EY IFRS 9 impairment banking survey - September · PDF filePage 7 Data Commentary 1. IFRS 9...

EY IFRS 9 impairment banking survey2016

IFRS 9 Financial Instruments represents the most fundamental change to a financial institution’s accounting methodology, risk management practices and operational processes

The adoption of IFRS 9 will require significant enhancements to a financial institution’s organizational engagement, data,systems, quantitative models and governance, amongst other areas. The methodology under IFRS 9 will also introducemore judgment, complexity and volatility in reporting, resulting in a need for intensive oversight and enhanced stakeholderscrutiny.

Furthermore, the impact on the financial institutions’ operational processes and financial reporting will not be limited to thetransition period and adoption date. It is expected to continue well after the implementation date of the standard (1 January2018) due to the scale of change required by the standard and the availability of public information in the post-implementation period.

In 2016, EY performed a second IFRS 9 global impairment survey and engaged 36 financial institutions to participate,including 14 global systemically important banks (G-SIBs). The survey is intended to assess the “state of readiness” in theimplementation of the IFRS 9 program with a particular focus on impairment.

This paper outlines the survey results across the global participants and provides a view on the current status of theoverall IFRS 9 program, including how banks are structuring the implementation plan, decisions around critical policieswithin the expected credit loss methodology and the level of compliance with the Enhanced Disclosure Task Force (EDTF)recommendations.

For further insights on this topic, please get in touch with the contacts provided in the appendix to this survey or your localEY contact. We would be glad to assist you if you would like to discuss the results contained in this report, including whereyour institution falls within the benchmarking study.

Yolaine Kermarrec Andre Correia Dos Santos

EY IFRS 9 impairment banking survey 2016

Introduction

Participants Profile

► We surveyed 36 top tier IFRS-reporting financial institutions worldwide

► 17 have a balance sheet in excess of €600b; 9 have a balance sheet between €200b and €600b

► 14 banks are global systemically important banks (G-SIBs)

► 15 banks are under the scope of Sarbanes-Oxley Act (SOX)

► 22 banks use advanced internal rating based approach (A-IRB) for all of their portfolios

► EY first conducted an IFRS 9 survey in June 2015 to provide participants with a “state of readiness” benchmark,and to identify emerging trends in the implementation of the new standard. This second round conducted inSpring 2016 captures the progress made by banks over the past nine months. All results are presented on ananonymous basis

The Survey

► Banks have made significant developments in the past nine months on the implementation of their impairmentprogram. Most banks are progressing well into the build phase in this workstream, with a focus on identifyingdata and system requirements in order to advance towards the deploy phase

► While certain impairment policy decisions are still under debate (i.e., multiple scenarios), we expect thatparticipants will continue to refine their policies leading up to the parallel run as we observe greater marketconvergence on these topics

► There has been some development on classification and measurement (C&M), albeit at a slower pace thanimpairment. This is consistent with the relative view of complexity associated with C&M. However, banks shouldnot underestimate the IFRS 9 requirements in this area, particularly with regards to the test of solely payment ofprincipal and interest (SPPI) for non-standardized contracts

► Most banks expect to start a full parallel run in Q1 2017, although some banks have had to delay this to Q2 oreven Q3 in the face of slower progress than expected due to scope increases and updates to implementationguidance

► Most banks expect to disclose a first quantitative impact assessment to the markets during 2017

Overall state of

readiness


Geographic representation of the survey participants

31

3

7

141

21

1

2

2

8United Kingdom

Canada

AustraliaAustria

Belgium

Denmark

France

Switzerland

Sweden

SingaporeItaly

IrelandGermany

36 total number of surveyed banks


1 IFRS 9 project status and governance 5–15

2 Impact assessment 16–17

3 Significant deterioration 18–25

4 Definition of default 26–29

5 Measurement of expected credit loss 30–38

6 IFRS 9 disclosures 39

Content


CommentaryData

12

17

7

8

10

21

13

15

4

13

13

12

7

3

23

14

12

2

3

1

1

1

1

1

1

1

Policy

Disclosures

Modeling

Data

Systems

Operating modeland controlframework

1. IFRS 9 project status and governanceStatus of impairment program

A shift to the build phase:

► Most banks have now moved into the build phase, especiallyon modeling (see pages 32-36), data and systems, whichbanks have prioritized

► As policy and design decisions are being finalized, with certaintopics under development, including multiple scenarios, mostbanks aim to allow flexibility for refinements

Data is widely seen as one of the major challenges of IFRS 9:

► IFRS 9 poses numerous challenges with regards to availability(historic data at origination for stage allocation, specificfeatures for classification, external market data formeasurement), granularity (for disclosures and managementinformation), quality and storage

► Most banks have, therefore, started identifying data gaps earlyon in their programs. Most have focused their disclosureefforts on quantitative disclosures and related data points

Banks are at an early stage on designing and implementing theend to end target operating model:

► Banks are often still focused on the deployment of models tomeet the immediate requirements of the standard, as opposedto delivering an end-to-end credit risk reporting solution tosupport the monthly business as usual (BAU) impairmentresults production

► Numerous significant areas of judgment will require robustgovernance and control process which are transparent toauditors and external stakeholders

Design — early

Design —advanced Build Deploy &

test Live


CommentaryData

12

9

9

15

14

18

12

12

15

13

15

16

6

5

4

6

6

1

5

9

7

1

1

1

1

1

1

1

Policy

Business modelassessment

Bottom-up SPPItesting*

Data

Systems

Operating modeland controlframework

1. IFRS 9 project status and governanceStatus of classification and measurement program

Banks are still in the design phase for policy, BMA and SPPI:

► Efforts invested seem proportional to the impact banks expectat transition on their balance sheets, with around a quarter ofbanks having started bottom-up SPPI testing back to thecontracts

► A few banks referred to open questions remaining on technicalinterpretation of IFRS 9 (e.g., on certain prepayment options)

Banks have focused less on data, systems, operating modeland control framework:

► These workstreams have a significant dependency on thefinancial impact assessment (BMA and SPPI)

► Most banks are still in the process of performing a data gapanalysis — new data fields to track term features for BAUgovernance around SPPI, market data required for thevaluation of portfolios transferring to fair value through profit orloss (FVTPL), new data points for statutory and regulatorydisclosure requirements

► Embedding BMA and SPPI in BAU processes will requireenhancing trade capture and new product approval processes,as well as the governance around central storage ofstandardized contracts. Other processes impacted includestructuring, impairment, valuation, hedge accounting andreporting

