小额信贷投资和国际财务报告准则公允价值的挑战

1、原文：Microfinance Investments and IFRS: The Fair Value Challenge Demand for microfinance products clearly exceeds supply: over 2.5 billion people, or 83% of the global market, lack access to financial services. One constraint that prevents microfinance institutions from reaching more customers is thei

2、r lack of access to refinancing. Given the scarcity of donor funds and the limits of long-term domestic funding sources, seeking funding are increasingly turning to international private capital markets.The hurdles MFIs face in attracting private capital are complex and profuse.2Industry-specific ch

3、aracteristics, including size, a dearth of regulation, lack of internationally-recognized ratings, and location in developing and transition countries impede MFI access to international capital markets. MFIs must also overcome the challenges of attracting private capital to a new asset class. Microf

4、inance does not fit neatly into institutional investment mandates, few institutional investors have microfinance expertise in-house, and the perception of microfinance as a risky asset class, as well as the high cost of thorough analysis relative to investment size, may discourage due diligence. Mor

5、eover, the total potential volume of institutional investors portfolios of microfinance instruments is very large relative to the limited number and small size of such investments. This may limit institutional investors ability to reap the benefits of diversification and may contribute to prohibitiv

6、ely high transaction costs. Yet for investors, the challenges of investing in microfinance as an asset class do not end once the investment is made. A different type of challenge may then arise: International Financial Reporting Standards (IFRS) require that investments be reported at fair value. Fo

7、r microfinance debt instruments, fair value is used pri-marily for informational purposes in the supporting balance sheet notes (see box 1). On the other hand, determining fair value for microfinance equity investments in the absence of reliable earnings and transaction data can be quite complex. Th

8、e purpose of this paper is to identify these challenges and to discuss how KfW approaches these issues on its way to full adoption of IFRS at year-end 2007. We begin with an overview of the current state of MFI funding and trends, focus-ing on equity and mezzanine funding. Next, we provide a brief b

9、ackground of IFRS, followed by a comparison of standard setters fair value definitions. We examine the options for determining fair value, including those based on market prices, and of most relevance to the case of microfinance, methodologies recommended for use in the absence of active markets. Fi

10、nally, we conclude with a brief summary. The largest overall source of MFI financing is domestic, including commercial loans, savings deposits for institutions with banking licenses, and retained earnings. Yet domestic sources also pose the greatest bottleneck, which is the dearth of long-term domes

11、tic funding sources in emerging markets. The lack of developed pension systems and institutional investor funds are the primary missing links. At the same time, only a small proportion of total MFI funding comes from for-eign investment, defined by CGAP as“quasi-commercial investment in equity, debt

12、, and guarantees, made by private-sector funding arms of bilateral and multi-lateral donor agencies (development investors); and by socially-motivated, privately managed investment funds financed by both public and private capital (social investment funds).Yet it is difficult to make generalizations

13、 about MFI funding sources, as they vary significantly with type of institution and maturity, among other variables. One way to categorize these differences is through a “tiered approach. We regard first tier MFIs as those that are sustainable on both a financial and operational basis. The 2nd tier

14、is comprised of promising MFIs on track toward becoming 1st tier institutions. Institutions seeking to retain their primary social objective, or unable to make the leap to financial and operational sustainability for other reasons, may prefer (and may be limited to) financing their operations throug

15、h grants and donationsthese institutions would be regarded as the 3rd tier.First tier institutions have the greatest access to domestic and international funding sources. They tend to be more mature and often have banking licenses, allowing them to fund themselves partially through deposits. Their “

16、formalization also subjects them to a higher level of regulatory oversight, in turn requiring a higher level of management, operational and systems competency all of which decrease their credit risk, which makes them more attractive to domestic commercial funding sources. Because of their financial

17、sustainability, the interest of private foreign investors focuses almost exclusively on this group.We began this paper by stating that one of the reasons 2.5 billion people lack access to financial services is that the institutions that would serve them lack funding particularly long-term funding. S

18、o where are these funding gaps? They lie in the 2nd tier MFIs. Third tier institutions have limited possibilities to attract foreign investment given their lack of operational and financial sustainability. Some may have little interest in taking on quasi-commercial funding as their founders may pres

