Significant judgements

Reform of interest rate benchmarks

Certain interest rate benchmarks including LIBOR, EURIBOR and EONIA are being or have recently been reformed.

What are interest rate benchmarks?

Interest rate benchmark are used to determine

1. the amount of interest payable for a wide range of financial products such as derivatives, bonds, loans, structured products and mortgages, and
2. the valuation of financial products.

The most common examples of interest rate benchmarks used in financial contracts across the world are the London Interbank Offered Rate (LIBOR) and for the Euro, the Euro Interbank Offered Rate (EURIBOR) and Euro Overnight Index Average (EONIA).

Why are these benchmarks being reformed?

As benchmark rates are fundamental to so many financial contracts, they need to be robust, reliable and fit for purpose. Each of these interest rate benchmarks subject to reform were based on the rates at which banks lend to each other in the interbank market.

Financial regulatory authorities have expressed their concern that because interbank lending transactions have significantly decreased in recent years, the benchmark rates may no longer be representative or reliable.

This concern has resulted in recommendations made by the Financial Stability Board towards the global financial industry to reform the major interest rate benchmarks and to develop a set of alternative rates that are more representative of the current financial environment.

IFRS Reporting disclosure amendments

The amendments made to IFRS 9 Financial Instruments, IAS 39 Financial Instruments: Recognition and Measurement and IFRS 7 Financial Instruments: Disclosures provide certain reliefs in relation to interest rate benchmark reform. The reliefs relate to hedge accounting and have the effect that the reforms should not generally cause hedge accounting to terminate. However, any hedge ineffectiveness should continue to be recorded in the income statement. Given the pervasive nature of hedges involving interbank offered rates (IBOR)-based contracts, the reliefs will affect companies in all industries.

Entities relying on the relief must disclose:

1. the significant interest rate benchmarks to which the entity’s hedging relationships are exposed
2. the extent of the risk exposure that the entity manages that is directly affected by the interest rate benchmark reform
3. how the entity is managing the process of transition to alternative benchmark rates
4. a description of significant assumptions or judgements that the entity made in applying the reliefs, and
5. the nominal amount of the hedging instruments in those hedging relationships. [IFRS 7.24H]

Information about how the entity is managing the transition process will provide users with an indication of the extent to which management is prepared for the transition. For example, this could include explanations about differences in fallback provisions between the hedged item and the hedging instruments.

The amendments are not clear whether the disclosure of the extent of the risk exposure that the entity manages could be provided on a qualitative rather than quantitative basis. However, numerical disclosures may be more useful for users.

Accounting policies relating to hedge accounting will need to be updated to reflect the reliefs. Fair value disclosures may also be impacted due to transfers between levels in the fair value hierarchy as markets become more / less liquid.

Entities should consider whether further disclosure of the impending replacement of IBOR should be provided in other parts of the annual report, for example in management’s discussion and analysis.

Example Disclosure reform of interest rate benchmarks

This Example Disclosure Related party transactions shows the disclosures an entity would have to add if it has a loan with an interest rate based on 3-month GPB LIBOR and a cash flow hedge in the form of a floating-to-fixed rate interest rate swap that is referenced to LIBOR. The disclosures assume that the entity has adopted the hedge accounting requirements of IFRS 9.

While primarily illustrating the disclosures required by the amendments made to IFRS 7 and other hedge accounting disclosures affected by IBOR reform, extracts of other disclosures from the main body of the publication have been included, to provide some context for the additional disclosures.

New or revised disclosures are highlighted with shading. This appendix does not illustrate disclosures that may be required if the terms of the loan and the swap have moved to new benchmark rates.

12 Financial risk management (extracts)

12(a) Derivatives (extracts)

(iv) Hedge effectiveness (extracts)

Hedge ineffectiveness for interest rate swaps is assessed using the same principles as for hedges of foreign currency purchases. It may occur due to:

• the credit value/debit value adjustment on the interest rate swaps which is not matched by the loan
• differences in critical terms between the interest rate swaps and loans, and
• the effects of the forthcoming reforms to GBP LIBOR, because these might take effect at a different time and have a different impact on the hedged item (the floating-rate debt) and the hedging instrument (the interest rate swap used to hedge the debt). Further details of these reforms are set out below. [IFRS 7.22B(c), IFRS 7.23D]

Ineffectiveness of CUXX,XXX has been recognised in relation to the interest rate swaps in other gains or losses in profit or loss for 2020 (2019 CUXX,XXX). The significant increase in ineffectiveness in the current year was caused by the expectation that the interest rate swap and the hedged debt will move from GBP LIBOR to SONIA at different dates. [IFRS 7.24C(b)(ii)]

12(b) Market risk

[IFRS 7.33]

(ii) Cash flow and fair value interest rate risk

[IFRS 7.21C]

The group’s main interest rate risk arises from long-term borrowings with variable rates, which expose the group to cash flow interest rate risk. Group policy is to maintain at least 50% of its borrowings at fixed rate, using floating-to-fixed interest rate swaps to achieve this when necessary.

