6.3 Income Statement
6.3.1 Qualifying Hedging Relationships
ASC 815-20
45-1A For qualifying fair
value and cash flow hedges, an entity shall present both
of the following in earnings in the same income
statement line item that is used to present the earnings
effect of the hedged item:
-
The change in the fair value of the hedging instrument that is included in the assessment of hedge effectiveness
-
Amounts excluded from the assessment of hedge effectiveness in accordance with paragraphs 815-20-25-83A through 25-83B.
See paragraphs 815-20-55-79W through 55-79AD for related
implementation guidance.
As discussed in Section 3.1, gains and
losses on the derivative and the hedged item that are attributable to the hedged
risk in a qualifying fair value hedging relationship are recognized in earnings
and presented in the same income statement line item, which should be related to
the risk being hedged. As discussed in Section
4.1, changes in fair value attributable to components of the
hedging instrument that are included in the assessment of hedge effectiveness in
a qualifying cash flow hedging relationship are recorded in OCI. The changes in
fair value that are recorded in OCI are reclassified from AOCI into earnings
when the hedged item affects earnings and presented in earnings in the same line
item as the earnings effect of the hedged item.
In accordance with ASC 815, if the results of a qualifying hedging relationship
are recognized in earnings, they generally must be recognized in the income
statement line item related to the risk being hedged. For example, an entity
that is hedging interest payments on outstanding debt with an interest rate swap
should recognize any related gains and losses in interest expense. There are a
few exceptions to this rule, which are discussed in the next sections.
Chapters 3, 4, and 5 provide detailed
examples, many of which illustrate the income statement classification of gains
and losses related to qualifying hedging relationships.
6.3.1.1 Forecasted Transaction Will Probably Not Occur
ASC 815-20
45-1B For cash flow hedges
in which the hedged forecasted transaction is
probable of not occurring in accordance with
paragraph 815-30-40-5, this Subtopic provides no
guidance on the required income statement
classification of amounts reclassified from
accumulated other comprehensive income to
earnings.
If the hedged item is a forecasted transaction and it
becomes probable that the transaction will not occur within two months of
the originally specified time period, amounts are generally reclassified out
of AOCI (see Section 4.1.5.2). ASC 815
is silent on the income statement classification of such amounts in this
circumstance. We believe that an entity should exercise judgment in deciding
where to report amounts that are reclassified out of AOCI into earnings when
it becomes probable that a forecasted transaction will not occur within two
months of the originally specified time frame. The entity should disclose
where such amounts are reported and consistently apply any policy that it
develops. Even though the FASB decided not to require such amounts to be
recognized in the same line item in which the earnings effect of the
forecasted transaction would have been reported, entities are not precluded
from deciding to do so.
6.3.1.2 Excluded Components of Net Investment Hedge
ASC 815-20
45-1C For qualifying net
investment hedges, an entity shall present in the
same income statement line item that is used to
present the earnings effect of the hedged net
investment those amounts reclassified from
accumulated other comprehensive income to earnings.
This Subtopic provides no guidance on the required
income statement classification of amounts excluded
from the assessment of effectiveness in net
investment hedges.
As discussed in Section 5.4.2.1.1.1.2,
ASC 815-35 is silent on the income statement classification of amounts
related to excluded components of the derivative that are recognized in
earnings in connection with a hedging relationship in which the spot method is used. We believe that the FASB intended to allow entities to continue the practice they had used before the issuance of Statement 133. In many cases,
entities had viewed the “cost or income” of derivatives related to foreign
currency hedging as a financing cost, so they had recognized such amounts,
whether positive or negative, in interest expense. For many entities, the
decision to recognize such costs in interest expense was also driven by the
fact that they may also have issued foreign-currency-denominated debt to
finance the foreign operations. We believe that an entity should establish a
reasonable, consistently applied income statement classification policy and
disclose that policy in its financial statements.
6.3.1.3 Hedging on an After-Tax Basis
ASC 815-20-25-3(b)(2)(vi) allows an entity to hedge foreign currency risks on
an after-tax basis. If an entity uses an after-tax hedging strategy for cash
flow or net investment hedges, the portion of the gain or loss on the
hedging instrument that exceeds the loss or gain, respectively, on the
hedged item should be included as an offset to the related tax effects in
the period in which such effects are recognized (see Section 5.1.3).
