IFRSUSGAAPdifferences

1、Comp arison of IAS 32 and IAS 39 and US GAA P1 / 30The followi ng table ide ntifies differe nces betwee n the acco unting models in cluded in IAS 32 and IAS 39 and the related US GAA P guida nee that may result in sig nifica nt differe nces betwee n US GAAP and IFRS.AreaIAS 32 and IAS 39US GAA PComp

2、 aris onDefin iti on - DerivativeA derivative is a finan cial in strume nt:(a)(b)whose value cha nges in response to the cha nge in a sp ecified in terest rate, security p rice, commodity p rice, foreig n excha nge rate, in dex of p rices or rates, a credit rat ing or credit in dex, or similar varia

3、ble (sometimes called the 'un derly in g');that requires no in itial net in vestme nt or little in itial n et in vestme nt relative to other types of con tracts that have a similar res ponse to cha nges in market con diti ons; andthat is settled at a future date.(c)IAS 39.9A derivative in st

4、rume nt is a finan cial in strume nt or other con tract with all three of the followi ng characteristics:(a)It has (1) one or more un derly ings and (2) one or more no ti onal amounts or p ayme nt p rovisi ons or both.It requires no in itial net in vestme nt or an in itial net in vestme nt that is s

5、maller tha n would be required for other types of con tracts that would be exp ected to have a similar response to cha nges in market factors.Its terms require or permit net settleme nt, it can readily be settled net by a means outside the con tract, or it provides for delivery of an asset that puts

6、 the recipient in a po siti on not substa ntially differe nt from net settleme nt.FAS 133, para 6(b)(c)reciDefinition -Firm Commitme ntA firm commitme nt is a binding agreeme nt for the excha nge of a sp ecified qua ntity of resources at a sp ecified price on a sp ecified future date or dates.A firm

7、 commitme nt is an agreeme nt with an un related p arty, binding on both p arties and usually legally en forceable, with the followi ng characteristics:The defi niti ons of a derivative in IAS 39 and FAS 133 are sig nifica ntly differe nt that the popu lati on of con tracts meet ing the defi niti on

8、 un der each sta ndard will differ. FAS 133 requires a con tract to have the ability to“ net settleIAS 39 requires“ settlemefittatedate. ”For exa mple, prep aid con tractsmay not satisfy the settleme nt characteristic in IAS 39 however they may satisfy FAS 133' s “ net settlrequireme nt. ”IAS 39

9、 does not defi neemerlittle in itial nees ainvestment ' , whereas FAS 149 provid defi niti onAs a con diti on to meet the defi niti on of a firm commitme nt, US GAAP requires that the agreeme nt in cludes a sufficie ntly large dis incen tive for nonp erforma nee,AreaIAS 32 and IAS 39US GAAPComp

10、aris onIAS 39.9a. The agreement specifies all significantterms, in cludi ng the qua ntity to be excha nged, the fixed p rice, and the tim ing of the tran sact ion. The fixed price may be exp ressed as a sp ecified amount of an entity' s functionalcurre ncy or of a foreig n curre ncy. It may also

11、 be exp ressed as a sp ecifiedin terest rate or sp ecified effective yield.b. The agreement includes a disincentive for nonp erforma nee that is sufficie ntiv large to make performa nee probable.FAS 133, 540otherwise, the agreeme nt may satisfy the net settleme nt requireme nt in p aragra ph 6. Sinc

12、e IAS 39 does not require net settleme nt for satisfy ing the defi niti on of a derivative, it does not require the existe nee of such a pen alty in order to meet the defi niti on of a firm commitme nt.3Derivative Scope - Physical VariablesIFRS 4 amen ded IAS 39 to i nclude weather derivatives in th

13、e scope of IAS 39 IAS 39.2 (e)4Derivative Scope - Nonfinan cial Asset & LiabilitiesA similar exe mp ti on does not exist in IAS 39.Non-excha nged traded con tracts with an un derly ing based on the p rice or value of (a) a nonfinan cial asset of one of the p arties to the con tract p rovided tha

14、t the asset is not readily con vertible to cash or (b) a nonfinan cial liability of one of the p arties to the con tract p rovided that the liability does not require delivery of an asset that is readily con vertible to cash is not con sidered a derivative.FAS 133, 10e(2)A similar exe mp ti on to th

