so it is widely criticized by investors, regulators and intermediary institutions. To this end, in 2005, the IASB and the U.S. Financial Accounting Standards Board (FASB) began to work together to improve and simplify the financial instrument report, and in March 2008 released a discussion draft of the “Reduce the Complexity of Financial Instrument Reports”.

In 2008, the international financial crisis broke out, which had a profound impact on the world economy, and exposed many problems in the fair value accounting system represented by IAS39. To this end, political forces represented by G20, FSB and FCAG have begun to promote the IASB to carry out fair value accounting reform, and its direction mainly focuses on three aspects: reducing the complexity of financial instrument accounting standards, alleviating the pro-cyclical effect of fair value accounting, and enhancing the transparency of financial information. *It is in this context that IASB has initiated the research and formulation of new accounting standards.

* Huang Shizhong: "Reform and Reshaping of Fair Value Accounting in Post-Crisis Era", "Accounting Research", 2010 No. 6.

Three stages of replacement of old and new standards

The process of the International Accounting Standards Board using IFRS9 to replace IAS39 can be mainly divided into 3 stages, each stage corresponding to a part of the new accounting standards.

Stage 1: Classification and measurement of financial assets and financial liabilities. In November 2009, the International Accounting Standards Board issued the chapter on "International Financial Reporting Standards No. 9" related to the classification and measurement of financial assets. Relevant chapters change the original four categories of financial assets to two categories based on the business model of managing financial assets and the characteristics of contractual cash flow quantity - financial assets measured at amortized cost and financial assets measured at fair value. In October 2010, the IASB added classification and measurement requirements for financial liabilities to the new standards, and the relevant regulations are consistent with IAS39. In July 2014, the IASB made limited revisions to the classification and measurement requirements of financial assets in the new standards.

Stage 2: Hedging Accounting. In November 2013, IASB added new standards to hedging accounting related requirements, requiring hedging accounting to reflect risk management more closely.

Stage 3: Impairment method. In July 2014, IASB added the expected credit loss impairment requirement for accounting entities' financial assets and credit commitments to the new standards, and canceled the threshold conditions for credit loss recognition in IAS39. At this point, all three stages have been completed, and IFRS9 has begun to completely replace IAS39.

IFRS9 implementation process in my country

In April 2010, the Ministry of Finance issued the "Roadmap for Continuous Convergence of Chinese Enterprise Accounting Standards and International Financial Reporting Standards".The document pointed out that "Chinese corporate accounting standards will maintain continuous convergence with international financial reporting standards, and the continuous convergence schedule will remain synchronized with the progress of IASB" . Therefore, after the IASB officially launched IFRS9, the Ministry of Finance also began work related to the formulation and release of new accounting standards.

On August 1, 2016, the General Office of the Ministry of Finance issued a letter on soliciting opinions on three standards, including accounting standards for enterprise accounting standards No. 22 - Confirmation of financial instruments and measurement (revision) (draft for soliciting opinions).

On March 31, 2017, the Ministry of Finance officially issued three financial instrument accounting standards, including "Enterprise Accounting Standard No. 22 - Confirmation and Measurement of Financial Instruments", "Enterprise Accounting Standard No. 23 - Transfer of Financial Assets", and "Enterprise Accounting Standard No. 24 - Hedging Accounting". Ministry of Finance pointed out that for the above three standards, enterprises listed at the same time at home and abroad, and enterprises listed overseas and prepared financial reports using international financial reporting standards or enterprise accounting standards will come into effect on January 1, 2018; other domestic listed companies will come into effect on January 1, 2019; non-listed enterprises that implement enterprise accounting standards will come into effect on January 1, 2021; at the same time, enterprises are encouraged to implement them in advance.

On June 22, 2017, the Ministry of Finance issued the "Notice on Transitional Measures for Insurance Companies to Implement Accounting Standards Related to New Financial Instruments". The document points out that for listed insurance companies that meet the "conditions for insurance companies to suspend the implementation of accounting standards related to new financial instruments", the implementation of accounting standards related to new financial instruments is allowed to be suspended until January 1, 2021.