*SPPI testing back to individual contracts


Design — early

Design —advanced Build Deploy &

test Live

CommentaryData

1. IFRS 9 projectIFRS 9 hedge accounting

Most banks will not apply IFRS 9 hedge accounting in 2018:

► As they are awaiting for further clarity and progress on theInternational Accounting Standards Board (IASB) macro-hedge project, and in the context of the wider cost reductionagenda, banks are cautious not to spend too much, too early,on their IFRS 9 hedge accounting program. This may all needto change once the outcome of the macro project is known

► Banks also see little benefit in applying the standard, and afew stated their hedging strategy is mainly macro hedging

New disclosure requirements:

► Banks are required to apply new disclosure requirements forhedge accounting from 1 January 2018 onwards, irrespectiveof whether they will apply IFRS 9 hedge accounting then.New disclosures relate to risk management strategy for eachhedged exposure, the amount, timing and uncertainty of futurecash flows, the effects of hedge accounting on financialposition and performance, and the option to designate a creditexposure at fair value through profit or loss (FVTPL)

23

183

10

Apply IFRS 9 hedge accounting in full

Apply IFRS 9 hedge accounting for all hedges except for portfolio fairvalue hedges

- Remain on IAS 39 hedge accounting as long as permitted- Focus current efforts on developing new disclosure requirements ofIFRS 7- Remain on IAS 39 hedge accounting for 2018- May adopt IFRS 9 hedge accounting earlier than when required

Undecided


CommentaryData

1. IFRS 9 projectGovernance and coordination

3

8

23

2

GovernanceFinance

- Finance for C&M andhedge accounting- Risk for impairment

- Finance for C&M andhedge accounting- Finance and risk forimpairmentOther

18

8

4

6

Coordination Exclusively centralizedimplementation

Centralized implementation witha few exceptions depending onportfolios and systems

- Centralized guidelines,coordination and IFRS 9 ECLmodels- Decentralized implementation

- Centralized guidelines andcoordination- Decentralized implementationincluding IFRS 9 ECL models

Implementation governance

► There is a clear trend for the implementation efforts of C&Mand hedge accounting to be predominantly led by Finance

► Impairment continues to be jointly governed by both Financeand Risk. The joint leadership between Finance and Risk ofthe impairment project will require banks to clearly articulatethe roles and responsibilities across both functions within adetailed target operating model

► Additional success factors in the project implementationinclude the integration of interactions with other functionalunits such as operations, IT and affected business units

► A number of banks are working to enhance their existingcontrol framework in this area due to the intricacies within theIFRS 9 end-to-end processes

Centralized implementation efforts

► Project coordination is generally aligned with the operatingmodel, with half of the participants applying an exclusivelycentralized implementation, where possible, depending on ITinfrastructure, geographical constraints and local regulatoryrequirements

► Banks have indicated that they need a robust communicationstrategy in terms of disseminating information to the relevantdepartment or business units when using a centralizedimplementation


CommentaryData

1. IFRS 9 projectParallel run

1

10

7

9

4

2

3

Live

Q1 2017

Q2 2017

Q3 2017

Q4 2017

Other

Undecided

Full parallel run

1

8

4

10

7

2

1

2

1

Live

Currently running

H1 2016

H2 2016

Q1 2017

Q2 2017

Q3 2017

Q4 2017

Undecided

Calculating IFRS 9 numbers in a tactical platform

Tactical platform

► Calculating IFRS 9 numbers within a tactical platform will bean imperative first-step in determining the impact of thestandard. It will also provide useful information to participantson data issues and system limitations that will requireresolution prior to the parallel run

► Over half of the participants have indicated that they will havethe ability to generate impairment figures within a tacticalplatform by the end of 2016, with just under one third ofparticipants reporting that they currently have this platform inplace

Parallel run

► Only a third of participants plan to complete at least a 9 monthparallel run of IAS 39 and IFRS 9 figures. This figure hasdeclined compared to our previous survey where more thanhalf of participants intended to perform at least 12 months ofparallel run

► The majority of the large European and global banks will havecompleted at least one reporting period under a parallel run in2017


CommentaryData

11

4

3

2

1

1

14

1

4

5

6

2

3

3

12

21

15

≤€2m

€2m < €5m

€5m < €15m

€15m < €25m

€25m < €40m

€40m < €60m

€60m < €100m

Undecided /Undisclosed

C&M, impairment, and hedge accounting

Classification &Measurement

Impairment

Hedge Accounting

1. IFRS 9 projectBudget

► As expected, there was a very wide range of budgets for IFRS9, with an element of uncertainty on the actual spend forimplementation

► While larger and more global banks are spending more thansmaller locally focused banks, the scale of cost does notappear linearly related to the size of the bank. For example, alarger bank may have budgeted 25x the cost, but the balancesheet is only 10x larger. This strikingly illustrates the costdifferences with implementing more complicated solutions

► While impairment remains the costlier element of IFRS 9implementation, there is a wide range of cost estimates forC&M. The banks with the larger C&M budgets are moreadvanced with their programs, suggesting many of the bankswith low cost estimates for C&M may be underestimating thecost and complexity


13

75

27

222

5

≤€2m€2m < €5m

€5m < €15m€15m < €25m€25m < €40m€40m < €60m

€60m < €100m€100m < €125m

≥€125mUndecided /Undisclosed

Expected total budget

CommentaryData

1. IFRS 9 projectBudget (cont’d)

10

6

20

≤€1m €1m < €5m Undecided

BAU yearly budget post-implementation► Over half of our survey respondents have not fully quantified

the cost on their BAU budget, with many banks explicitlyindicating that it was premature to form such a view

► BAU costs are expected to be mainly related to additionalresources to run models and for licenses (if applicable). Somebanks mentioned there will be incremental costs for controlfunctions, reporting, and disclosure, but these are yet to bequantified


CommentaryData

1. IFRS 9 projectSynergies

► There are many areas within most banks that are either beingleveraged for the benefit of IFRS 9, or subject to the samegovernance process to ensure consistency and accuracy

► In terms of leveraging existing or developing processes forIFRS 9, the two areas most cited are:

► roll out of IRB models, which are generally used as astarting point for IFRS 9 impairment calculations, butthen developed and operated as separate models

► data improvement initiatives, such as BCBS 239 ordata warehouse developments

► For governance, the three areas most cited are:

► stress testing to ensure consistency (whereappropriate) in the forward looking information beingused; the IFRS 9 platform will generally be leveragedfor stress testing going forward

► capital planning and ICAAP to ensure some level ofintegration between IFRS 9, risk managementframework and overall capital management

► FinRep, given the template information that requiresreporting has an element of IFRS 9

► While governance may cover and promote consistency (whereapplicable) between IFRS 9, regulatory capital calculations,and stress testing, there was little indication that the processesthemselves have a high degree of overlap

25

3

10

3

11

Data aggregation and reportingsystems improvement (e.g. BCBS 239)

Use Pillar III disclosures as a startingpoint

Roll IRB out for portfolios previouslyunder a standardised approach

Preparation for ECB TRIM

Others, including regulatoryrequirements

Existing programs leveraged for IFRS 9

20

27

23

32

8

13

FinRep and CoRep

Use stress testing platform toincorporate FLI

Capital planning / ICAAP / Forecasting

Risk management reporting

Asset Liability Management (ALM)

Fair Value Measurement processes

Processes linked for IFRS 9 governance

Total in both graphs is more than 36 as most banks selected more than one option


CommentaryData

1. IFRS 9 projectEffective interest rate (EIR) approach

► EIR impacts both the discounting in IFRS 9 models as well asthe measurement of interest revenue

► The majority of banks noted they will not revisit their currentEIR approach as a result of the introduction of IFRS 9 on thegrounds that there is no material difference with their currentshort-cuts, however some are keeping their options open (seeslide 35)

► As part of its implementation of IFRS 9, a bank will need toconsider whether approximations used in determining EIRsunder IAS 39 remain appropriate given the more significantrole that discounting has in measuring impairment under IFRS9 (e.g. discounting of cash shortfalls that may occur a numberof years into the future)

► Of the banks that have determined they need to remove shortcuts (such as straight line approximation), some noted thatthey will do this due to emphases on the discounting andincome that will be magnified under IFRS 9

8

21

7

Plan to revisit current EIR approach

Yes — Existing short-cuts will be removed

No — No material difference between existing short-cuts and what is required by IAS 39/IFRS 9

N/A — EIR approach already fully compliant with IAS 39/IFRS 9


CommentaryData

1. IFRS 9 projectIT architecture and governance

22

12

2

Number of ECL calculators in IFRS 9 solution

One ECL calculator

More than one ECLcalculator

Undecided

2

26

8

Frequency of BAU IFRS 9 ECL calculation

More frequently thanmonthly

Monthly

Quarterly

ECL calculator

► Most participants are setting up a single, central platform asECL calculator, supporting various IFRS 9 models

► 12 banks plan to use more than one ECL platform dependingon portfolios (wholesale vs. retail, IRB vs. standardized); legalentities, and purpose (ECL calculation for stages 1 and 2 vs.stage 3; live production vs. simulation)

Frequency of BAU ECL calculation

► Most banks plan a monthly IFRS 9 ECL calculation andmanagement information, which is seen as good practice forcredit monitoring purpose

► 8 banks plan to run an ECL number on a quarterly basis,aligned with their external reporting

► A couple of banks plan to calculate the ECL numbers morethan once per month, essentially in a pre-productionenvironment, with not full governance applied on the numberfor the intra-month calculation(s)


CommentaryData

1. IFRS 9 projectIT architecture and governance (cont’d)

911

16

Current month-enddata

Older data Mix current/older data,depending on entities

and portoflio

Data used for significant deterioration and ECL calculation

6 7

23

Yes No In progress

Documented data taxonomy

Use of month-end data for stage allocation and ECLcalculation

► Although participants aim to use data as current as possible,especially for year-end reporting, many recognize that they willhave to use lagged data in order to meet financial closetimelines

► Most banks planning to use prior period data referred to atime-lag of one month; a few referred to a time-lag between acouple of days and 3 months

► In a number of cases it depends on portfolios (corporates databeing less timely), legal entities, and type of data

► Lagging data would be adjusted for significant eventsoccurring prior to closing (e.g. in credit and volumes), andrelated governance is still in development. This is an area ofsubjectivity and will likely gain external audit attention

Data

► Most banks have identified data gaps early on in theirprograms (e.g. lifetime PD curves at origination, certainunlikely to pay factors, date of transfer to stage 3) in order todevelop data remediation solutions. Data gaps not onlyinclude data limitations but also data reconciliation issues (i.e.data mismatch)

► Most banks are in the process of documenting a datataxonomy (e.g. detailed glossary) and establishing sourcingprocesses in an iterative manner


CommentaryData

1

2

9

10

1

3

1

2

7

Prior to G-CRAECL

2017 -Quarter

undecided

H1 2017 H2 2017 During2018

Undecided

Date of public disclosure of quantitative impact assessment

Q1

Q2

Q3

Q4

Quarter undecided

2. Impact assessmentDisclosure of impact to the market

► Most banks are undecided on timing of public disclosureswhich is surprising due to the recommendations produced bythe Enhanced Disclosure Task Force (EDTF)

► Many banks are planning to disclose a quantitative impactassessment in Q4 2017 (mainly banks with 31 October year-ends) or at beginning of 2018 in their 2017 annual reports.This is at the latest point recommended by the EDTF

► Despite the fact that regulators around the world are starting torequest a preliminary IFRS 9 impact analysis, banks are stillrefining their models and policy decisions in key areas (e.g.significant deterioration) in order to improve the reliability ofthe numbers and full governance in place before a publicquantitative impact is disclosed


CommentaryData

66

41

2

116

0 - 5%5.1 - 10%

10.1 - 15%15.1 - 20%20.1 - 30%30.1 - 40%40.1 - 50%

> 50.1%Not disclosed or calculated

Wholesale

2. Impact assessmentProportion of good book expected to be stage 2

Total

► Most banks estimate that no more than 10% of theirperforming exposures will be assessed as stage 2. However,some expect considerably more. The portfolios will vary inquality, but it is possible that some of the differences arisefrom differences in approach

► The majority of banks who cannot calculate this number arebanks that have not yet been requested to submit aquantitative impact assessment to their regulator

38

511

117

0 - 5%5.1 - 10%

10.1 - 15%15.1 - 20%20.1 - 30%30.1 - 40%40.1 - 50%


Retail

Wholesale

► As would be expected, it is generally SME loans that show thegreatest percentage of exposures in stage 2, followed bycorporate loans

