Accounting for Interest Rate Derivatives. Frank Wilary and Douglas Winn

Transcription

1 Accounting for Interest Rate Derivatives FAS ASC 815 Presented by Frank Wilary and Douglas Winn May 1,

2 Describe hedge accounting and provide examples Address hedge effectiveness testingti Define hedge ineffectiveness testing vs. bookkeeping Provide alternative to hedge accounting We will briefly revisit certain items from our prior webinar on the rule itself 2

3 Derivatives must be accounted for and reported at fair value Three options to decrease resulting income statement volatility: 1. Fair Value Hedge Accounting 2. Fair Value Accounting 3. Cash Flow Hedge Accounting 3

4 1. Fair value hedge Two types of hedge accounting Change in fair value of the hedging instrument t runs through the income statement, along with the change in the fair value of the item being hedged used for existing financial assets and liabilities 2. Cash flow hedge Effective portion of the hedge is reported in Other Comprehensive Income, while the ineffective portion is reported in current earnings used for forecasted transactions or variable payments on existing financial assets and liabilities 4

5 Type of accounting depends on the item being hedged Credit Union enters into a Pay Fixed, Receive Floating Interest Rate Swap Fair Value Hedge Example: CU wants to hedge against the decrease in fair value of a fixed rate loan portfolio defines hedge as change in benchmark interest rate If benchmark interest t rate increases, fair value of the loans will decrease, and the fair value of the swap will increase. Change in each runs through the income statement Cash Flow Hedge Example: CU wants to hedge against increase in cost of its floating non-maturity deposits. Defines hedge as risk of an increase in the forecasted payments to its members. Effective portion will run through h OCI 5

6 Formal designation and documentation required at inception The CU s objective and strategy for the hedge must include: The hedging instrument the derivative (interest rate swap, interest rate floor, interest rate cap, etc.) The hedged item or transaction the asset or liability being hedged The nature of the risk being hedged interest rate risk The method that will be used to retrospectively and prospectively measure the hedge s effectiveness 6

7 The method that will be used to measure hedge ineffectiveness Benchmark interest rate being hedged Eligible benchmark rates are: Treasury rates Federal funds effective swap rate LIBOR In addition, for cash flow hedges the following information about forecasted transactions must be provided: Date on which transaction will occur Specific nature of asset or liability Quantity of the forecasted transaction 7

8 NCUA authorizes credit unions to use only the following derivatives: Interest Rate Swaps An agreement to exchange future payments of interest on a notional amount at specific times and for a specific time period Interest Rate Caps A contract, based on a reference interest rate, for payment to the purchaser when the reference interest rate rises above the level specified in the contract Interest Rate Floors A contract, based on a reference interest rate, for payment to the purchaser when the reference interest rate falls below the level l specified in the contract t 8

9 Note: Basis Swaps An agreement between two parties in which the parties make periodic payments to each other based on floating rate indices multiplied by a notional amount Treasury Note futures A U.S. Treasury note financial contract that obligates the buyer to take delivery of Treasury notes (or the seller to deliver Treasury notes) at a predetermined future date and price. Futures contracts are standardized to facilitate trading on an exchange Wilary Winn Risk Management believes all of the derivatives permitted by the NCUA meet the definition of a derivative under GAAP. 9

10 Notional Amount Limitit o Takes into account type of derivative, time to maturity and net worth Fair Value Loss Limit o Loss limit does not include hedge benefit measures the derivatives only o Limit is based on net aggregate loss of derivatives and net worth worth Entry Standard Limits Limits Total fair value Weighted average remaining maturity - notional

11 Cannot net offsetting transaction calculation is cumulative Step #1 Gross Adjust Factor Product National (Percent) Step #2 Adjusted Notional Step #3 WARM Options (Caps) Current notional 33 33% of current notional Time remaining to maturity Options (Floors) Current notional 33 33% of current notional Time remaining to maturity Swaps Current notional % of current notional Time remaining to maturity Futures Contract size % of contract size Underlying contract Sum = Total adjusted notional Sum = Overall WARM WARMN = Adjusted notional * (WARM/10) 11