19、ume that commercial funding would compromise the institutions social mission. The prospects for foreign investment in 2nd tier institutions, however, are promising. These institutions, often not licensed to accept deposits and deemed too high a credit risk for commercial loans, may not be attractive

20、 to domestic funding sources. This situation is a challenge foras well as the duty ofdevelopment financiers: they may provide support in the form of long-term refinancing as well as technical assistance for institutional improvement necessary to promote a 2nd tier institution to 1st tier statuswhile

21、 retaining the institutions reach and avoiding “mission drift.Expanding the 1st tier means more institutions will be able to access private capital, decreasing these institutions reliance on funding from development finance institutions (DFIs). Determining fair value for equity investments tends to

22、be more complex than for debt investments. The extent to which equity valuation issues will arise is a function of the percentage of equity and quasi-equity funding relative to debt: as MFIs tap international capital markets, what form will this funding take? According to a 2004 CGAP study, debt and

23、 equity accounted for 73% and 20% respectively of the USD 167.3 million in foreign investment in microfinance surveyed in the study. Some pundits have questioned a narrowing of this gap: a 2006 Council of Microfinance Equity Funds (CMEF) study identified just 199 MFIs as eligible for foreign equity

24、investments, underpinning the limited number of potential investees, making it more important to support 2nd tier institutions.Other opportunities for equity investment do exist. Two of the most salient are the upgrading of 2nd tier to 1st tier institutions, discussed above, and green field investme

25、nts in newly established MFIsboth of which require equity. The mini-mum capital adequacy requirement (CAR) under Basel I is 8% of risk-weighted assets, though an appropriate minimum capital level may be deemed to be much higherindeed, as high as 20% in the case of start-up banks in some developing c

26、ountries. Whether upgrading an existing institution into a bank or establishing a new one, risk capital is necessary, and its most likely source is donors. According to the International Accounting Standards Board (IASB), IFRS is comprised of the standards and their corresponding interpretations ado

27、pted by IASB, an independent and privately-funded accounting standards organization. Standards include International Accounting Standards (IAS), issued from 1973 to 2001 by the International Accounting Standards Committee, and IFRS issued by the IASB. Standards and topics range in scope and depth fr

28、om the presentation of financial statements to financial reporting in hyperinflationary economies.The standard relevant to valuing investments in MFIs is IAS 39, entitled “Financial Instruments: Recognition and Measurement. The objective of IAS 39 is “to establish principles for recognizing and meas

29、uring financial assets, financial liabilities and some contracts to buy or sell non-financial items. It requires that a financial asset or liability be recognized at fair value at initiation, including related transaction costs. Thereafter, equity instruments and embedded derivatives should be state

30、d at fair value whereas debt instruments are usually held at amortized cost depending on their classification into one of the categories defined in IAS 39.9 (see box 3). There is an important exception that is relevant to microfinance: “equity investments that do not have a quoted market price in an

31、 active market and whose fair value cannot be reliably measured .Determining fair value at investment initiation when the first funding transaction is made for a de nove entityis usually a simple task: according to IFRS, the transaction price is normally considered the fair value of an investment. T

32、he initial transaction price for a debt, equity or mezzanine investment in an existing microfinance institution or the subscription price for an equity stake in a green field transaction would be considered fair value. At remeasurement, the determination of fair value can be more complicated and a f

33、air value hierarchy, discussed below, must be applied. Market prices, when available, are considered the best gauge of fair value. According to IFRS, “The existence of published price quotations in an active market is the best evidence of fair value and when they exist they are used to measure the f

34、inancial asset or liability.Usually the current bid price in the most advantageous market is used as a basis, adjusted for necessary considerations such as differences in the credit risk profile of the counterparty. Yet market prices require active financial markets, which create a problem in valuin

35、g MFI Investments. Markets for MFI investments are neither active by any definition, nor do transactions occur on an arms length basis. (See below for more detail on microfinance secondary markets.) According to IFRS, “A financial market is quoted in an active market if quoted prices are readily and