► The bank with >50% of good book expected to fall into stage 2plans to recognise a lifetime expected credit loss at initialrecognition due to undue cost and effort undertaken indetermining significant increase in credit risk

Retail

► Overall, credit cards show the largest proportion of exposuresin stage 2 in this portfolio

► For other types of retail lending there is diversity. For instance,in most cases where the calculation had been made at thislevel, a relatively low percentage of the mortgage portfolio wasassessed to be in stage 2, but for some of the banksmortgages were one of the larger contributors

76

511

115

0 - 5%5.1 - 10%

10.1 - 15%15.1 - 20%20.1 - 30%30.1 - 40%40.1 - 50%


Total


All banks consider using a combination of quantitative and qualitative drivers structured as primary and secondary drivers, plusbackstops. The primary driver is meant to be the most early indicator and is generally based on a relative measure while theothers cover more obvious (absolute) signs of deterioration such as forbearance or delinquency

Primary drivers - the survey reveals two major trends:

► Use of IFRS 9 lifetime probability of default (PDs), guided by scores and ratings, OR

► Use of Basel adjusted 12M PD or scores (often equivalent) for retail exposures or use of ratings for corporate exposures

Secondary drivers and backstops - Answers are homogeneous around using forbearance, delinquency (mainly 30 days pastdue (DPD) as a backstop), watchlists or a combination of those. As expected, watchlists are less frequently mentioned for retailcompared to corporates. Also retail watchlists concepts tend to largely overlap with forbearance, delinquency as well as fixedlevels of scores or PDs

Use of variation of 12M PD - Banks will have to demonstrate that they are not missing any significant increase in risk of a defaultbeyond 12 months. This may require further adjustments based on macroeconomic forecasts. However, these indicators are stillconsidered very relevant as they are well understood and have been used and tested for a long time

Use of variation of lifetime PD - The obvious challenge on transition is to have data available at origination date for existingportfolios (including forward looking information). Some banks mentioned they would have to use proxies on transition (Baselscores, through the cycle (TTC) PDs, latest information available or lending policy cut-offs)

Use of variation of ratings – Ratings are considered more forward-looking by nature as they involve more expert judgmentbased on a wider range of information, including more prospective information (borrower’s financials, sectorial information etc.)and look beyond a 12 month horizon. Depending on their calibration, they may also require demonstrating the associated PDsreflect current circumstances and reasonable forecasts

Transitional vs. strategic approach - The challenges faced on transition are obviously less significant for banks using Baselscores or PD although some issues may still arise depending on when the IRB models were built. It remains to be seen whetherin the longer term, the development and increasing use of lifetime PD curve (including forward-looking elements) may result inmore convergence towards the use of this more sophisticated quantitative measure

3. Significant deteriorationDrivers


CommentaryData

16

2

4

9

4

1

3

1

3

1

9

11

1

1

3

4

2

5

25

4

3

IFRS 9 lifetime PD

Adjusted IFRS 9 12m PD

IFRS 9 12m PD

Basel PD

Ratings or scores

Fixed level of score or PD

Watchlist

Forbearance

30 DPD

Delinquency other than30DPD

LCR simplification

Other

Undecided

Retail

Primary Secondary Backstop

3. Significant deteriorationDrivers — retail

Primary drivers► Around half of the banks converge towards using IFRS 9

lifetime PDs as their main indicator. Although not alwaysspecified, this generally means comparing the averagemarginal PDs over the residual term to what was expected atinception for the same period

► The other half intends to use Basel 12M PD or scores(generally equivalent measures). Among these banks, a fewbanks mentioned they would use fixed levels of score (i.e. anabsolute measure). They consider this is a good proxy forassessing deterioration and easier to operationalise

► A few banks mention using IFRS 9 12M PD (with onementioning adjustments to reflect longer term expectations).Compared to Basel PD, these measures would not becalibrated through a cycle

Secondary drivers and backstops► Answers are very homogeneous around using forbearance,

delinquency (mainly mentioned as a backstop), watchlists or acombination of those

► Retail watchlists are more mechanical than for corporateexposures and tend to largely overlap with forbearance,delinquency as well as fixed levels of scores or PDs

► Given the number of entities aligning non-performing forborneassets and stage 3, forbearance may mostly be relevant instage 2 during probation periods, when the assets are nolonger in default

NB. Other risk metrics generally correspond to scores or ratings. Most banks selected this indicator in combination with 12m PDNB. The graph and commentary refer to the secured retail portfolio as banks displayed similar trends across all retail portfoliosNB. 1 bank does not have retail portfolios


CommentaryData

18

2

1

13

4

1

2

1

1

6

1

17

10

1

1

3

5

3

8

22

2

4

IFRS 9 lifetime PD


IFRS 9 12m PD

Basel PD

Ratings or scores


Watchlist

Forbearance

30 DPD


LCR simplification

Other

Undecided

Wholesale


3. Significant deteriorationDrivers — wholesale

Primary drivers► Half of the banks intend to use the same primary indicator for

corporate compared to retail

► Almost all banks using lifetime PD for retail also use it forcorporates (with one bank mentioning it will use watch listinstead)

► Then, rating deterioration is more commonly mentioned

► Ratings are considered more forward looking than retail scores.Rating calibration can be through the cycle (with some stickinessaround better ratings) and may therefore require demonstratingthey don’t miss out any deterioration compared to forward lookinglifetime PDs. However, they remain a favoured criteria as theybuild on a robust process and are aligned with risk management

► Watchlists are mentioned by a few banks (with one combining itwith adjusted PD). Almost all these banks are currently enhancingtheir watchlist process (see slide 22) . Those banks tend to useratings as secondary driver

Secondary and backstop drivers► Watchlist is the most common secondary drivers. Most banks

using lifetime PD or rating changes as primary indicators usewatchlist as secondary or backstop criteria. Interestingly, majorityof the banks are not proposing any enhancement to the watchlistprocess

► Forbearance is mentioned similarly to retail

► While 30 DPD is generally considered as a lagging indicator forcorporate, this is mentioned as a backstop

NB. The graph and commentary refer to the corporate portfolio as banks displayed similar trends across all wholesale portfolios