Generally, the group enters into long-term borrowings at floating rates and swaps them into fixed rates that are lower than those available if the group borrowed at fixed rates directly. During 2020 and 2019, the group’s borrowings at variable rate were mainly denominated in Oneland currency units and US dollars. Except for the GBP LIBOR floating rate debt noted below, other variable interest rates were not referenced to interbank offered rates (IBORs) that will be affected by the IBOR reforms. [IFRS7.22A(a),(b), IFRS7.33(a),(b)]

Included in the variable rate borrowings is a 10-year floating-rate debt of CU10,000,000 (2019 CU10,000,000) whose interest rate is based on 3 month GBP LIBOR. To hedge the variability of in cash flows of this loan, the group has entered into a 10-year interest rate swap with key terms (principal amount, payment dates, repricing dates, currency) that match those of the debt on which it pays a fixed rate and receives a variable rate. [IFRS 7.24H(a)]

The group’s borrowings and receivables are carried at amortised cost. The borrowings are periodically contractually repriced (see below) and to that extent are also exposed to the risk of future changes in market interest rates.

The exposure of the group’s borrowings to interest rate changes and the contractual re-pricing dates of the borrowings at the end of the reporting period are as follows: [IFRS 7.22A(c), IFRS 7.34(a), IFRS 7.24H(b)]

Amounts in CU’000	2020	%of total	2019	% of total
Variable rate borrowings – GBP LIBOR	10,000	10%	10,000	12%
Variable rate borrowings – non-IBOR	43,669	46%	40,150	47%
Fixed rate borrowings – repricing or maturity dates:
– Less than one year	4,735	5%	3,895	5%
– 1 – 5 years	26,626	27%	19,550	23%
– Over 5 years	11,465	12%	11,000	13%
Total	97,515	100%	84,595	100%

An analysis by maturities is provided in note 12(d) below. The percentage of total loans shows the proportion of loans that are currently at variable rates in relation to the total amount of borrowings.

Instruments used by the group

Swaps currently in place cover approximately 37% (2019 – 37%) of the variable loan principal outstanding. The fixed interest rates of the swaps range between 7.8% and 8.3% (2019 – 9.0% and 9.6%), and the variable rates of the loans are between 0.5% and 1.0% above the 90 day bank bill rate or LIBOR which, at the end of the reporting period, were 8.2% and x.x% respectively (2019 – 9.4% and x.x%). [IFRS 7.22B(a), IFRS 7.23B]

The swap contracts require settlement of net interest receivable or payable every 90 days. The settlement dates coincide with the dates on which interest is payable on the underlying debt. [IFRS 7.22B(a)]

Effects of hedge accounting on the financial position and performance

The effects of the interest rate swaps on the group’s financial position and performance are as follows:

Amounts in CU’000	2020	2019
Interest rate swaps
Carrying amount (current and non-current asset) [IFRS 7.24A(a)(b)]	453	809
Notional amount – LIBOR based swaps [IFRS 7.24H(b),(e)]	10,000	10,000
Maturity date [IFRS 7.23B(a)]	2030	2030
Hedge ratio [IFRS 7.22B(c)]	1 : 1	1 : 1
Change in fair value of outstanding hedging instruments since 1 January [IFRS 7.24A(c)]	xx	xx
Change in value of hedged item used to determine hedge effectiveness [IFRS 7.24B(b)(i)]	xx	xx
Weighted average hedged rate for the year [IFRS 7.23B(b)]	x.x%	x.x%
Notional amount – non-LIBOR based swaps [IFRS 7.24H(b),(e)]	10,010	8,440
Maturity date [IFRS 7.23B(a)]	2020	2019
Hedge ratio [IFRS 7.22B(c)]	1 : 1	1 : 1
Change in fair value of outstanding hedging instruments since 1 January [IFRS 7.24A(c)]	-202	1,005
Change in value of hedged item used to determine hedge effectiveness [IFRS 7.24B(b)(i)]	202	1,005
Weighted average hedged rate for the year [IFRS 7.23B(b)]	8.1%	9.

xx) Significant judgements Interest rate benchmark reform Following the financial crisis, the reform and replacement of benchmark interest rates such as GBP LIBOR and other interbank offered rates (‘IBORs’) has become a priority for global regulators. There is currently uncertainty around the timing and precise nature of these changes. [IFRS 7.24H(b)] To transition existing contracts and agreements that reference GBP LIBOR to SONIA, adjustments for term differences and credit differences might need to be applied to SONIA, to enable the two benchmark rates to be economically equivalent on transition. Group treasury is managing the group’s GBP LIBOR transition plan. The greatest change will be amendments to the contractual terms of the GBP LIBOR-referenced floating-rate debt and the associated swap and the corresponding update of the hedge designation. However, the changed reference rate may also affect other systems, processes, risk and valuation models, as well as having tax and accounting implications. [IFRS 7.24H(c)] Relief applied The group has applied the following reliefs that were introduced by the amendments made to IFRS 9 Financial Instruments in September 2019: When considering the ‘highly probable’ requirement, the group has assumed that the GBP LIBOR interest rate on which the group’s hedged debt is based does not change as a result of IBOR reform. In assessing whether the hedge is expected to be highly effective on a forward-looking basis the group has assumed that the GBP LIBOR interest rate on which the cash flows of the hedged debt and the interest rate swap that hedges it are based is not altered by LIBOR reform. The group has not recycled the cash flow hedge reserve relating to the period after the reforms are expected to take effect. Assumptions made In calculating the change in fair value attributable to the hedged risk of floating-rate debt, the group has made the following assumptions that reflect its current expectations: The floating-rate debt will move to SONIA during 2022 and the spread will be similar to the spread included in the interest rate swap used as the hedging instrument. No other changes to the terms of the floating-rate debt are anticipated. The group has incorporated the uncertainty over when the floating-rate debt will move to SONIA, the resulting adjustment to the spread, and the other aspects of the reform that have not yet been finalised by adding an additional spread to the discount rate used in the calculation. [IFRS 7.24H(d)]

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