15、e exe mp ti on in FAS 133 does n ot exist in IAS.Accord in gly, an op ti on on non-finan cial assets may be con sidered a derivative un der IAS but not un der US GAAP.5Derivative Scope - Normal Purchases /Commitme nts to buy or sell non-finan cial assets and liabilities that are inten ded to be sett

16、led by theNormal pu rchases and no rmal sales are con tracts that p rovide for the pu rchase orMore con tracts are likely to qualify for the no rmal pu rchases and sales3 / 30AreaIAS 32 and IAS 39US GAA PComp aris onSalesreporting en ter prise by making or tak ing delivery in the no rmal course of b

17、us in ess, and for which there is no p ractice of settl ing n et (either with the coun ter party or by en teri ng into offsett ing con tracts), are not acco un ted for as derivatives but rather as executory con tractsIAS 39.6-7exe mp ti on in IAS 39 as the requireme nts to qualify for this exe mp ti

18、 on are less str ingent in IAS 39 than in FAS 133.sale of somethi ng other tha n a finan cial in strume nt or derivative in strume nt that will be delivered in qua ntities exp ected to be used or sold by the reporting en tity over a reas on able p eriod in the no rmal course of bus in ess. However,

19、con tracts that have a p rice based on an un derly ing that is not clearly and closely related to the asset being sold or pu rchased (such as a price in a con tract for the sale of a grain commodity based in part on cha nges in the S&P in dex) or that are denomin ated in a foreig n curre ncy tha

20、t meets n either of the criteria in p aragra phs 15(a) and 15(b) shall not be con sidered no rmal p urchases and no rmal sales. Con tracts that contain net settleme nt p rovisi ons as described in p aragra phs 9(a) and 9(b) may qualify for the n ormal p urchases and no rmal sales exce pti on if it i

21、s p robable at incep ti on and throughout the term of the in dividual con tract that the con tract will not settle net and will result in p hysical delivery. Net settleme nt (as described in p aragra phs 9(a) and 9(b) of con tracts in a gro up of con tracts similarly desig nated as no rmal p urchase

22、s and no rmal sales would call into questi on the classificati on of all such con tracts as n ormal p urchases or n ormal sales. Con tracts that require cash settleme nts of gains or losses or are otherwise settled net on a p eriodic basis, in cludi ng in dividual con tracts that are part of a serie

23、s of seque ntial con tracts inten ded to5 / 30acco mp lish ultimate acquisiti on or sale of a commodity, do not qualify for this exce pti on. For con tracts that qualify for the n ormal pu rchases and no rmal sales exce pti on, the en tity shall docume nt the basis for con cludi ng that it is p roba

24、ble that the con tract will result in p hysical delivery. The docume ntati on requireme nts can be app lied either to groups of similarly desig nated con tracts or to each in dividual con tract.FAS 133,10(b)Derivative Scope - Regular-Way Exemp ti onIf an enterp rise con tracts to buy a finan cial as

25、set on terms that require delivery of the asset within the time frame established gen erally by regulati on or conven ti on in the market place concerned (sometimes called a 'regular way' con tract), the fixed price commitme nt betwee n trade date and settleme nt date is a forward con tract

26、that meets the defi niti on of a derivative. However, regular way con tracts should not be recog ni sed as a derivative in the finan cial stateme nts. Regular way con tracts should be acco un ted for based on the guida nee p rovided in p aragra phs 38 and AG53-56IAS 39 AG12A con tract that allows fo

27、r or requires net settleme nt should not be acco un ted for as a“ regular way ” con tract.IAS 39 AG54Regular-way security trades exe mpts con tracts from being acco un ted for as derivatives if all the followi ng con diti ons are met:Con tract requires delivery of securities that are readily con ver

28、tible to cashCon tract does not in clude net settleme nt p rovisi onsThere is no market mecha nism to facilitate net settleme ntDelivery is required within the time gen erally established by regulati ons or conven ti ons in the market place or excha nge in which the tran sact ion is being executed.F

29、AS 133, 10a and 58aDerivative Scope -Loa n commitme nts that cannot be settled net inLoa n commitme nts that relate to theThe exe mp ti on in IAS 39 is broader because it app lies to all types of finan cial assets whereas the exe mp ti on in FAS 133 is limited to tran sactio ns in volv ing securitie