36、 regularly available from an exchange, dealer, broker, industry group, pricing service or regulatory agency and those prices represent actual and regularly occurring market transactions on an arms length basis, this term referring to independent third-party transactions. In cases where current marke

37、t prices are unavailable, the task of determining fair value becomes more complicated. In such a case, the starting point for determining fair value is the price of the most recent transactionproviding that no“significant change in economic circumstances has taken place since that transaction settle

38、ment. If such a change has occurred, or if the reporting organization can prove that the price of the most recent transaction does not accurately represent fair value, then the market price is adjusted accordingly to arrive at fair value according to IAS 39. The initiation price of the investment it

39、self may be used as the fair value, or the price of a recent investment in the same entity by a different investing party may be used. The International Private Equity and Venture Capital Valuation Guide-lines (IPEVCVG) provide specific guidance as to events which may materially reduce current fair

40、value in relation to the investment initiation value: (1) the performance or prospects of the underlying business has significantly deteriorated relative to expectations at investment initiation; (2) a significant adverse change in the underlying business or business milieu has occurred; (3) market

41、conditions have declined; and (4) the underlying business is raising capital and evidence exists that future financing will take place under conditions materially different from the investment in question.The third point is of particular importance to microfinance investments and is relevant to both

42、 new and existing investors. Many microfinance investors are motivated by strategic considerations, including sustainable development and more specific social goals in addition to profit. If, as pundits predict, MFIs tap into private capital markets in the future, more profit-oriented investors may

43、join the ranks of the current social/mixed or dual objective investors in MFIs. In the future, profit-driven equity holders in a particular MFI may have to adjust for the dual or mixed goals of other investors in the same MFI when considering using the most recent transaction price as the fair value

44、. Markets for MFI investments are neither active by any definition, nor do transactions occur on an arms length basis: though the number of microfinance investors is growing, the number remains limited and many transactions take place between “related parties. Data on transactions among related part

45、ies, clearly violating the “arms length principle, cannot be used as a basis for determining the fair value of a “comparable transaction. The lack of an active secondary market for MFI investments precludes the use of published price quotations or recent transactions as a basis for calculating fair

46、value. Valuation options set out in IAS 39 include those based on recent transactions, the current fair value of a similar investment, option pricing models, or discounted cash flow analysis (DCF).While not discussing the methodologies in detail, IAS 39 outlines inputs to valuation techniques that s

47、hould be taken into consideration, including the time value of money, credit risk, foreign currency exchange prices, commodity prices, equity prices, volatility, prepayment risk and surrender risk, and the servicing costs for a financial asset or a financial liability.Source: Mark. "Guidelines&

48、quot;. International journal of business, June 2005:P23-25.译文：小额信贷投资和国际财务报告准那么:公允价值的挑战小额信贷产品在市场上显然已供不应求：可以说，有超过25亿人,或者说全球市场的83%缺乏金融效劳。阻碍小额信贷机构客户量的一个约束便是他们缺乏再融资的能力。考虑到赞助资金的缺乏和长期国内资金源的限制，越来越多筹集资金者开始涉足国际私营资本市场。小额信贷机构在吸引私人资本方面遇到的难题复杂且繁多。一些行业方面的特点包括开展中国家规模，规那么的缺乏和国际认证的等级，地理位置都不约而同阻碍了小额信贷机构向国际资本市场开展的脚步。小额

49、信贷机构还必须克服将私人资本吸引到一个全新的资产阶级的挑战。小额信贷并不能完美的融入到公司投资方案当中来，很少有公司投资者有自己的小额信贷专家，同时将小额信贷视作冒险资产阶级来全面分析投资规模带来的高本钱的理念往往也打击了这投资者的信心。除此之外，相对小额信贷投资的有限数量和小型规模，此类投资者的潜在投资总额是非常巨大的。这也许会限制此类公司投资者获取多元化利益的手段，同时也可能导致过高的贸易本钱。但是对投资者来说，在完成投资之后，为一个资产阶级投资小额信贷所带来的挑战远远没有结束。到时候可能会出现的另一类挑战便是国际财务报告准那么要求投资报告公允化。作为小额信贷借贷工具，公允价值首先应用在支