On January 1, 2018, Ping An of China began to implement IFRS9. In addition, in November 2018, IASB agreed to postpone the implementation of IFRS9 for one year in order to synchronize with IFRS17. On March 17, 2020, the International Accounting Standards Board decided that the effective date of IFRS17 will be postponed to the annual reporting period starting on or after January 1, 2023; and extend the exemption period for insurers to use IFRS9 (financial instruments) so that insurers can implement both IFRS9 and IFRS17. Therefore, if the Ministry of Finance introduces relevant transition measures, it is expected that domestic insurance companies except Ping An of China will implement IFRS9 and IFRS17 at the same time in 2023.

IFRS9 main content

Among the three major contents adjusted by IFRS9, the classification, measurement and impairment methods of financial instruments have a great impact on financial institutions. Therefore, this article will focus on the analysis of the above two parts.

Classification and measurement of financial instruments

Under the original accounting standard IAS39, financial assets are divided into four categories according to the management's holding intention and ability, and combined with the characteristics of financial assets: financial assets measured at fair value and their changes are included in the current profit and loss (FVTPL), holding-to-maturity investment (HTM), loans and receivables (LR), and available-for-sale financial assets (AFS). Under the new accounting standard IFRS9, financial assets are divided into three categories according to the business model of corporate management of financial assets and the contract cash flow characteristics of financial assets: financial assets (AC) measured at amortized cost, financial assets (FVTOCI) measured at fair value and their changes are included in other comprehensive income, and financial assets (FVTPL) measured at fair value and their changes are included in current profit and loss.

Under the new accounting standards, the business model of enterprises in managing financial assets is mainly judged as three categories: (1) only for the purpose of collecting contract cash flow, (2) both collecting contract cash flow and selling financial assets, and (3) other business models. At the same time, the contract cash flow characteristics of financial assets are judged to be divided into two categories: (1) The contract cash flow is only interest payments for the principal and the outstanding principal amount, and (2) others. This discrimination is also called contract cash flow characteristics testing (SSPI).

IFRS9 points out that if an enterprise manages financial assets only for the purpose of collecting contract cash flow, and the contract cash flow of the financial assets is only for the interest payment of principal and outstanding principal amount, then such assets are measured at amortized cost; if an enterprise manages financial assets both for the contract cash flow and sells financial assets, and the contract cash flow is only for the interest payment of principal and outstanding principal amount, then such assets are measured at fair value and their changes are recorded in other comprehensive income; assets other than the above two situations are measured at fair value and their changes are recorded in the current profit and loss.In addition to the above provisions, an enterprise may still irrevocably designate financial assets as measured at fair value and their changes are recorded in profit or loss at initial recognition, provided that doing so can eliminate or significantly reduce accounting mismatches (i.e., inconsistencies in measurement or recognition).

In actual operation, financial assets are usually divided into three categories: debt instruments, equity instruments and derivative instruments. The corresponding relationship with the three categories of IFRS9 is shown in the figure below. For debt instruments, SSPI test is first carried out, and business model test is carried out after passing the test. If it is held to collect contract cash flow, it is recorded in AC. If it is collected both contract cash flow and financial assets are sold, it is recorded in FVTOCI, otherwise it is recorded in FVTPL; for equity instruments, except for those not for transaction purposes and designated as FVTOCI, it is recorded in FVTPL; derivative instruments are preset classification as FVTPL. It is worth noting that the classification of an asset can only be confirmed from the beginning and cannot be changed at will after confirmation.

From the perspective of specific and common investment assets, we will find that IFRS9 has little impact on ordinary bonds and has a greater impact on equity-inclusive bonds and equity.

1. Treasury bonds, IFRS9 has almost no impact on it. Under the old four categories, according to the investment purpose, treasury bonds can be classified as holding-to-maturity investment (HTM), available-for-sale financial assets (AFS), and even financial assets (FVTPL) measured at fair value and their changes are included in current profit and loss. However, under the IFRS9 third classification, treasury bonds must first undergo an SSPI test (all the most standard bonds that do not include rights can pass this test) and must pass this test, so treasury bonds will be classified as AC or FVTOCI. Specifically, if the coupon is for the purpose of earning coupons, it is classified as AC; if the coupon income + capital gains are for the purpose of it, it is classified as FVTOCI. In this way, even if the treasury bond market fluctuates significantly, changes in the capital gains only affect the owner's equity (other comprehensive income) on the balance sheet and cannot have an impact on the income statement (the profit and loss realized will not be included in the income statement until the sale is sold).