30、s only. Additi on ally, the exem ption in FAS 133 is further limited to trades that are readily con vertible to cash and do not in clude the other net settleme nt mecha ni sms.FAS 133 in cludes a sp ecific exe mp ti onAreaIAS 32 and IAS 39US GAA PComp aris onLoa n Commitme ntsDerivative Scope - Equi

31、tyDefinition -Written Equity Put (Issuer persp ective)'s owiAeqUtten put on a company's commoiMstacContracts are likely to be exemptcash or ano ther finan cial in strume nt are excluded from scope unl ess a finan cial liability desig nated at fair value through pr ofit or loss.An issuer of a

32、 commitme nt to pr ovide a loa n at a below-market in terest rate shall in itially recog nise it at fair value, and subseque ntly measure it at the higher of (i) the amou nt recog ni sed un der IAS 37 and (ii) the amou nt in itially recog ni sed less, where approp riate, cumulative amortisati on rec

33、og ni sed in accordanee withIAS 18 . An issuer of loancommitments shall applyIAS 37 to other loancommitme nts that are not with in the scope of this Sta ndard.IAS 39.2(h) and 39.4Equity in strume nts issued by the reporting enterp rise in cludi ng op ti ons, warra nts, and other finan cial in strume

34、 nts that are classified as shareholders' equity of the reporting only whe n settled by excha nging a fixed nu mber of own equity shares for a fixed amount of cash.IAS 39.2(b) and IAS 32.22A writte n put op ti on on a company is'considred an equity in strume nt only if settled by excha nging

35、 a fixed nu mber of own quity shares for a fixed amount of cashIAS 32.22origi nati on or acquisiti on of mortgage loa ns that will be held for sale, as discussed in p aragra phs 21 and 23 of Stateme nt 65 (as ame nded), must be acco un ted for as derivatives. Loa n commitme nts that relate to the or

36、igi nati on or acquisiti on of mortgage loans that will be held for in vestme nt, as discussed in p aragra ph 25 of Stateme nt 65 (as ame nded), and other types of loa ns (nonmortgage) should not be acco un ted for as derivatives.FAS 149, DIG issue C13Con tracts issued or held by the reporting en ti

37、ty that are (1) in dexed to its own stock and (2) classified in stockholders its stateme nt of finan cial po siti on.FAS 133, 11a is con sidered to be equity if it is settleable in either of the follow ing manners and the con ditio ns in par 12 through 32 of EITF 0019 are satisfied:Net share settlem

38、e ntPhysical settleme nt (cash for shares)If mult iple settleme nt op ti ons are p rovided, the n the holder must not have from the defi niti on of a derivative for all loan commitme nts that relate to loa ns other tha n mortgage loa ns that will be held for sale. Loa n commitme nts that relate to m

39、ortgage loa ns that will be held for sale are gen erally acco un ted for as derivatives. IAS 39 does not contain a similar exe mp ti on as in FAS 133.No similar guida nee in US GAAP for below-market loa n commitme ntsIAS 39 exe mpts only those con tracts issued by the reporting en tity are 'clas

40、pjftednas part of shareholders equity, whereas FAS 133 exe mpts all con tracts (issued or pu rchased) that are in dexed to the reporting company and are classified in shareholders equity. Accord in gly, more con tracts are likely to be exempt un der FAS 133.un der FAS 133 because IAS 39 only exe mpt

41、s written put op tions on its own stock that can beeihefnet or gross share settled (without an option to net cash or physically settle).However, FAS 33exem pts con tracts that do not require the issuing entity to net cash settle.9 / 30AreaIAS 32 and IAS 39US GAAPComp aris onthe op ti on to select ne

42、t cash settleme nt and the settleme nt op ti ons may in clude net share or p hysical settleme ntOtherwise, the writte n op ti on is a derivative if it satisfies the defi niti on of a derivative.FAS 133. 11 and EITF 00-1910Scope -Sales Volume and Service RevenueIAS 39 does not exe mpt con tracts that

43、 are based on sales volumes.IAS 39 IG B.8However, royalty agreeme nts are not con sidered derivatives.IAS 39 AG2Certa in con tracts that are not traded on an excha nge are not subject to FAS 133 if the un derly ing on which the settleme nt is based on are sp ecified volumes of sales or service reve

