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1、fair value accounting in the banking sectormary pacaperscuthe financial instruments joint working group (jwg) of standard setters issued in december 2000 the consultative document entitled “draft standard and basis for conclusions financial instruments and similar items”. the draft standard reviews
2、and assesses an extensive use of fair value accounting (fva) as the basis for the valuation of all financial instruments in a banks balance sheet. the work of the jwg is linked to the long-term strategy of the international accounting standards committee (iasc) recently replaced by the international
3、 accounting standards board (iasb) to introduce a comprehensive fva framework for the recognition and measurement of financial instruments. the jwg invited comments on the draft standard from all interested parties by 30 september 2001. the iasb will evaluate the long-term prospects of fva in the li
4、ght of the comments received.this note conveys the comments of the european central bank (ecb) on an important dimension of the proposal put forward by the jwg, notably the application of fva to the banking sector. after reviewing the main innovations of the draft standard, the note focuses on the c
5、ritical aspects associated with the application of a full fva regime to the banking sector and presents a possible way forward.i. the main innovations of the draft standard for the banking sectorthe present accounting rules for banks in the european union distinguish between financial instruments he
6、ld for trading purposes (in the trading book) and those intended to be held to maturity (in the banking book). instruments held in the trading book are valued at market prices. a profit and/or loss arising from the revaluation of trading book instruments is recognised in the profit and loss account.
7、 the accounting rules for the trading book thereby take all market risks (i.e. price risk, interest rate risk, foreign exchange risk and liquidity risk) into account. banking book instruments, by contrast, are carried in the balance sheet at the lower of historical cost and market value. whereas a l
8、oss on a banking book instrument is transferred to the profit and loss account, unrealised gains are not recognised and can therefore become hidden reserves in the balance sheet. therefore, the accounting rules for the banking book do not take market risks into account (except for the foreign exchan
9、ge risk, where the end-period value is usually applied to almost all balance sheet items).the draft standard proposes a uniform rule for all financial instruments. the assets and liabilities are carried in the balance sheet at market values, if they are available, or at fair values calculated as an
10、approximation of the market value by using a present value model for discounting the expected future cash flow. for banks, this would imply that the trading and banking books would receive equal accounting treatment, whereby all changes in value would be recognised in the balance sheet and transferr
11、ed to the profit and loss account. the foreseen revaluation applies irrespective of whether a profit or loss has been realised or remains unrealised because all instruments are either marked to market or the fair value is estimated. the hidden reserves that may arise under the existing accounting ru
12、les thus disappear. market risks would be taken into account when calculating the value of financial instruments in both the trading and the banking book.ii. critical aspectsaccording to its proponents, an fva regime may constitute, from a conceptual point of view, an alternative approach to reporti
13、ng financial performance in order to avoid some of the problems associated with the current historical cost accounting. one of its main advantages would be to enhance the degree of transparency of financial statements. however, this point of view remains theoretical due to the absence of homogeneity
14、 and therefore comparability in fva methodologies. furthermore, the possible concrete application of a full fva regime (applying to all assets and liabilities) to the banking sector gives rise to some serious problems and concerns.the application of fva may be suitable for the trading book of banks,
15、 which refers to transactions (buying and selling) of marketable securities and related instruments with the objective of making a profit from short-term price variations. the use of fair value for these transactions is consistent with the availability of market prices and the short-term horizon. ho
16、wever, the application of fva to the banking book of banks, i.e. to non-negotiable instruments such as loans, appears to be inappropriate for at least three main reasons.first, the issue of relevance. fva principles do not reflect properly the way in which banks manage their core business, namely th
17、e granting of loans. the essence of bank management in this area lies in taking long-term decisions about credit quality and concentration and fostering customer relationships over the life of the contracts. it is less concerned about short-term variations that represent the basis for the use of fva
18、 principles. therefore, there is the possibility that the introduction of fva for the banking book might in principle create incentives for banks to alter their core business. this would be the case if banks decided to reduce their exposure to increased volatility of income (stemming from the accoun
19、ting recognition of interest rate risk in the banking book) by shortening the average maturity of loans. other ways to achieve the same goal would be the recourse to hedging techniques and the increased use of variable interest rates. the decision to reduce the average maturity of loans would depend
20、 also on other factors, including the nature of customer demand and the specific cost structure of individual banks.second, the issue of feasibility. there are serious doubts that an adequate fair value can be determined for bank loans, which are non-negotiable instruments precisely because they emb
21、ody elements that cannot be easily quantified in a standardised manner. first, there are, by definition, no secondary markets for these instruments. this is particularly true where credit risk markets do not appear to be sufficiently deep and liquid for the purpose concerned. second, some relevant i
22、nformation for the determination of the fair value of loans (i.e. that stemming from the bilateral relationship between the borrower and the lender) would never be priced in a market. third, the estimation techniques currently available (including the one proposed in the draft standard) suffer from
23、methodological problems (e.g. modelling of non-interest income, appropriate discount rate, etc.), which increase the risks of error. accordingly, they do not represent an effective benchmark for obtaining reliable fair values for loans. therefore, the application of fva to bank loans would give rise
24、 to many uncertainties hindering and working against the transparency and comparability of financial statements. it is acknowledged, however, that the current and future developments in banks credit risk management systems recognised also in the new capital adequacy regime proposed by the basel comm
25、ittee on banking supervision may provide accounting standard-setters with useful elements to refine their methodologies, in particular regarding the measurement of credit risk.doubts are also raised with regard to the application of fva to the liability side of banks. for instance, the suggested met
26、hodology (the so-called “own credit risk”) to determine the fair value of debt instruments issued by banks entails that, if the rating of a bank deteriorates, the value of its equity will ultimately increase (since the difference in revaluation of debt instruments is accounted in the profit and loss
27、 account). this outcome is counter-intuitive and can be misleading for shareholders and creditors.third, the issue of prudence. the use of fva in the banking book would entail that potential profits and losses would be treated in the same way, by being recognised as soon as they emerge. this goes ag
28、ainst the principle of prudence according to which losses stemming from the banking book should be recognised as soon as they are known, even if only potential, whereas profits should be recognised only if they are actually realised. potential profits should be recognised only for marketable instrum
29、ents. therefore, there is the possibility that the application of fva to the banking book might induce banks to adopt an imprudent behaviour. this is a crucial aspect also from the viewpoint of the banking supervisory function.iii. possible way forwardin light of the critical aspects mentioned above, the ecb has a negative stance towards the possibility of applying an fva regime to the banking book of banks. against this background, the following developments could be considered in order to make a constructive use of the valid arguments that lie behind fva.a first development w
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