2. Credit bonds, IFRS9 has more impact on them lies in the need to make up asset impairment provisions. is similar to treasury bonds. Under the old four categories, credit bonds are similar to treasury bonds. They can be classified as HTM, AFS or FVTPL depending on the investment purpose. Under the IFRS9 three-category, the simplest credit bonds can pass the SSPI test and are either classified as AC or FVTOCI. However, no matter which type is classified, the credit risk of credit bonds cannot be ignored, so asset impairment provisions need to be made, and this impairment provisions must be included in the current profit and loss. Different investors will have different expected credit loss models, so there will be differences in asset impairment provisions for the same credit bond.

3, floating interest bond. floating interest rate is Shibor 3M, and the interest rate reset cycle is also 3 months floating interest bonds, which can pass the SSPI test. The impact of IFRS9 is mainly to make up asset impairment provisions; if the floating interest rate is linked to LPR 5Y, but the interest rate reset cycle is one year, it cannot pass the SSPI test and must be included in the FVTPL, which has a greater impact on the income statement.

4, and rights-inclusive bonds cannot pass the SSPI test. Therefore, no matter which HTM, AFS or FVTPL is in the old category, it must be included in the FVTPL under IFRS9, which will have an impact on the income statement. Bank perpetual bonds and corporate perpetual bonds are no exception (except for extremely special false perpetual, false perpetual can be included in AC).

5, stock. Under the old four categories, stocks are usually classified as AFS or FVTPL; but under IFRS9, stocks can only be classified as FVTPL, because the stock market is volatile, which will put pressure on the income statement. Although there are special circumstances in which stocks can be designated as FTVOCI when they are initially confirmed for accounting (changes in fair value are not carried forward to the income statement at disposal and are designated irrevocable), this situation is generally more applicable to Venture Capital than daily stock investments.

Impairment method

Under the original accounting standard IAS39, the financial asset impairment model is the "loss model that has occurred". Accounting confirmation of impairment losses will only be carried out when objective evidence indicates that the asset impairment has occurred. Under the new accounting standard IFRS9, the "expected credit loss model" is used to impair financial assets, and different methods are used to make up impairment losses according to the status of the financial instruments. The specific operations are as follows:

Status 1: Credit risk has not increased significantly. At this time, accounting entity should measure the loss provision for the financial instrument based on the amount equivalent to the expected credit loss of 12 months.

Status 2: Credit risk has increased significantly. At this time, the accounting entity should measure the loss provisions of the financial instrument based on the amount equivalent to the expected credit loss of the entire expiration date.

Status 3: Credit impairment has occurred. At this time, the accounting entity should only recognize the cumulative changes in expected credit losses in the entire duration since the initial confirmation as a loss reserve.

In addition, if the accounting entity has measured the loss provisions of the financial instrument at the amount equivalent to the expected credit loss of the entire period in the previous reporting period, but the financial instrument no longer meets status 2 on the current reporting date, the accounting entity should measure the loss provisions of the amount equivalent to the expected credit loss of the 12 months on the current reporting date, and at the same time, the expected credit loss amount that needs to be recognized or reversed is included in the profit or loss as an impairment gain or loss.

Finally, for accounts receivable, contract assets and lease receivables, the accounting entity can use a simplified method of impairment of expected credit losses to measure loss provisions based on the amount equivalent to the expected credit losses for the entire duration.