CommentaryData

3. Significant deteriorationDrivers — debt securities

10

1

2

7

1

1

11

1

4

1

1

3

2

8

4

1

1

2

3

2

4

13

3

1

4

IFRS 9 lifetime PD


IFRS 9 12m PD

Basel PD

Ratings or scores


Watchlist

Forbearance

30 DPD


Deterioration creditspreads

LCR simplification

Other

Undecided

Debt securities


Primary drivers► Participants illustrate more variety in their primary approaches

to determining significant deterioration for debt securities. Thiscould be due to their being less attention drawn to theapplication of this concept to this product category

► The main difference to be noted for debt securities is the useof the low risk simplification, which is mentioned as a primaryindicator by 10 banks. The other banks are evenly splitbetween using lifetime PD and ratings

Secondary and backstop drivers► Fewer secondary drivers and backstops were mentioned,

reflecting simpler approaches; the main secondary drivers andbackstops remain watchlist, forbearance and delinquency


NB. 3 banks did not respond for debt securities

CommentaryData

1620

Plan to enhance watchlist process

Yes No

3. Significant deteriorationWatchlist enhancement process

► The increasing reliance on the ‘watchlist’ process as anindicator of significant deterioration has resulted in the reviewof whether there are enhancements required to this process inorder to allow for appropriate monitoring of credit

► The majority of participants have indicated the existingwatchlist processes will not be enhanced under IFRS 9. This islargely due to existing watchlist processes being identified asfairly robust and an ongoing review of the adequacy of theprocess outside of IFRS 9

► This point is particularly relevant for a few banks using it astheir primary indicator. Almost all of them intend to enhancetheir watchlist process around the following areas: reinforcingthe link with ratings, demonstrating the relative measure,reinforcing the link with governance and processes andmaking sure it is symmetrical. Things may also have to beremoved such as concentration risk

► For the other banks, the comments show that the issue is stillbeing investigated. Consistency of watchlist definition acrossthe bank is clearly a key point

► Interestingly one bank mentions that credit analysts will haveaccess to the modeling output which will bring morequantitative expertise into their analysis


CommentaryData

4

10

11

11

Plan to apply probation periods before returning assets from stage 2 to stage 1

Yes Yes for certain triggers No Undecided

3. Significant deteriorationUse of probation periods for transfer out of stage 2

► Over a third of the banks declare that they intend to applyprobation periods to their stage 2 assets

► In most cases, the probation period only applies when thetransfer to stage 2 has been initially triggered by indicatorsother than the primary trigger, especially:

► forbearance (potentially influenced by the EuropeanBanking Authority (EBA) definitions when relevant),with a few banks referring to a 2-year probation;

► delinquency (minimum cure periods are considered inrelation with the 30 DPD criteria), with a few banksreferring to a 3 to 6 month probation; and,

► watchlist, with a few banks referring to a 6-monthprobation period for instance

► This means that probation periods would not apply to assetstransferred in stage 2 for other reasons (based on PD modelsfor instance)

► Banks mention that probation periods are currently underreview and are part of the calibration exercise which willcontinue over the coming years

► Another third of the banks state that they won’t apply anyprobation period, especially as probation periods are alreadyincluded in ratings and PD models and will therefore“naturally” apply via the use of ratings or PD indicators

► Finally another third of the banks is still undecided. This isconsistent with the answers collected on the articulation withEBA definitions


CommentaryData

15

11

10

Use of a probability weighted approach to reflect multiple scenarios in the significant

deterioration assessment

Yes No Undecided

3. Significant deteriorationUse of probability weighted approach in significant deterioration

► In December the Impairment Transition Resource Group (ITG)agreed that banks should incorporate more than one forwardlooking scenario when assessing significant increases in creditrisk, if there is a non-linear relationship between the differentscenarios and the risk of default. However, they need notconsider only quantitative approaches

► There are differences of view as to whether probability-weighted multiple scenarios approach will be used todetermine significant deterioration. Some of those banks whointend not to do so report that they do not expect the effect tobe significant

► Others believe that the effect of non-linear relationships isalready reflected in corporate credit gradings or watchlists

► While over a third of the banks do intend to use multiplescenarios to assess significant deterioration, most have yet todecide how they will do this


CommentaryData

3. Significant deteriorationTrigger approach when using a relative criterion

► Calibration remains very much work in progress as banks arecurrently testing different sets of triggers

► Given the exponential shape of the PD curve relative toratings, the calibration of a significant deterioration has to takeinto account the fact that PD multiples in very good ratingsonly represent very small movements in absolute amountswhen the same multiple applied to bad ratings can represent asignificant change in the absolute amount of PD

► Therefore, most banks will use a combination of additive andmultiple factors to assess significant deterioration. Only a fewof them consider having only one factor as a sufficient triggerand these banks recognize that the triggers would have to beset differently for retail and corporate, but also by portfolio,country and taking into account the level of risk at origination

► Banks using ratings or scores as their primary drivers will usea number of notches (which is close to using PD multipleapproaches). They generally intend to adjust the number ofnotches depending on the position in the rating scale.Depending on the calibration, this could have similar effects tousing the low credit risk simplification and introducesubjectivity

► Note that those using lifetime PD may also try and calibratePD changes based on the rating scale to try and map PDvariation with ratings changes that are considered meaningfulfrom a risk management standpoint

9

3

13

76

A B C D E

Trigger approach when using a relative criterion

A. PD delta (e.g. + xx bps)

B. A PD multiple (e.g. PD*xx), or a number of notches for scores or rating (e.g. x notches out of a XX scale)

C. A combination of ‘delta’ and ‘multiple’ approaches - with both criteria to be met to trigger a transfer to stage 2

D. A combination of ‘delta’ or ‘multiple’ approaches, with at least one criteria to be met to trigger a transfer to stage 2

E. Other

Total is more than 36 as 2 banks selected two options as they will adopt a different trigger approach for their wholesale and retail portfolios


CommentaryData

4. Definition of defaultIFRS 9 and Basel definition of default

28

62

Align IFRS 9 and Basel definition of default

Fully align definitions of defaultused for IFRS 9 and for regulatorycapital calculation purposes

Align definitions except for certainexposures where 180DPD areused for regulatory capitalcalculation purposes

Undecided

6

27

3

Plan to rebut the 90 days past due presumption

Yes No Undecided

Alignment of regulatory definitions

► Almost all banks intend to align their IFRS 9 definition ofdefault with the regulatory definition, with only few banksintending to use some exceptions relating to DPD

Rebuttable presumptions

► For those banks using a 180 DPD trigger under Basel, fullalignment therefore implies rebutting the IFRS 9 90 DPDpresumption – which some banks are not willing to do as thiscould be perceived as a lower quality IFRS 9 implementation