12 To qualify for hedge accounting, the hedging g relationship (both at inception of the hedge and on an ongoing basis), shall be expected to be highly effective in achieving either of the following: Offsetting changes in fair value attributable to the hedged risk during the period that the hedge is designated - a fair value hedge Offsetting cash flows attributable to the hedged risk during the term of the hedge - a cash flow hedge 12

13 Hedge Effectiveness can be measured in two ways: 1. Dollar-offset approach Compares changes in fair value or cash flow of the hedged item and the derivative Can be applied period by period (cannot be less than 3 months) or cumulatively Most believe a dollar offset range of 80%-125% would be considered d highly effective 2. Statistical methodologies May permit a CU to continue to use hedge accounting for the current period even though the dollar-offset approach appears ineffective Complex to implement and requires multiple observation periods 13

14 Dollar-Offset Approach Example $50 MM pay fixed / receive floating 5-year interest rate swap Hedged item a group of fixed rate investments held AFS Market Rate Net Swap Change in Change in Change From Swap Fair Swap Investments Dollar Effective Month Inception Payment Value Fair Value Fair Value Offset % (y / n) Mo. 0 0b bps 0 Mo bps (68,950) (166,293) (166,293) 140, % yes Mo bps (71,327) (214,920) (48,627) 65, % no Mo bps (73,705) (371,804) (156,884) 150, % yes Mo bps (71,488) (181,349) 190,455 (140,757) 135.3% no Mo bps (62,835) 437, ,538 (625,865) 98.8% yes Total (348,305) 437,189 (410,361) 106.5% yes 14

15 Statistical Approaches Regression Analysis Minimum of 30 observations Must consider changes in the value of the derivative and the hedged item Time horizon must coincide or be less than the time horizon of the hedge relationship Must consider whether to regress value changes or value levels Must review distribution of error terms 15

16 Statistical Approaches Regression Analysis Continued R-squared result must exceed a pre-specified level (e.g. 0.80) Hedge relationship must correspond to beta (the slope of the regression line) Standard error must be used to calculate the reliability using the t statistic T-test must be passed at a 95% confidence level Must consider y-intercept Must compare results to dollar offset results 16

17 Statistical Approach Example R-squared Analysis Hedged item floating dividend rate on money market shares Mo LIBOR Line Fit Plot 1.40 Dividend Ra ate Div. Rate Predicted Div. Rate Mo LIBOR 17

18 Polling Question #1 If you have performed effectiveness testing in the past, what method did you use? Dollar offset Regression analysis Other statistical method Have not performed effectiveness testing 18

19 A credit union shall consider hedge effectiveness in two different ways: 1. Prospective Considerations 2. Retrospective Evaluations 19

20 Prospective Considerations Can be based on regression or other statistical analysis of past changes in fair values or cash flows as well as on other relevant information Shall consider all reasonably possible changes in fair value (if a fair value hedge) or in fair value or cash flows (if a cash flow hedge) of the derivative instrument t and the hedged d items for the period used to assess whether the requirement for expectation of highly effective offset is satisfied Not be limited only to the likely or expected changes in fair value (if a fair value hedge) or in fair value or cash flow (if a cash flow hedge) Generally involves a probability-weighted analysis consistent with FASB Concepts Statement No. 7 20

21 Retrospective Considerations An assessment of effectiveness shall be performed whenever financial statements or earnings are reported, and at least every three months Can be based on dollar offset or statistical approaches Dollar-offset measurement can be for period or cumulative Statistical methods must be similar period to period (e.g. same number of data points) 21

22 What if the hedge is not or no longer effective? The hedge accounting is discontinued prospectively, resulting in potential income statement volatility as the derivative is marked to market with no offset to the hedged item 22