IFRS9’s impact on financial institutions—taking insurance institutions as an example

AFS was the most affected, FVTPL assets increased, profit volatility intensified

Under the new accounting standards, the proportion of financial assets (FVTPL) measured at fair value and their changes included in current profit and loss will increase. First, for financial assets that are included in loan and receivable investments (LRs) and available-for-sale financial assets (AFS) accounts under IAS39, a large part of which will be classified as FVTPL under the new standards because they cannot pass the cash flow test. Secondly, although financial institutions have the option to designate financial assets as measured at fair value and their changes are included in profit and loss, and can designate some equity instruments that are not for transaction purposes as FVTOCI, because such designation is irrevocable and the fair value changes and investment returns of such equity instruments cannot affect current profits, financial institutions do not have sufficient incentives to designate equity instruments as FVTOCI.

Take Ping An of China as an example. On December 31, 2017, under the old standard system, FVTPL accounted for 2.18% of the total assets, and under the new standard on January 1, 2018, its proportion immediately adjusted to 10.67%. This is the direct reflection of the reclassification of financial assets caused by changes in accounting standards, and the details of their changes are shown in the table below.

From the perspective of asset reclassification, available-for-sale financial assets (AFS) were most affected under the original accounting standards. Taking stock assets as an example, the total stock assets measured at fair value under Ping An of China's AFS account at the end of 2017 were 259.94 billion yuan, while in 2018H1, the stock assets in FVTOCI were 138.82 billion yuan. Correspondingly, the stock assets in FVTPL increased from 10.73 billion yuan in 2017H2 to 108.73 billion yuan. This phenomenon is largely due to the migration of AFS assets under the old standard to FVTPL under the new standard.

The proportion of financial assets measured at fair value and its changes are included in the current profit and loss (FVTPL) has exacerbated the profit fluctuations of financial institutions. Under the old accounting standards IAS39, some financial assets are classified more subjectively, and enterprises have more room for operation to modify financial statements. Taking the Available-for-sale Financial Assets (AFS) account as an example, although such assets are measured at fair value, changes in their fair value are not included in the current profit and loss, but are included in other comprehensive income. Therefore, the decline in fair value will not bring negative effects to profits; however, if the fair value increases, the enterprise can dispose of such assets and transfer the profits and include them in the current income statement to achieve the effect of smoothing profits. With the implementation of the new standard IFRS9, as more assets are classified as FVTPL, their investment income and fair value changes during the holding period are included in the income statement.In FVTPL, a considerable number of equity investments with high sensitivity to profit changes, so profit fluctuations of financial institutions will intensify.

Among listed insurance companies that still adopt the old standards, the proportion of FVTPL of China Life Insurance and China Pacific Insurance in total assets shows a significant shrinking trend. The reason may be that the two insurance companies have made advance adjustments to asset allocation to prevent the impact of asset reclassification caused by the switching between new and old standards. Judging from the specific investment types, the stock investment allocation ratio of major insurance companies showed a certain downward trend in 2018, and rebounded in 2019. In addition to the bull-bear transformation of the equity market, the expected change of accounting standards is also one of the influencing factors.

asset impairment coverage has expanded, and the switching of the criteria may lead to significant changes in the impairment scale

IFRS9 adopts the "Expected Credit Loss Model" under IFRS9, which has expanded the coverage of asset impairment of financial institutions. In the short term, the impairment scale may undergo significant changes before and after the switching of new and old standards. In the long run, the financial statements can better reflect the risk conditions faced by enterprises.

Under IFRS9, the provision of impairment provision is based on expected credit losses, and credit risk has become an important basis for arranging impairment losses. Specifically, accounting accounts that require impairment include financial assets (ACs) measured at amortized cost, debt instruments measured at fair value and changes in other comprehensive income, accounts receivable, lease receivables, contract assets, and most loan commitments and financial guarantee contracts. Among them, for debt instruments in FVTOCI, the loss provision is included in other comprehensive income and does not reduce the book amount of its financial statements. Correspondingly, equity instruments and financial assets (FVTPLs) measured at fair value and are included in profit and loss (FVTPLs) do not need to make up impairment losses.

Because under the old standards, accounting confirmation of impairment losses is only carried out when objective evidence indicates that asset impairment has occurred, the scale of impairment of financial institutions may increase significantly during the reporting period when new and old standards are switched. Taking insurance companies as an example, the main components of their financial assets are debt assets, most of which require risk impairment losses, and the scale of credit bonds and non-standard assets is larger than interest rate bonds and local government bonds.