► Many banks also mentioned that their regulatory definition ofdefault is evolving towards a more systematic use of the 90DPD trigger – decreasing the need to rebut the IFRS 9presumption. Some banks stated that shifting from 180 to 90days often has little impact for mortgage loans as contagionwould cause default ahead of the 180 DPD trigger, whilstothers said on the contrary this impact was significant

► The few banks that intend to rebut the 90 DPD presumptionunder IFRS 9 will limit it to very specific portfolios (credit cardsin Canada, mortgages in the UK, public sector, sovereigns,institutions or under exceptional circumstances for others)

N.B. In Europe, the CRR limits the exception to exposures secured by residential or SME commercial real estate in the retail exposure class, as well as exposures to public sector entities


CommentaryData

4. Definition of defaultIFRS 9 definition of default and EBA definition of non-performing

► This question only applies to banks in the scope of EBAregulations

► Amongst these 22 European banks, more than half intend tofully align their IFRS 9 definition of default with EBA definitionsof non-performing exposures for both forborne and non-forborne exposures. One bank mentioned that alignmentwould be restricted to non-forborne exposures and anotherone on the contrary will limit it to forborne exposures

► Such alignment involves the application of probation periodsfor forborne exposures as the EBA definition requires thatforborne exposures remain non-performing for at least oneyear following the extension of forbearance measures. Otherconditions to cease being non-performing include thediscontinuation of the credit-impaired and defaultclassification, full repayment (according to the original or whenapplicable the modified conditions) likely to be made, and nopast-due amount by more than 90 days

► The Basel consultative guidelines on the definitions of non-performing and forbearance published earlier this year mayresult in increased harmonization across countries outsideEurope. Therefore the mapping between these concepts andIFRS 9 will remain an area of attention

144

4

IFRS 9 definition of default and EBA definition of nonperforming

Align IFRS 9 definition of default and EBA definition of non-performing

Do not align IFRS 9 definition of default and EBA definition of non-performing

Undecided


CommentaryData

4. Definition of defaultForbearance in stage 2 and definition of stage 3

33

13 1 2

Definition of stage 3All defaulted assets (based on thebank's interpretation of default forIFRS 9 purposes)Only defaulted assets for which aloss is expected (LGD > 0)

Assets which have not defaulted yet(PD < 1)

Other

Undecided

13

4

4

22

Forbearance in stage 2

All performing forborne exposuresbased on the EBA definition(including 2 year probation period)Non-performing forborne assetsbased on the EBA definition

Forborne exposures that are notcovered by the EBA definition

All forborne exposures in Stage 3

No link between forbearance andstaging

Total is more than 36 as 4 banks selected two options

Forbearance► This question only applies to banks in the scope of EBA

regulations

► Amongst the 22 banks affected by this question, 13 banksintend to fully align stage 2 with EBA definition of performingforborne exposures. These banks generally declare that theywill also align EBA non-performing status and IFRS 9 defaultand stage 3

► Such alignment involves the application of quite long probationperiods in stage 2 as the EBA definition requires that forborneexposures remain flagged as performing forborne for at least 2years (after being at least 1 year flagged as non-performingforborne)

► Only 2 banks said they were not linking forbearance and stage2 allocation. This mainly reflects that forbearance is anindicator already embedded in ratings or other risk categoriesand is not considered as a distinct indicator

Definition of stage 3► Almost all banks intend to align stage 3 with their interpretation

of default for IFRS 9 purposes. Only one bank intends toexclude from stage 3 defaulted assets which are fullyguaranteed

► 3 banks intend to classify exposures which are not yetdefaulted in stage 3. This generally relates to certain types offorbearance or the application of probation periods


CommentaryData

4. Definition of defaultCross asset contagion

11

23

5

8

4

8

14

3

13

2

6

10

Retail — Cross-asset contagion across

facilities with the same borrower

Corporate — Cross-asset contagion across facilities with the same

borrower

Corporate — Cross-asset contagion across

counterparties within the same group

Cross-asset contagion for default

Yes to all facilities/counterparties

Yes for some facilities/counterparties

No

Undecided

► Even though there is general alignment between IFRS 9 andregulatory definitions, banks reveal diversity in the applicationof the regulatory definition of default across countries

► Under the Basel definition, default shall reflect unlikeliness topay or delinquency of a particular obligor observed at the levelof the banking group in full. For retail exposures however, thedefinition of default can be applied at the level of a particularfacility, rather than at the level of the obligor.

► Around half of respondents intend to apply cross-assetcontagion for retail exposures while two thirds intend to do sofor corporate exposures with the same borrower. Datalimitation is often mentioned as the reason for not applyingcross-asset contagion overall

► The number for corporates drops when it comes to applyingcross-asset contagion to borrowers within the same group,with more banks being undecided and more going forcontagion only in certain circumstances

► Finally, many banks do not see applying contagion as anautomatic process, but may involve expert judgment andmanagement review in their decision

Total for retail is less than 36 as 1 bank does not have a retail portfolio


CommentaryData

5. Measurement of expected credit loss (ECL) Probability of default

5

10

72

4

8

Calculation of PiT PD for IFRS 9 when Basel PD not available

Point-in-time estimates alreadyin place in the organisation

New point-in-time models

Expert judgement approaches

Historical loss rates or roll rates

Not applicable — full Basel PD coverage

Other

Undecided

31

4

Corporate

30

5

Retail

Yes No

Use of Basel PD as a starting point Majority of banks leveraging Basel PDs► The majority of the banks planning to leverage on Basel

models, will be re-calibrating the PD value, aiming atconverting the value to a point-in-time (PiT) estimate andincluding forward looking expectations

► Although almost all of the banks state that they will leverageexisting Basel PDs, most banks will also have to develop anew range of models to get full coverage of their books

Calculation of PiT PD for IFRS 9► For the development of new PiT PD models where Basel PDs

are not available as a starting point, the approaches will varybetween portfolios within the respective banks

► A number of banks are developing new models based on rollrate, historical loss rates and, or expert judgment. The use ofexpert judgment will require enhanced documentation andsupport for the methodology

► A number of banks that already have PiT PD estimates in theircurrent suite of credit risk models intend to leverage theseexisting models

Totals are less than 36 as some banks do not have a corporate or retail portfolio


CommentaryData

5. Measurement of expected credit lossProbability of default — lifetime

► To get to a lifetime PD, transition matrices is the single mostpopular approach but most banks will use differentapproaches (e.g. transition matrices and extrapolations and, orlifetime default observations) for different portfolios or products