23 Hedge ineffectiveness is measured by the Dollar-offset method Fair Value Hedge: Hedge ineffectiveness flows through the income statement based on any difference between the change in the value of the derivative and the change in value of the hedged item Cash Flow Hedge: Ineffectiveness must be separately measured and recorded on the income statement. If the fair value of the derivative changes by more than the present value of hedged cash flows, the difference is the ineffective amount. If the fair value of the hedged cash flows changes by more than the change in the fair value of the derivative then no ineffectiveness 23

24 Entities can assume no ineffectiveness in an interest rate swap in two instances: 1. A private company that enters into a pay fixed, receive floating interest rate swap (this exemption does not apply to financial institutions) 2. A swap can be examined to determine if it can be accounted for under the Short-Cut Method (this applies to all companies, including financial institutions) 24

25 To conclude no hedge ineffectiveness in a hedge with an interest rate swap, all of the following conditions must be met: Notional amount of swap matches principal amount of item being hedged Fair value of the swap is zero at inception Note: For the purposed of determining zero: can ignore bid/ask spread at inception, commissions, and other transaction costs 25

26 Formula for computing net settlements remains the same throughout the swap Fixed rate remains the same Variable rate index does not change Interest bearing asset or liability is not pre-payable Unless the prepayment is due to an embedded call (put) option and the swap has a mirror option call (put) option - options must mach exactly Because the NCUA does not allow a credit union to enter into a swap with this feature, we believe a swap involving loans that can be prepaid p will not qualify for the short-cut method Index on which the variable rate leg is based matches the benchmark interest rate designated as the interest rate being hedged 26

27 WW Risk Management does not recommend the short-cut method, because if you fail, you cannot reassess. We recommend that a credit union account for the swap using the long-haul method, recognizing that swaps that would qualify for the short-cut method will easily pass the effectiveness testing 27

28 As asset or liability is eligible for designation as a hedged item in a fair value hedge if all of the following criteria are met: The hedged item is specifically identified as either all or a specific portion of a recognized asset or liability or of an unrecognized firm commitment The hedged item presents an exposure to changes in fair value attributable to the hedged risk that could affect reported earnings 28

29 The hedged item is a single asset or liability (or a specific portion thereof) or is a portfolio of similar il assets or similar il liabilities (or a specific portion thereof) o If similar assets or similar liabilities are aggregated and hedged as a portfolio, the individual assets or liabilities shall share the risk exposure generally proportionate change in fair value o If the specific portion of an asset or liability then one or more selected contractual cash flows, including one or more individual interest payments during a selected portion of the term of a debt instrument (such as the portion of the asset or liability representing the present value of the interest payments in the first two years of a four-year debt instrument). o A put option or call option (including an interest rate cap or price cap or an interest rate floor or price floor) embedded in an existing asset or liability that is not an embedded derivative accounted for separately 29

30 If the hedged item is a financial asset or liability or a recognized loan servicing i right, the designated d risk being hedged d is any of the following: o The risk of changes in the overall fair value of the entire hedged item o The risk of changes in its fair value attributable t bl to changes in the designated benchmark interest rate (referred to as interest rate risk) o The risk of changes in its fair value attributable to both of the following (referred to as credit risk): Changes in the obligor s creditworthiness Changes in the spread over the benchmark interest rate with respect to the hedged item s credit sector at inception of the hedge 30

31 Change in fair value for each item in the portfolio must be within a fairly narrow range such as 9 to 11%. On the other hand, a range of 7 to 13% would not meet the similar portfolio requirement 31

32 In aggregating loans in a portfolio to be hedged, an entity may choose to consider some of the following characteristics, as appropriate: a. Loan type b. Loan size c. Nature and location of collateral d. Interest rate type (fixed or variable) e. Coupon interest rate (if fixed) f. Scheduled maturity g. Prepayment history of the loans (if seasoned) h. Expected prepayment performance in varying interest rate scenarios 32