However, in the long run, compared with the obvious pro-cyclical characteristics of the "loss model" under the old standards, the impairment provision of the "expected credit loss model" under the new standards is more forward-looking, which can better reflect the actual risk conditions faced by the company, thereby promoting the prudent operation of the company to a certain extent, helping to avoid the rapid deterioration of financial assets and the cliff-like decline in company performance during the economic depression.

insurance funds investment will be more stable

IFRS9, the current profits of financial institutions will increase their sensitivity to changes in the fair value of financial assets. In order to avoid excessive fluctuations in profits, financial institutions will also undergo marginal changes in the allocation of financial assets. Taking insurance companies as an example, it is expected that their investment style will be more stable, reducing the allocation of equity assets and low-rated credit bonds, and increasing the proportion of blue-chip stocks, interest-rate bonds and high-rated credit bonds. In addition, insurance companies have previously adjusted the space for profit reduction through fund dividends and other forms, and amortized cost valuation products may become their important allocation products.

As mentioned earlier, the proportion of assets of financial institutions FVTPL under the new accounting standards will increase, which in turn will intensify the profit fluctuations of financial institutions. Taking fund investment as an example, under IAS39, such assets are often classified as available-for-sale assets (AFS), and changes in fair value are not included in the current profit and loss. Under the new standards, the existence of performance fluctuations makes it more difficult for them to pass the contract cash flow characteristic test (SSPI), and are likely to be classified as FVTPL. At this time, the fluctuations in the net value of such assets will directly lead to profit fluctuations of financial institutions, and equity funds are also representative of them. For insurance institutions, investment returns have a great impact on company profits. In order to smooth profits, they have sufficient incentives to adjust their asset allocation strategies. Specifically, since the fair value of equity assets changes more frequently, the allocation ratio of insurance institutions to stocks and equity funds may be marginally reduced.For stock assets classified as FVTPL, insurance institutions will prefer to invest in blue-chip stocks or cash bull companies with stable dividends and low risk.

For debt-related assets, insurance institutions will also prefer less risky interest rate bonds and high-rated credit bonds. Since most debt investment vehicles can pass the SSPI test, and the worse the credit rating, the more impairment losses that need to be set aside under the "Expected Credit Loss Model", which has an adverse impact on company profits, so this type of assets is often less attractive to insurance institutions. For some non-standard assets that cannot pass the SSPI test and are classified as FVTPL, the fluctuations in their fair value are not conducive to the smooth profits of insurance institutions and are also not attractive.

At the same time, according to the requirements of IFRS9, most funds and asset management products cannot pass the SPPI test and need to be divided into FVTPL. These products are adjusted from AFS to FVTPL, which will lead to a reduction in the space for adjusting profits through fund dividends and other forms in the past, increasing the fluctuations in insurance companies' profits. At this time, amortized cost valuation products may become an important configuration product for insurance companies.

Overall, under IFRS9, the investment style of insurance institutions will be more stable. In addition, with the gradual liberalization of insurance funds in the treasury bond futures market and the optimization of hedging accounting under the new standards, the necessity of insurance companies to use derivatives to hedge interest rate risks has also increased.

Risk warning

1. The implementation date requirements for the new standard have been adjusted. According to the current requirements of the Ministry of Finance, listed insurance companies should start implementing new accounting standards at the latest from 2021. If the Ministry of Finance adjusts the transition period according to the latest requirements of the IASB, domestic insurance companies may postpone the implementation of the new standards accordingly.

2. The income from investment assets does not match the risk. In order to avoid excessive fluctuations in current profits caused by the new standards, insurance companies will gradually adjust their investment asset allocation, and at this time, there may be a situation where asset returns and risks are not matched.

3. Whether there are unified requirements for the provision of impairment losses. There is room for profit management operation for impairment provision of financial assets, and the introduction of relevant requirements for impairment loss provision will reduce the profit adjustment space of financial institutions.

The views contained in this material are derived from the research report "The Impact of IFRS9 on Insurance Investment" released on November 9. Please refer to the above research report for a complete understanding of this material.

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