In applying the portfolio guidance, valuation of the net open risk position is required. Market participants may value a portfolio with basis risk differently than one that was perfectly hedged. The following are some examples of mismatches in the portfolio that affect the measurement of fair value.
Basis differences
Portfolios with basis differences may qualify for the portfolio exception. If there is any basis difference for dissimilar risks, the reporting entity should reflect that basis risk in the fair value of the net position. For example, a reporting entity may include financial instruments with different (but highly correlated) interest rate bases in one portfolio, provided the reporting entity manages its interest rate risk on a net basis. However, reporting entities should consider any difference in the interest rate bases (e.g., LIBOR vs. Treasury) in the fair value measurement.
Duration differences
Similar to basis differences, portfolios containing offsetting positions with different maturities may qualify for the portfolio exception. Reporting entities should adjust the fair value of the portfolio’s net position for such duration mismatches. Therefore, unmatched (or unhedged) portions of the terms to maturity of the financial assets and liabilities that form part of the portfolio could result in an adjustment to the net position. For example, in a portfolio of interest rate swaps with long (asset) positions of 30 years to maturity offset with short (liability) positions of 25 years to maturity, the reporting entity could avail itself of the portfolio exception for the net position for interest rate risk. However, the reporting entity would measure the five years of unhedged long position as part of the net position.
Question FV 6-1 addresses whether a company can apply the portfolio exception for offsetting market price risk in common shares of an entity.
Question FV 6-1
FV Company owns one million common shares of Entity X and enters into a forward sale agreement for 500,000 additional shares of Entity X. FV Company accounts for the shares at fair value using the fair value option. FV Company documents and manages the long position of shares and the forward sale agreement together as a net position according to its investment strategy.
Can FV Company apply the portfolio exception for offsetting market price risk? Specifically, could FV Company value the net position based on the price that is most representative within the bid-ask spread, by incorporating a discount to the net position if this is how market participants would price the net risk exposure?
PwC response
Maybe. The portfolio exception changes the unit of measurement to the net position (rather than each individual share). Management should consider whether the degree of offset in the position is meaningful and determine whether the particular strategy is consistent with its overall investment policies and strategies.
Question FV 6-2 illustrates whether a company can apply the portfolio exception for offsetting interest rate risk positions with identical duration.
Question FV 6-2
FV Company has $500 million in 10-year pay 3-month LIBOR, receive fixed rate interest rate swaps (liability position) and $200 million in 10-year receive 3-month LIBOR, pay fixed rate interest rate swaps (asset position) that FV Company manages together and documents as a $300 million net liability position for purposes of managing interest rate risk.
Can FV Company elect the portfolio exception?
PwC response
Yes. When elected, the portfolio exception allows a reporting entity to measure the fair value of those financial assets and financial liabilities based on the net positions of the portfolio. Assuming the reporting entity has met the requirements for electing the portfolio exception, the exception permits FV Company to determine fair value based on how market participants would price the net risk exposure within the bid-ask spread. FV Company would adjust the bid-ask spread of the $500 million short position and the $200 million long position to a new bid-ask spread for the net short $300 million position based upon how market participants would price the net risk exposure at the measurement date.
In this example, the interest rate risk exposure on the long and short positions (three-month LIBOR) and the terms to maturity (10 years) are identical so there is no need to adjust for basis or duration mismatches. However, FV Company should consider any need for a counterparty credit risk adjustment.
Question FV 6-3 discusses the ability to apply the portfolio method when positions have different durations. Question FV 6-3 illustrates the application of the portfolio exception when the offsetting asset and liability have different durations.
Question FV 6-3
FV Company has $500 million in 10-year pay 3-month LIBOR, receive fixed rate interest rate swaps (liability position) and $200 million in 10-year receive 3-month LIBOR, pay fixed rate interest rate swaps (asset position) that FV Company manages together and documents as a $300 million net liability position for purposes of managing interest rate risk.
Assume that the long position (i.e., the $200 million swap asset) has a term to maturity of 12 years instead of 10 years. FV Company documents its holding as a $300 million net liability position for purposes of managing interest risk.
Can FV Company elect the portfolio exception?
PwC response
Yes, but FV Company would be required to adjust the fair value on the 10-year net position for the additional two years of net open risk. The fair value for the remaining two-year period on the 12-year swap would impact the valuation of the net position.