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IFRS 9 vs ASC 815 Navigator

Groups reporting under both frameworks run two sets of rules on the same trades. These are the differences that change outcomes, with what each one means for you in practice.

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Material difference

4

of 14 topics

Different

9

of 14 topics

Broadly aligned

1

of 14 topics

Effectiveness

Effectiveness threshold

Material difference

IFRS 9

No bright line. Requires an economic relationship, credit risk not dominating the value changes, and a hedge ratio consistent with how risk is actually managed.

US GAAP · ASC 815

The hedge must be 'highly effective', which practice reads as offset within 80 to 125%.

So what

A hedge can qualify under IFRS 9 and fail ASC 815 on the same numbers. Dual reporters need both tests on file.

Effectiveness

Retrospective assessment

Different

IFRS 9

Assessment is prospective only. Ineffectiveness is still measured and recognised each period.

US GAAP · ASC 815

Prospective and retrospective assessments, at inception and at least every quarter.

So what

US GAAP needs a backward-looking test in the quarterly close; IFRS 9 needs the ineffectiveness calculation instead.

Effectiveness

Qualitative assessment

Different

IFRS 9

Qualitative assessment is acceptable where critical terms match closely; otherwise a quantitative method is needed.

US GAAP · ASC 815

After a quantitative test at inception, later assessments may be qualitative if the entity can reasonably support continued high effectiveness. Shortcut and critical-terms-match methods also exist.

So what

Both allow lighter-touch ongoing testing, but the evidence trail and eligibility conditions differ.

Qualification

Designation and documentation timing

Different

IFRS 9

Formal designation and documentation at inception of the hedging relationship.

US GAAP · ASC 815

Designation documented at inception, but the initial quantitative effectiveness test may be completed up to the first quarterly assessment date. Private companies get further relief.

So what

Missing inception documentation is fatal under both. US GAAP gives a short window for the number-crunching only.

Qualification

Risk components of non-financial items

Material difference

IFRS 9

Allowed if the component is separately identifiable and reliably measurable, whether or not it is contractually specified.

US GAAP · ASC 815

Allowed for forecast purchases or sales only where the component is contractually specified.

So what

Commodity hedgers can often hedge a market benchmark component under IFRS 9 that US GAAP would not allow, creating more ineffectiveness under ASC 815.

Qualification

Groups and net positions

Different

IFRS 9

Groups of items, including net positions, can be hedged items subject to conditions, with specific presentation rules.

US GAAP · ASC 815

Net positions are not eligible hedged items. A gross amount within the group must be designated instead.

So what

Treasuries that hedge net FX exposure need a gross designation workaround under US GAAP.

Measurement

Excluded components (time value, forward points, basis)

Different

IFRS 9

Option time value, and optionally forward points and currency basis, can be treated as a cost of hedging: deferred in OCI and released to profit or loss over the hedge period or with the hedged transaction.

US GAAP · ASC 815

Excluded components are recognised in earnings, either through a systematic and rational amortisation (with the remaining change in OCI) or at fair value each period.

So what

Both can smooth the cost of options and forward points, but the mechanics and disclosures differ.

Measurement

Cash flow hedge ineffectiveness

Material difference

IFRS 9

Lower-of test: the cash flow hedge reserve holds the lesser of the cumulative change in the instrument and the hedged item. Over-hedging ineffectiveness goes to profit or loss.

US GAAP · ASC 815

No separate measurement of ineffectiveness. The whole change in the instrument's fair value included in the assessment goes to OCI and is reclassified when the hedged item affects earnings.

So what

The same hedge can show P&L noise under IFRS 9 and none under US GAAP.

Discontinuation

Rebalancing

Different

IFRS 9

Required when the hedge ratio drifts but the risk management objective is unchanged. Rebalancing continues the relationship.

US GAAP · ASC 815

No rebalancing concept. Changes in the hedge mean de-designating and re-designating, in whole or in part.

So what

IFRS 9 lets you adjust without a restart. Under US GAAP every change is a new relationship with fresh documentation.

Discontinuation

Voluntary de-designation

Material difference

IFRS 9

Not permitted while the risk management objective for the relationship is unchanged and the criteria are still met.

US GAAP · ASC 815

Permitted at any time.

So what

IFRS 9 relationships are stickier. Design them carefully, because you may not be able to walk away.

Presentation

Income statement presentation

Different

IFRS 9

No general requirement to present hedge results in the hedged item's line. Net position hedges use a separate line.

US GAAP · ASC 815

The earnings effect of the hedging instrument must be presented in the same income statement line as the hedged item.

So what

Line-item mapping in the GL and consolidation tool often differs between the two reporting packs.

Effectiveness

Shortcut method

Different

IFRS 9

No shortcut method.

US GAAP · ASC 815

Qualifying interest rate swaps can assume perfect effectiveness under the shortcut method, if the strict conditions are met throughout.

So what

Shortcut is efficient but unforgiving: a failed condition can unwind the accounting back to inception.

Portfolios

Portfolio and macro interest rate hedging

Different

IFRS 9

IFRS 9 lets entities keep IAS 39 for portfolio fair value hedges of interest rate risk, including the EU carve-out. The IASB's dynamic risk management model is still in development.

US GAAP · ASC 815

The portfolio layer method allows fair value hedges of a layer of closed portfolios of prepayable financial assets.

So what

Banks run different macro models under each framework, and the IFRS side is set to change.

Qualification

Net investment hedges

Broadly aligned

IFRS 9

Permitted. The effective portion goes to the foreign currency translation reserve in OCI.

US GAAP · ASC 815

Permitted, assessed using a spot or forward method. Amounts go to the cumulative translation adjustment, with excluded components eligible for amortisation.

So what

Broadly aligned in outcome, with method choices worth matching across the two packs.

Method and caveats

A summary for orientation, written by practitioners who work across both frameworks. It is simplified by design and is not a substitute for the standards, your auditor's view, or advice on your facts.

Covers IFRS 9 hedge accounting (with IAS 39 where IFRS 9 allows it to continue) and ASC 815 as amended by ASU 2017-12 and the portfolio layer method.

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