44、nues of one of the p arties to the con tract. FAS 133.10 e (3)More con tracts are likely to be exe mpt un der FAS 133 because IAS 39 does not in clude an exe mp ti on for con tracts with an un derl ying based on a sales volume of a p arty to the con tract.HTM -sales fromHTM categoryProhibited from u

45、sing HTM classificati on for the n ext 2 years.IAS 39.9Prohibited from using the HTM classificati onUn der IAS it would be po ssible to use the HTM classificati on two years follow ing tain ti ng. No similar time frame exists in FAS 133NPSEE&Y Q&A 39.5-A-Commodity con tract e nteredinto p ar

46、tly for exp ected pu rchase requireme ntsThere exists the poten tial for certa in NPSE con tracts to require sep arati on of an embedded writte n op ti on un der IASNPSE -embedded derivativesWritte n op ti ons embedded in non finan cial con tracts may require sep arati on if po ssible to settle net

47、in accorda nee with IAS 39.6 (a) or (d)E&Y Q&A 39.7-A-Writte n non-financial itemop ti ons in cluded in delivery con tactsgNot p ermitted.Con tracts that qualify for NPSE are not assessed for embedded derivatives that may require bifurcati on.10 (b) 4 DIG Issue B1811Embedded Derivatives -IAS

48、 39 does not p rovide any gra ndfatheri ng p rovisi ons for embedded derivatives.At the date of in itial app licati on, an en tity shall choose to either (a) recog nize as anIFC elected to gran dfather all embedded derivatives in con tracts en tered intoGran dfatheri ngasset or liability in the stat

49、eme nt of finan cial po siti on all embedded derivative in strume nts that are required pu rsua nt to p aragra phs 1216 to be sep arated from their host con tracts or (b) select either Jan uary 1, 1998 or January 1, 1999 as a tran siti on date for embedded derivatives (therefore, gra ndfatheri ng co

50、n tracts en tered into before the selected date and not substa ntially modified thereafter).FAS 133, par 50prior to 1/1/99 for US GAAP purposes. IFC will n ot be able to gran dfather those same con tracts for IAS 39 purpo ses. Thus, more embedded derivatives will have to be acco un ted for sep arate

51、ly in its IAS finan cial stateme nts.12Determi ning Fair Value of Embedded DerivativeSince the embedded derivative must be recorded at fair value with cha nges in fair value rep orted in p rofit or loss, the in itial carrying amount assig ned to the host con tract on sep arati on is determ ined as t

52、he differe nee betwee n the cost (fair value of the con siderati on give n) for the hybrid (comb in ed) in strume nt and the fair value of the embedded derivative.IAS 39 AG28, IAS 32.31If an enterp rise is required to sep arate an embedded derivative and is able to reliably measure the fair value of

53、 the en tire in strume nt and of the host con tract, the differe nee betwee n the two values p rovides reliable evide nee of the fair value of the embedded derivative. This an swer does not affect the ide ntificati on of the terms of an embedded derivative on in itial recog niti on.IAS 39.11-12The a

54、llocati on method that records the embedded derivative at fair value and determ ines the in itial carry ing value assig ned to the host con tract as the differe nee betwee n the basis of the hybrid in strume nt and the fair value of the embedded derivative should be used to determ ine the carry ing

55、values of the host con tract component and the embedded derivative component of a hybrid in strume nt whe n sep arate acco un ti ng for the embedded derivative is required by Stateme nt 133.Both IAS and US GAAP state that in order to allocate the in itial basis of the hybrid con tract to the host in

56、 strume nt and the embedded derivative one must determ ine the in itial fair value of the host in strume nt by subtract ing the in itial fair value of the embedded derivative from the in itial basis of the hybrid con tract. IAS 39 offers an alter native when the fair value of the embedded derivative

57、 is not reliable measurable. In such cases, IAS 39 p ermits one to calculate the fair value of the embedded derivative as the differe nee betwee n the in itial basis of the hybrid con tract and the fair value of the host. Eve n though US GAAP does not have a similar interp retati on to IAS, such an

58、app licati on may be p erformed in p ractice.DIG B6AreaIAS 32 and IAS 39US GAAPComp aris on13Embedded Derivatives -Term Exte nding Op ti onsTerm exte nding op ti ons in debt in strume nts are not closely related if there is not a con curre nt adjustme nt to the market rate of in terest at the time of exerciseIAS 39 AG30(c)Term exte nding op ti ons i