33 Credit unions considering a fair value hedge should be aware of the following: Fair value hedge cannot be used to hedge interest rate risk on heldto-maturity securities If a fair value hedge is used to hedge interest rate risk on availablefor- sale securities then the change in the value of the hedged item runs through the income statement and not through OCI A partial-term hedge of a fixed rate financial instrument using a shorter-term, notionally matched swap will generally not "be effective" (e.g. hedging a 30-year loan with a 3-year swap) 33

34 Fair value hedge accounting is restrictive and complex, and a CU could elect to account for the financial instrument at fair value in order to avoid these complications and limitations. However, fair value election has several disadvantages: Hedge-accounting election can be terminated at any time, while the fair value election is irrevocable Nearly all of the change in value of an interest rate derivative over time will be due to changes in the market interest rates, while fair value of the loans will be affected by changes in interest t rate and credit conditions The CU will need to develop systems to estimate the fair value of loans over their entire lives 34

35 We recommend that if a credit union elects to account for loans at fair value, that it: Select high credit borrowers to minimize the change in value arising from deterioration of the borrower s credit or the widening out of credit spreads We note that t we have systems in place to estimate t the fair value of loans over their entire lives 35

36 Fixed Rate Mortgage Fair Value Example Fixed Rate Mortgage FICO Score Range LTV Range Avg FICO Avg LTV WAC CPR % CRR % CDR % Severity % Discount Rate Fair Value % 780+ under 50% % 4.2% 9.9% 9.9% 0.0% 0.0% 4.0% 100.3% % - 75% % 4.1% 9.4% 9.3% 0.0% 10.0% 4.2% 99.2% % - 100% % 4.7% 9.8% 9.8% 0.0% 15.0% 4.4% 100.6% % 4.3% 9.8% 9.7% 0.0% 5.2% 4.1% 100.0% under 50% % 4.0% 10.2% 9.8% 0.1% 0.0% 3.8% 100.4% % - 75% % 4.3% 9.8% 9.7% 0.1% 10.0% 4.2% 99.5% % - 100% % 47% 4.7% 96% 9.6% 95% 9.5% 01% 0.1% 15.0% 44% 4.4% 100.2% % 4.3% 9.9% 9.7% 0.1% 7.7% 4.1% 100.0% under 50% % 4.3% 8.6% 8.4% 0.2% 0.0% 4.1% 100.4% % - 75% % 4.6% 8.7% 8.4% 0.3% 10.0% 4.7% 98.4% % - 100% % 4.8% 6.3% 5.7% 0.6% 15.0% 5.8% 90.7% % 4.6% 8.0% 7.6% 0.3% 8.5% 4.9% 96.8% under 50% % 4.9% 8.3% 7.3% 1.0% 0.0% 4.4% 101.1% % - 75% % 4.9% 8.4% 7.3% 1.1% 10.0% 5.3% 95.4% % - 100% % 5.0% 7.5% 5.2% 2.3% 15.0% 7.4% 80.5% % 5.0% 8.1% 6.7% 1.4% 8.4% 5.6% 92.9% 36

37 An entity may designate a derivative instrument as hedging the exposure to variability in expected future cash flows that is attributable to a particular risk. That exposure may be associated with either of the following: Payments on an existing recognized asset or liability (such as all or certain future interest payments on variable-rate debt or variable rate liabilities share accounts) A forecasted transaction (such as a forecasted purchase or sale) 37

38 A forecasted transaction is eligible for designation as a hedged transaction in a cash flow hedge if all of the following criteria are met: A forecasted transaction ti is specifically identified d as either: a. A single transaction b. A group of individual transactions that share the same risk exposure for which they are designated as being hedged. A forecasted purchase and a forecasted sale shall not both be included in the same group of individual transactions that constitute the hedged transaction. 38

39 The occurrence of the forecasted transaction is probable. The forecasted transactions meets both of the following conditions: o It is a transaction with a party external to the reporting entity o It presents an exposure to variations in cash flows for the hedged d risk that could affect reported earnings The forecasted transaction is not the acquisition of an asset or incurrence of a liability that t will subsequently be re-measured with changes in fair value attributable to the hedged risk reported currently in earnings. If the forecasted transaction relates to a recognized asset or liability, the asset or liability is not re-measured with changes in fair value attributable to the hedged risk reported currently in earnings. 39