► A number of the banks stating that they will use external datawill do so in the context of applying external transition matricesor filling gap in their internally built transition matrices. Somewill also use external data to build lifetime PD curves that arethen used to extrapolate internal data

► Given the high degree of judgment in choosing the modelapproach and the incorporation of different forward lookingelements, we expect to see granular and detailed disclosuresallowing comparability across banks

Totals are more than 36 as some banks have responded with multiple approaches

Estimating lifetime PD for IFRS 9 purposes

24

12

56

3

Corporate

18

21

5 11

Retail

Transition matrices

Models based on default observations over the life of the instrument

Extrapolations

External data

Undecided


CommentaryData

5. Measurement of expected credit lossLoss given default

2

7

1

15

1

9

Corporate

2

8

1

14

2

8

Retail Historical loss rates

Historical loss rates calibratedto PIT and forward-lookingexpectationsExpert judgment

Not applicable — full Basel LGD coverage

Other

Undecided

Calculation of LGD for IFRS 9 when not using Basel LGD

28

52

Retail

Yes

No

Undecided29

51

Corporate

Use of Basel LGD as a starting point



Leveraging Basel LGDs

► The majority of banks plan to leverage their Basel LGDs andadjust them to make them IFRS 9 compliant

► The most common adjustments are:

► Removal of downturn calibrations and floors to makeLGDs unbiased

► Discounting

► Application of lifetime and forward looking estimates

► Recovery costs

► Consideration of derivatives

Developing IFRS 9 LGDs

► For those who do not plan to leverage Basel LGDs or forportfolios where Basel LGDs are not available, most banksintend to derive PiT LGDs from historical loss rates, commonlycombined with macro economic variables and, or expertjudgment


CommentaryData

5. Measurement of expected credit lossLoss given default (cont’d)

15

11

3

6

Corporate

16

11

3

5

Retail Effective interestrate (EIR)

Contractual rate

Other

Undecided

Rate to discount LGDs

16

14

20

7

9

7

1

1

1

11

9

7

Secured Corporate

Secured SMEs

Secured Retail

Use of time-dependent LGDs

Yes

No

Other

Undecided

Totals are less than 36 as some banks do not have a corporate, SME or retail portfolio


Rate to discount LGDs

► The majority of banks intend to use the EIR or a proxy thereofto discount LGDs, the proxy often being the contractual rates

► Contractual rates are used on the basis of the effect not beingmaterially different from the EIR and often in line with thebanks’ current practices in interest recognition, however somebanks will perform further assessments before deciding (seeslide 13)

Reflecting the evolution of collateral value in the LGD

► When it comes to the use of time-dependent LGDs roughly athird of the banks are still undecided

► Some banks suggested they will only use time dependentLGDs where there is an established link between LTV andLGD – e.g. mortgages

► The most common approach for modeled portfolios is to adjustthe LGD against the indexed collateral value, with mostreferring to housing price index for their retail exposures, whilethe LGDs of non-modeled exposures will be adjusted throughexpert judgment


CommentaryData

5. Measurement of expected credit loss Forward looking information

Forward looking scenarios► The number of discrete forward looking scenarios required to

calculate ECLs is still up for debate. Most banks areconsidering a fixed number of scenarios, with participantseither:

► intending to use three scenarios, representing a best,worst and base case; or

► remaining undecided on the number of scenarios,although most ‘Undecided’ banks are choosingbetween using 2, 3 or 4 scenarios

► 4 of the banks intending to use only one scenario plan toreflect non-linearities in the loss distribution by means of amanagement overlay. Another considers that the effect ofalternative scenarios is already reflected in their basescenario. This approach will need to be properly documented

► Nearly all banks are planning to use centralized internalscenarios for consistency with business planning, stresstesting and IFRS 9. Centralized scenarios often are built upusing external information

Probability weighting of forward looking scenarios► The most common proposed approach is to derive separate

ECL numbers for each scenario and apply a probabilityweighting to derive the final number

► Some banks are using only one scenario, either the most likelyscenario or a pre-weighted scenario. Some will add an overlaywhile others did not mention an overlay or remain undecided.Their approach will need to be properly documented

7

1

12

1 13

11

Number of discrete forward looking

scenarios

7

1

16

3

9

One scenario with an overlay approach

Run multiple scenarios, calculate one ECL based onthe weighted average of credit risk factors

Run multiple scenarios, calculate an ECL for each,and probability-weight them

Modelled approach

Undecided

Probability-weighted approach to incorporate forward looking information

33

6

17

51 3

Sources of forward looking scenarios

Total is more than 36 as most banks have selected multiple sources of information


CommentaryData

5. Measurement of expected credit lossForward looking information (cont’d)

Probability of default► The majority of the banks are incorporating the forward

looking information at the calibration stage, adjusting the PDcalibration target to reflect the macro/customer specificvariations. We also note that a minority of banks are looking atincorporating macro-economic factors directly into the PDmodels

► All banks are planning to use some form of managementoverlay – in fact, a small portion are planning to relyexclusively on management overlays to adjust the modeloutcomes

► Banks do not seem to have finalized their governance processaround the management overlays, which is a process that hasproven to be time consuming e.g. the bank wide stress testexercises

Loss given default► Forward looking LGD continues to be an area where banks

are less advanced on their thought process compared to PDs,evidenced by almost a third of the banks still being undecidedon the approach

► The majority of banks that have selected ‘Other‘ state thatthey will use some form of macro economic variable basedforecast, for examle within the individual components in theLGD model, such as collateral values for secured loans

► Banks that state that they will use the existing stress testingprocesses will only stress the LTV values, affecting securedLGD and leaving the unsecured LGD flat

3

9

14

8

2

Retail Pre-calibration process

Post-calibration process

Combination of post-calibration process andmanagement overlay

Combination of pre-calibration process andmanagement overlay

Undecided

3

8

15

7

2

Corporate

Forward looking perspective - estimation of IFRS 9 PD

Forward looking perspective - estimation of IFRS 9 LGD

5

10

111

10

Corporate

4

9

213

10

RetailKeep the LGD static

Use stress testingprocesses

Management overlayusing expert judgement

Other

Undecided

Totals are equal to 36 however some banks do not have a corporate or retail portfolio, while some banks selected two approaches in combination