50、持资产负债表笔记的信息里。另一方面，在缺少可靠的收入以及交易信心的时候来确定小额信贷股权投资的公允价值是十分复杂的。这篇论文的目的便在于理清这些挑战并讨论复兴信贷银行是如何在2007年底一路解决国际财务报告准那么方面的难题的。首先我们先展望一下当前的小额信贷资金和趋势，将重点放在股权和夹层资金上。接下来，我们会提供简要的国际财务报告准那么的背景信息，并在第一时间与一些其他标准的公允价值进行比拟。我们检查了用来确定公允价值的因素包括基于市场价格的因素，与小额信贷关系最紧的因素以及在缺乏积极市场情况下推荐使用的方法论。最后，我们得出了一个简要的结论。小额信贷总体上最大的融资来源来自国内，包括商业贷

51、款，拥有银行执照的公司的储蓄和结余下来的薪水。然而国内的资源同样遇到很大的瓶颈，即新兴市场缺乏长期国内资金来源，缺乏完善的抚恤金制度和公司投资基金是主要的缺失环节。同时，小额信贷公司资金只有很小一局部来源于外国投资，这被注册政府审计专家定义为“双边和多变赞助机构开展投资者在股权，债务和担保人方面用有利于社会开展以及个体经营的投资资金的私人资金以及公私双重自主资本的准商业投资。然而要概括小额信贷机构来源仍非易事，因为来源由于公司种类，成熟度以及其他变数方面差异很大。可以统一这些差异的一个方法便是通过一个“分层的方法。我们认为第一层小额信贷机构在财务和操作根底方面都可持续的。第二层那么是由正在成为

52、第一层公司的小额信贷机构构成。那些寻求保存他们首要社会目的，或者由于其他原因不能获得财务和操作方面的可持续性的公司，或许会更倾向于或许受限于通过赞助和捐赠来扶持自己的运行-这些公司被划为第三层。第一层公司最有时机获得国内和国际的资金来源。他们往往更加成熟而且有银行执照，可以通过储蓄局部来增加自己的资金。他们的“正式化同时决定他们受上级的管制，从而反过来会要求公司拥有更高的管理，运营和制度条件。所有的这些降低了他们的信贷冒险，这让他们更受国内资金源的青睐。由于它们财务方面的可再生性，私营国外投资者的兴趣几乎都在这个群体之上。我们以陈述为何25亿人缺乏资金效劳的一个原因开题，即那些愿意为他们效劳的

53、公司们缺乏资金，尤其是长期资金。因此这些资金缺口究竟在哪呢？恰恰是在第二层小额信贷公司。第三层公司吸引外资的可能性很小，因为他们缺乏运营和资金的持续性。有些公司没什么兴趣接受准商业资金，因为他们的老板会认为商业资金会危及公司的社会人物。而第二层公司的外资前景那么是光明的。这些公司通常没有执照接受储蓄并对商业贷款来说太冒险，通常不容易吸引国内的资金源。这种处境对新投资者来说会是挑战也是一种责任：他们也许可以通过长期再融资和技术扶持来提供足够的帮助让第二层公司升级为第一层公司-同时保存公司的目标，防止改变任务。第一层公司的扩充意味着更多的公司可以获得私营资本，降低他们对新投资公司的依赖。确定股权投

54、资的公允价值通常比债务投资更加复杂。股权评估会在什么时候出现是由股权所占百分比和相对债务而言的准股权资金所占百分比决定的：当小额信贷公司试水国际资本市场的时候，这类资金会以何种形式出现？根据2004年CGAP的研究，债务和股权分别占了研究中调查的小额信贷外资总额1亿六千七百三十美元中的73%和20%。一些专家质疑了这个空缺的缩小：2006年小额信贷股权资金委员会研究说明仅有数量有限的199家小额信贷公司有资格为潜在投资寻求这一效劳，获得国外股权投资，这使得扶持第二层公司变得更加重要。股权投资的其他时机同样存在。两个最显著的便是如上所述的第二层公司向第一层公司的开展和新兴小额信贷公司的绿地投资他们两个都对股权有要求。最低资本充裕度的