40 Polling Question #2 If you considering the use of derivatives, which types are you considering (select all that apply)? Swap Cap Floor Treasury futures Have not decided yet 40

41 If the hedged transaction is the variable cash inflow or outflow of an existing financial i asset or liability, the designated d risk being hedged d is any of the following: o The risk of overall changes in the hedged cash flows related to the asset or liability, such as those relating to all changes in the purchase price or sales price o The risk of changes in its cash flows attributable to changes in the designated benchmark interest rate (referred to as interest rate risk) o The risk of changes in its cash flows attributable to all of the following (referred to as credit risk): i. Default ii. Changes in the obligor s creditworthiness iii. Changes in the spread over the benchmark interest rate with respect to the related financial asset s or liability s credit sector at inception of the hedge. 41

42 Fair Value Hedges Portfolio Method using an interest rate swap Purchase of an interest rate cap Cash Flow Hedges First Payments Method using an interest rate swap Method 1: Change in variable cash flows we will show example Method 2: Hypothetical derivative Method 3: Change in fair value Purchase of an interest rate cap 42

43 A pay fixed, receive floating interest rate swap is used to hedge against the change in the fair value of a portfolio of fixed rate single family mortgages Hedging item used - pay fixed, receive floating interest rate swap with a fair value of zero at inception Hedged item - portfolio of fixed rate single family mortgage loans Nature of the risk being hedged d - interest t rate risk defined d as the change in the fair value of the mortgage loan portfolio in relation to the change in benchmark interest rate (LIBOR) The portfolio of loans meets the similar il assets criteria i 43

44 A pay fixed, receive floating interest rate swap is used to hedge against the change in the fair value of a portfolio of fixed rate single family mortgages Stated maturity of swap is consistent with the stated maturities of the loans Swap amortizes on a schedule that equates to scheduled amortization of the loans 44

45 As part of its documented risk management strategy associated with this hedging relationship, on a quarterly basis, the credit union intends to do both of the following: Assess effectiveness of the existing hedging relationship for the past three- month period. Consider possible changes in value of the hedging derivative and the hedged item over the next three months in deciding whether it has an expectation that the hedging relationship will continue to be highly effective at achieving offsetting changes in fair value. Loans can prepay credit union considers prepayment risk of the portfolio in its prospective testing ti If loans prepay faster than expected resulting in an over-hedge credit union de-designates a portion of the swap for the next three month period 45

46 Portfolio Method Example $50 MM amortizing 15 year pay fixed / receive floating interest rate swap Hedged item a pool of 15-year fixed rate loans Market Amortizing Rate Change in Change in Hedge Change Net Swap Swap 15 Year Loan De-designation Notional From Swap Fair Fair Loan Pool Portfolio Dollar Effective Notional Month Amt Inception Payment Value Value Unpaid Bal. Value Offset % (y / n) Amount Mo. 0 50,000,000 0 bps 0 50,000,000 Mo. 1 49,796, bps (104,527) (251,261) (251,261) 49,571, , % yes Mo. 2 49,592,968 +5bps (97,316) 372, ,586 49,017,968 (508,479) 122.6% yes Mo. 3 49,388, bps (94,853) 639, ,718 48,632,600 (301,068) 88.6% yes 755,834 Total (296,696) 639,043 (552,447) 115.7% yes 755,834 46

47 An interest rate cap is purchased to hedge against the decline in the price of a $100 million 10-year treasury note, which the credit union is holding in its available-for- sale inventory. Hedging item used - in-the-money interest rate cap Hedged item - $100 million 10-year treasury note Nature of the risk being hedged d - interest t rate risk defined d as the change in the fair value of the note in relation to the change in benchmark interest rate - US treasury rate 47