Total for corporate is less than 36 and equal to 36 for retail; some banks do not have a corporate or retail portfolio, while some banks selected 2 approaches in combination


CommentaryData

5. Measurement of expected credit lossExposure at default

► There is a clear trend with the majority of banks planning touse adjusted Basel credit conversion factors (CCF). Thefollowing are some rationales for the adjustments:

► Include only committed limits in the calculation of EADand capping the EAD to the contractually agreed limit

► Remove conservatism from the Basel CCF estimates

► Apply the payment and pre-payment pattern from non-revolving product to revolving products as a proxy

► For retail exposures in particular, banks will rely on behavioralassumptions to estimate drawdowns and repayment patterns

15

14

16

14

3

3

4

3

3

9

8

8

15

9

8

10

Financial Guarantees

Revolving - Credit Cards

Revolving - Committed lines

Revolving - Uncommited lines

EAD calculation for exposures with no amortisation or repayment plan

Use adjusted Basel advanced CCF assumptions

Use adjusted Basel standard CCF assumptions

Other

Undecided

Totals for credit cards and uncommitted lines are less than 36 as some banks do not have these exposures


CommentaryData

6

20

8

Retail

Yes

No

Undecided

12

11

11

Corporate

5. Measurement of expected credit lossPeriod over which to estimate ECL — revolving facilities

Capping lifetime at the next credit review for revolving facilities in stage 2

Totals are less than 36 as some banks do not have a retail or corporate portfolio

► Banks remain divided in this key area although a number ofbanks want to use some version of behavioral life (although itis unclear how they precisely define this term - disclosuresmay help clarify how behavioral life is ascertained). Many arestill undecided

► A smaller number of banks are considering capping behaviorallife or other periods to when the next thorough credit reviewoccurs. This approach might be challenging to support forretail portfolios. As discussed at the ITG meeting in December2015, banks who plan to use this approach will have to beable to demonstrate that they frequently take credit riskmitigating actions based on the outcome of the review process

► Some banks are considering using a fixed period, either afixed number of months depending on the characteristics ofthe products (e.g. fixed maturity) or the time between renewalof lending conditions. It is unclear how this choice will besupported

► Whatever the final outcome, banks should recognize theimportance of the disclosure related to areas of judgment(inputs, assumptions, portfolio segmentations and estimationtechniques), to assist users in understanding howmanagement formed their assessment

14

44

12

Corporate

14

8

3

9

RetailEstimating ECL period for revolving facilities in stage 2

Behavioral life

Use a fixed period

Behavioral life for portfolios to revert to stage 1, and an estimation of time to default and collect for transfer to stage 3Undecided


CommentaryData

7

19

10

Horizon for revolving facilities in stage 1

Yes — risk horizon < 12 months

No — 12 months risk horizon

Undecided

3

5

1

3

15

8

1

32

14

13

Corporate

Retail

Reference point to assess significant deterioration for revolving facilities

Initial date when the facility (e.g. thefirst credit card) was issued

Date when the facility was lastincreased

Date of the most recent thoroughcredit review

12 months before the reporting date

Not applicable — Use of maximal credit risk approached use for significant deterioration assessment as per IFRS 9 IG Example 6Undecided

5. Measurement of expected credit lossPeriod over which to estimate ECL — revolving facilities (cont’d)


Time horizon for estimating ECL - revolving facilities in stage 1

► Most banks do not intend to use a time horizon shorter than 12months, reflecting the timing of their credit review practice

► The remaining banks intend to use the behavioral life if lessthan 12 months and 12 months for all others, with mostundecided banks leaning towards this option too

Defining initial recognition for revolving facilities

► Many banks are undecided about their approach to thisdifficult topic

► For corporates, many banks intend to use the date of the mostrecent thorough credit review

► A relatively high number of banks are planning to use the dateof the most recent credit review for the retail portfolio as well;this might be a difficult approach to support as retail creditreviews tend to be less frequent and less thorough comparedto corporate reviews

► A smaller number of banks intend to consider the date whenthe facility was last increased (under the assumption thatcredit risk must have decreased since origination for theincrease to be granted)

► An even smaller number of banks intend to just look back 12months prior to the date of initial adoption. These entities willhave to demonstrate that this represents an acceptable proxybased on specific factors and circumstances


CommentaryData

6. IFRS 9 disclosuresEDTF recommendations and ECL specific disclosures

► Compliance with the 2012 EDTF recommendations is largelyconcentrated in countries where local regulators have requiredimplementation, namely the UK and Canada

► There is a higher level of compliance with originalEDTF recommendations (2012) as compared to theanticipated level of compliance with the EDTFrecommendations on ECL disclosures (2015), with 28 ofbanks applying most or all of the original recommendationsagainst 23 banks expecting to comply with most or all of theECL disclosure recommendations by the EDTF. This ratiomight change once the ECL implementation progresses

► Due to the phased approach for incorporating IFRS 9disclosures recommended by the EDTF, we anticipate thatthere will be an increase in the level of information provided asparticipants progress in their efforts towards IFRS 9implementation

► A few banks indicated that they will continue to assessapplication of the recommendations at a later stage

232

11

Plan to apply the 2015 ECL specific EDTF recommendations

Yes No Undecided

16

12

8

Current application of 2012 EDTF recommendations

Yes, all of them

Yes, most of them

No


A-IRB Advanced internal rating based approach G-CRAECL Guidance on credit risk and accounting for expected credit loss

BAU Business as usual ICAAP Internal capital adequacy assessment process

BCBS Basel Committee on Banking Supervision IRB Internal rating based approach

BMA Business model assessment ITG Impairment Transition Resource Group

C&M Classification and measurement LCR Low credit risk

CCF Credit conversion factor LGD Loss given default

DPD Days past due LTV Loan-to-value

EAD Exposure at default NPE Nonperforming exposure

EBA European Banking Authority PD Probability of default

ECL Expected credit loss PiT Point-in-time

EDTF Enhanced Disclosure Task Force QIS Quantitative impact study

EIR Effective interest rate SICR Significant increase in credit risk

FLI Forward looking information SPPI Solely payment of principal and interest

FVTPL Fair value through profit or loss SOX Sarbanes-Oxley Act

FVOCI Fair value through other comprehensive income

TOM Target operating model

Glossary


EY survey contacts

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Jana Währisch +49 160 939 23072 [email protected]

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EY IFRS 9 impairment banking survey - September · PDF filePage 7 Data Commentary 1. IFRS 9...

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