Does measurement of expected credit losses appropriately reflect the impact of increased economic uncertainty?

Increased economic uncertainty caused by external events – e.g. a natural disaster, geopolitical events or pandemic – has had severe impacts across many jurisdictions. Governments, central banks and economists have been revising their economic forecasts to try to incorporate the likely impacts. However, the economic outlook may change quickly.

Companies are required to update the economic forecasts that they use to measure ECLs at each reporting date by incorporating the reasonable and supportable information available at that time. The effort and sophistication required will depend on the company’s exposures. ECLs are usually material for banks and other financial institutions: these companies are likely to continue to face the greatest challenges and will need to put the most resources into updating ECLs to reflect changing conditions. [IFRS 9.5.5.17]

The following factors may be particularly relevant when measuring ECLs.

• The increased economic uncertainty about potential future economic scenarios and their impact on credit losses may require companies to explicitly consider additional economic scenarios when measuring ECLs. [IFRS 9.B5.5.42]
• Existing ECL models use historical experience to derive links between changes in economic conditions and customer behaviour, and ECL parameters such as loss rates, probabilities of default and loss given default. However, these historical relationships are unlikely to remain stable in times of increased economic uncertainty. Therefore, adjustments to model results, based on expert credit judgement and the most recent economic data, could be necessary to reflect the information available at the reporting date appropriately.
• Certain types of customers, industries or regions may be affected by the increased economic uncertainty more than others. Companies with exposure to these customers, industries or regions will need to consider whether this exposure is captured appropriately in their ECL measurements.
• There may be impacts from government and central bank measures to mitigate the adverse impact of the increased economic uncertainty on banks and borrowers.
• Many borrowers may draw down credit lines or hold on to cash to obtain additional liquidity to help them weather the economic storms. This will be relevant for estimating exposures from loan commitments and prepayable or extendable loans.
• The expected cash flows used in measuring ECLs may also be affected by any actions planned by the company – e.g. modification, forbearance, limit extensions. [IFRS 9.5.5.12]
• Also, limit increases for credit cards may impact the period of exposures assessed under paragraph 5.5.20 of IFRS 9.

Disclosures

A company is required to disclose the nature and extent of risks arising from financial instruments and how it manages those risks. Therefore, a company will need to explain the significant impacts of increased economic uncertainty on the risks arising from financial instruments and how it is managing those risks. It will need to use judgement to determine the specific disclosures that are relevant to its business and necessary to meet these objectives. [IFRS 7.31]

Examples of specific disclosures include the following.

• Information about a company’s credit risk management practices and how they relate to the recognition and measurement of ECLs. A company may have changed its risk management practices in response to the impact of increased economic uncertainty – e.g. by extending debt relief to borrowers or by following specific guidance issued by governments or regulators. [IFRS 7.35F]
• The methods, assumptions and information used to measure ECLs – e.g. a company may need to explain how it has incorporated updated forward-looking information into measuring ECLs; in particular:
  • how it has dealt with the challenge of ECL models that were not designed for the economic shocks; and
  • how it has calculated overlays and adjustments to these models.
• Quantitative and qualitative information that allows evaluation of the amounts arising from ECLs; the types of analysis disclosed previously may need to be adjusted or supplemented to clearly convey the evolving impacts arising from the increased economic uncertainty. [IFRS 7.35H–L]
• Information on the assumptions that the company has made about the future and other major sources of estimation uncertainty at the reporting date that have a significant risk of resulting in material adjustment within the next financial year. [IAS 1.125]

Consider the following when measuring ECLs:

• whether additional economic scenarios are needed;
• whether adjustments to model results, based on expert credit judgement, are necessary;
• whether the measurement appropriately captures the types of customers/issuers or regions that are particularly impacted by the effects of increased economic uncertainty;
• changes in customer behaviour such as drawing more extensively on credit lines and holding on to cash;
• the impact of any assistance to borrowers from a government or regulator; and
• the impact of any actions planned by the company (e.g. modification, forbearance, limit increases) on the expected cash flows.