48 Interest Rate Cap Example $100 MM semi-annual al 10-year with a cap strike price of 2.78% Semi-annual Cap Reset Intrinsic Time Total Payment Notional Strike Rate PV PV PV 1 100,000, ,000,000, ,152 1, ,000, ,076 41, ,000, , , ,000, , , ,000, , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , , ,000, , , ,764 Total 5,513,076 3,732,098 9,245,174 48

49 Interest Rate Cap Example $100 MM semi-annual al cap with a strike price of 2.78% Hedged item 10-year Treasury note PV Initial PV Updated Change in Change in PV Initial PV Updated Change in Intrinsic Intrinsic PV Intrinsic Treasury Dollar Time Time PV Time Value Value Value Security Value Offset % Effective? Value Value Value 5,513,076 6,566,932 1,053,856 (1,142,384) 92.25% yes 3,732,098 3,625,143 (106,955) Ineffective 49

50 A pay fixed, receive floating interest rate swap is used to hedge against the risk of increasing interest rates for a credit union's money market share accounts Hedging item used - pay fixed, receive floating interest rate swap with a fair value of zero at inception Hedged item - payments on the $50 million of the credit union's money market share accounts Nature of the risk being hedged - variability in cash flows on its quarterly interest payments on $50 million principal of money market share accounts 50

51 A pay fixed, receive floating interest rate swap is used to hedge against the risk of increasing interest rates for a credit union's money market share accounts Re-pricing beta is 0.50 compared with 60-day LIBOR and money market accounts have an estimated life of 3 years Credit union enters into a 3-year 60-day LIBOR swap with a notional amount of $25 million and quarterly settlements 51

52 Credit Union must perform effectiveness testing. To be effective, changes in money market rates must closely track changes in LIBOR. Effectiveness testing cannot be based on the changes in LIBOR only must consider actual payments made because the dividend rate is not the risk free rate Ineffectiveness can be measured in one of three ways: Change in variable cash flows method we will show an example Hypothetical derivative method Change in fair value method 52

53 Hedge ineffectiveness is based on a comparison of: Variable leg of the interest rate swap Hedged variable-rate cash flows on the money market account Based on the premise that only the floating-rate component of the interest rate swap provides the cash flow hedge The interest rate swap is recorded at fair value on the balance sheet. The calculation of ineffectiveness involves a comparison of the following amounts: a. The present value of the cumulative change in the expected future cash flows on the variable leg of the interest rate swap b. The present value of the cumulative change in the expected future interest cash flows on the variable-rate asset or liability 53

54 If the variability of the hedged cash flows of the variable-rate asset or liability is based solely l on changes in a variable-rate index, the present value of the cumulative changes in expected future cash flows shall be calculated using the discount rates applicable to determining the fair value of the interest rate swap Hedge ineffectiveness results when the present value of the cumulative cash flows on the swap exceed the present value of the cumulative cash flows of the designated money market accounts. Conversely, there is no ineffectiveness if the PV of the designated money market payments exceed the PV of the swap (FAS ASC (b) 54

55 Change in Variable Cash Flow Method Example $25 MM 3-year pay fixed / receive floating interest rate swap Hedged item variability in cash flows on its quarterly interest payments on $50 million principal of money market share accounts At Inception Testing After Initial Quarter Expected Present Expected Present Present Present Ineffective Swap Variable Value of Share Value of Value of Value of Portion of Payment Receipts Variable Leg Payments Share Pmts Variable Leg Share Pmts the Hedge Year 1, Quarter 1 12,094 12,088 12,094 12,088 Year 1, Quarter 2 14,328 14,312 14,328 14,312 23,680 22,552 Year 1, Quarter 3 15,396 15,371 15,396 15,371 24,723 23,546 Year 1, Quarter 4 19,259 19,212 19,259 19,212 28,546 27,187 Year 2, Quarter 1 25,647 25,558 25,647 25,558 34,865 33,205 Year 2, Quarter 2 38,106 37,916 38,106 37,916 47,179 44,932 Year 2, Quarter 3 52,796 52,422 52,796 52,422 61,622 58,688 Year 2, Quarter 4 69,886 69,198 69,886 69,198 78,314 74,584 Year 3, Quarter 1 89,047 87,857 89,047 87,857 96,864 92,251 Year 3, Quarter 2 106, , , , , ,823 Year 3, Quarter 3 123, , , , , ,518 Year 3, Quarter 4 140, , , , , , , , , , , ,124 37,306 55