6.3.2 Economic Hedging
In an economic hedge, an entity enters into a derivative to manage a risk (e.g.,
interest rate, currency, credit, or commodity), but the relationship is not
accounted for as a hedge under ASC 815. In such cases, either (1) the hedging
relationship fails to meet the rigorous requirements for hedge accounting or (2)
the hedging entity concludes that the costs of implementing hedge accounting
outweigh the benefits and thus does not designate the derivative in a qualifying
hedging relationship.
ASC 815 is silent on classification in the income statement of gains and losses
related to derivatives that are not in qualifying hedging relationships.
Consequently, there is diversity in practice regarding the presentation of such
results.
In a speech at the 2003 AICPA Conference on Current SEC
Developments, Gregory Faucette, a professional accounting fellow in the OCA,
made extensive comments on the income statement classification of derivatives.
Mr. Faucette addressed the following topics:
-
The classification of gains and losses on derivatives used in economic hedges in multiple income statement categories.
-
The inclusion of gains and losses on derivatives used in economic hedges in inappropriate financial statement captions.
With respect to the first topic, Mr. Faucette indicated that it would be
inappropriate for an entity to present gains and losses on a nonhedging
derivative under multiple captions in its income statement. For example, an
entity should not classify separately the unrealized gains and losses on an
economic derivative under the caption “risk management activities” while
classifying realized gains and losses on the same derivative (e.g., periodic or
final cash settlements) in a separate revenue or expense line item that may be
associated with the underlying in the economic hedge. Mr. Faucette’s discussion
echoed SEC staff comments made at the September
2003 AICPA SEC Regulations Committee’s joint meeting with
the SEC staff. At that meeting, the staff cited the following examples:
-
If an insurance company purchases a derivative to economically hedge the benefits paid on equity-indexed annuity products, it should record the premium paid for the derivative, the mark-to-market adjustment, and any realized gain or loss in the same line item on the income statement, despite the fact that the derivative is an economic hedge.
-
If net interest expense or income (e.g., net cash payments) is periodically recognized for an interest rate swap that does not qualify for hedge accounting, it should be recorded in the same line item as any unrealized and realized gains or losses recognized for that instrument.
With respect to the second topic, at the 2003 AICPA Conference on Current SEC
Developments, Mr. Faucette cited the following example of inappropriate income
statement classification of the results of a derivative used as an economic hedge:
For example, a financial institution classifying in the provision for
loan losses all changes in credit derivatives used as economic hedges
would not seem appropriate given the importance of that line item to
certain credit quality analyses.
The guidance from the SEC staff clearly addresses its views on an inappropriate
classification of credit derivatives in the income statements of financial
institutions. Also, it suggests that registrants should (1) carefully consider
whether it is appropriate to classify the results of derivatives used as
economic hedges in captions that are included in the determination of operating
income and (2) document the justification for such classification.
Typically, the income statement consequences of derivatives used as economic
hedges should be classified consistently with other gains and losses on
financial instruments or in accordance with specialized industry practice, if
any. Because many companies that are not financial institutions only incur such
gains and losses infrequently, classification as other income or expense is
common.
If a company classifies the income statement impact of derivatives used as
economic hedges in captions that would be considered part of operating income,
the factors to be considered include the following:
-
Is there a clear justification for the presentation that the company has chosen? Is there a clear relationship between the derivative activity and the other transactions classified in the same income statement caption?
-
Does the company have a documented policy for its income statement presentation and is that policy consistently followed?
-
Is it remote that the changes in the fair value or cash flows of the derivative could distort trends, especially in captions that are significant to users of the registrant’s financial statements?
-
Companies should consider significant timing differences between unrealized changes in the fair values of (1) the derivative used as an economic hedge and (2) the hedged item. For example, if cash flows on the derivative will not occur for a significant period, the unrealized changes in the derivative’s fair value easily might distort an income statement caption that includes current transactions that settle in a short period.
-
Has the company fully complied with the disclosure requirements of ASC 815-10-50?
-
Has the company considered the guidance in ASC 815-10-55-62 for physically settled derivative contracts that are not held for trading purposes?
See Section 7.3 of Deloitte’s Roadmap
Derivatives for discussion of
income statement geography for derivatives not held for hedging purposes (i.e.,
not in either qualifying hedges or economic hedges).