7.1 General
Under U.S. GAAP, ASC 860 is the primary source of guidance on
accounting for transfers and servicing of financial assets. Under IFRS Accounting
Standards, IFRS 9 is the primary source of guidance on accounting for transfers of
financial assets and initial recognition of servicing rights. IFRS 9 also is the
primary source of guidance on the recognition and measurement of all financial
assets and financial liabilities.
This chapter focuses on transfers and servicing of financial assets.
ASC 860 and IFRS 9 also provide guidance on accounting for collateral arrangements,
but this guidance is substantively the same. The table below summarizes some of the
key differences between IFRS Accounting Standards and U.S. GAAP with respect to
transfers and servicing of financial assets.1
Table
7-1
Subject
|
U.S. GAAP
|
IFRS Accounting Standards
|
---|---|---|
Transfers of financial assets — control versus risks
and rewards of ownership (see Section 7.2.1)
|
A control-based model is used. Under this model, each party
to a transfer of financial assets recognizes or continues to
recognize the assets that it controls and derecognizes
assets when control is surrendered.
|
A multistep derecognition model is used. Under this model, an
entity first considers risks and rewards, then considers
control. In certain arrangements, derecognition may apply
even when the asset is not transferred but the entity has an
offsetting obligation to pass through the cash flows of a
particular asset.
|
Transfers of financial assets — definition of control
(see Section
7.2.2)
|
Control of a financial asset is surrendered only if (1) the
transferred asset is legally isolated from the transferor
and its consolidated affiliates; (2) the transferee has the
ability to freely pledge or exchange the transferred
financial asset (or third-party beneficial interest holders
have the right to pledge or exchange the beneficial
interests if the transferee’s sole purpose is to engage in
securitization or asset-backed financing activities); and
(3) the transferor, its consolidated affiliates, or agents
do not maintain effective control over the transferred asset
through other rights.
|
Control of a financial asset is surrendered if the transferee
has the unilateral ability to sell that transferred asset.
However, control is not the sole determining factor in the
assessment of derecognition.
|
Transfers of financial assets — transfers of a portion
of a financial asset (see Section
7.2.3)
|
Derecognition of a portion of a financial asset is allowed if
the portion of the financial asset meets the definition of a
participating interest in ASC 860-10-40-6A and all the
conditions in ASC 860-10-40-4 through 40-5A are met for that
participating interest.
|
For a specified portion of a financial asset to be assessed
for derecognition, certain conditions must be met. If these
conditions are not met, the entire asset must be assessed
for derecognition.
|
Transfers of financial assets — retaining the rights
to the cash flows of a financial asset (“pass-through
arrangements”) (see Section
7.2.4)
|
Derecognition of a financial asset is not allowed if the
contractual rights to the cash flows of that asset are
retained.
|
An entity can derecognize a financial asset regardless of
whether it retains the right to the contractual cash flows
of that asset, provided that three restrictive conditions
for pass-through arrangements are met.
|
Transfers of financial assets — impact of a cleanup
call (see Section
7.2.5)
|
A call option held by a transferor that is also the servicer
and that meets the definition of a cleanup call does not
cause the transferor to maintain effective control over the
transferred financial assets.
|
Regardless of whether a call option is considered a cleanup
call, an entity must consider the effect of that call option
when determining whether substantially all the risks and
rewards of ownership of a financial asset are transferred or
retained and whether control over the financial asset is
surrendered.
|
Transfers of financial assets — repurchase agreements
(see Section
7.2.6)
|
An entity must consider the restrictive conditions in ASC
860-10-40-24 and 40-24A, in addition to the criteria in ASC
860-10-40-4 through 40-5A, when determining whether
continued recognition of a transferred financial asset
subject to a repurchase agreement is appropriate.
|
Conditions for derecognition that are specific to repurchase
agreements are not provided. Rather, derecognition of a
repurchase agreement must be determined on the basis of (1)
whether substantially all the risks and rewards of ownership
of the financial assets are transferred or retained and,
(2) in cases in which substantially all the risks and
rewards of ownership have been neither transferred
nor retained, whether control over the financial assets is
surrendered.
|
Transfers of financial assets — recognition and
measurement of a secured borrowing (see Section 7.2.7)
|
A secured borrowing equal to the consideration received must
be recognized if a transfer of financial assets fails to
qualify for derecognition. Guidance on the subsequent
measurement of a secured borrowing is not provided.
|
Recognition and measurement of a secured borrowing depend on
why the secured borrowing is being recognized. If a secured
borrowing is recognized because an entity retains
substantially all the risks and rewards of ownership of a
financial asset, a secured borrowing equal to the
consideration received is initially recognized. If a secured
borrowing is recognized because an entity has neither
retained nor transferred substantially all risks and rewards
but has retained control over the financial asset, the
secured borrowing is initially recognized only to the extent
of the entity’s continuing involvement in the transferred
asset.
|
Accounting for servicing rights — initial measurement
of a servicing asset (see Section
7.3.1)
|
A servicing asset must be initially recognized at fair value.
|
A servicing asset retained as part of a transfer of financial
assets is considered a retained interest in those
transferred assets. Therefore, the servicing asset is
initially recognized at its allocated previous carrying
amount on the basis of its relative fair value as of the
transfer date.
|
Accounting for servicing rights — subsequent
measurement of a servicing asset or liability (see Section 7.3.2)
|
An entity has the option of subsequently measuring a
servicing asset or liability at either fair value or
amortized cost.
|
Guidance is not provided on the subsequent measurement of a
servicing right because it is not considered a financial
instrument. In practice, entities often account for
servicing assets in accordance with IAS 38 and servicing
liabilities in accordance with IAS 37.
|
Footnotes
1
Differences are based on comparison of authoritative
literature under U.S. GAAP and IFRS Accounting Standards and do not
necessarily include interpretations of such literature.