56 Credit union purchases an interest rate cap to hedge against the risk of adverse extreme marketplace interest rate changes on the credit union's floating rate Federal Home Loan Bank advances. Hedging item used out-of-the-money interest rate cap Hedged d item adverse extreme market place interest t rate changes related to its variable rate payments on the credit union's $50 million Federal Home Loan Bank advances Nature of the risk being hedged d -variability in cash flows on the quarterly interest payments on its $50 million Federal Home Loan Bank advances 56

57 Interest Rate Cap Example $50 MM 3-year quarterly with an out of the money strike price of 3.00% Hedged item 3-month LIBOR interest rate changes above 3.00% Quarterly Cap Reset Intrinsic Time Total Pe riod Notional Strike Rate PV PV PV 1 50,000, ,000, ,000, ,000, ,000, ,000, ,000, ,216 4, ,000, ,257 13, ,000, ,363 12, ,000, ,970 23, ,000, ,364 40, ,000, ,180 58,180 Total 0 153, ,305 57

58 Interest Rate Cap Example $50 MM 3-year quarterly with an out of the money strike price of 3.00% Hedged item 3-month LIBOR interest rate changes above 3.00% Perfectly matched resets, indices and terms fair value includes time & intrinsic value Fair Value Change in Fair Value Period , , ,600 (134,821) - 378, , , ,075 (1,246) (1,414) (6,525) 2 15, , ,551 (1,246) (1,414) (6,525) 3 15, , ,403 (330) 825 (10,148) 148) 4 18, , ,459 3,051 5,791 (6,944) 5 24, , ,234 5,995 10,270 (5,225) 6 19, , ,803 (5,465) (15,630) (43,431) 7 16, , ,047 (2,994) (14,135) (46,756) 8 16, , , (11,863) (50,339) 9 20, , ,916 3,437 (11,579) (55,792) 10 9,207 68, ,038 (11,184) (45,764) (103,878) 11 1,926 27,964 96,224 (7,281) (40,429) (99,814) ,953 (1,926) (27,964) (62,271) (153,305) (153,305) (119,352) 58

59 Call Report References Other Assets,32 d Non-Trading Derivatives Assets, net Liabilities, 7 Non-Trading Derivative Liabilities, net Schedule D: Pages Risk Based Capital AOCI not included in capital so no regulatory benefit for cash flow hedge 59

60 Identify the optimal derivative(s) to be used given your credit union's ALM profile Work with you to amend your ALM policies to allow for the use of derivatives Work with you to draft derivatives policies and procedures that ensure you have the proper internal controls in place and that you meet all of the NCUA requirements regarding the use of derivatives We can provide estimates of ongoing fair value for loans, investments, and liabilities which you have elected to account for at fair value. We can also help you with the initial selection of the items 60

61 For those electing hedge accounting we can: Develop the appropriate interest rate hedge and hedging item(s) to be used given your credit union's ALM profile Work with you to identify the item(s) to be hedged and the nature of the risk being hedged Ensure you are able to achieve hedge accounting - including prospective p and retrospective effectiveness testing on a dollar offset or statistical basis Provide you with the journal entries needed to report hedging activities 61

62 Services and Contact Information Asset Liability Management, Derivatives and Private Label MBS/CMOs: Frank Wilary Mergers and Acquisitions, Fair Value Footnotes, ASC , and TDRs: Brenda Lidke Mortgage Servicing Rights and Mortgage Banking Derivatives: Eric Nokken 62

63 Wilary Winn Risk Management LLC First National Bank Building 332 Minnesota Street, Suite W1750 Saint Paul, MN