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Reporting Standards
for Hedge Funds
Overview side the EU have followed and IFRS has gained
acceptance as a set of global standards specifi-
This document is intended to introduce hedge cally among multinational organizations. For
funds and hedge fund service providers to Inter- example, approximately 40% of the Global For-
national Financial Reporting Standards (IFRS) tune 500 companies are currently using IFRS,
and to help them understand major differences with another 40% using GAAP, and the remain-
between them and U.S. GAAP. The information ing 20% using other local GAAP. Many of the
here will also educate them on potential companies using local GAAP are located in
impacts to their organization when adopting the countries that will be transitioning to IFRS in the
international standard, including considerations near term. Examples of some of the global mar-
for accounting systems. Finally, the document kets and emerging markets that are moving
will educate firms about Advent’s portfolio toward IFRS in the near term are: Chile (2009),
accounting system, Geneva,® and its currently South Korea (2009), Brazil (2010), Canada
available capabilities for supporting multiple (2011), and India (2011).
accounting standards.
What about IFRS in the
What is IFRS? U.S.?
International Financial Reporting Standards is a
The United States is almost the only major capi-
set of accounting principles that is rapidly gain-
tal market that has not yet adopted IFRS, but it
ing acceptance on a worldwide basis. These
seems that this may be changing soon. In
standards, which are published by the London-
August 2007, the SEC issued a “concept
based International Accounting Standards
release” soliciting input on whether U.S. regis-
Board (IASB), are more focused on objectives
trants should be permitted to have the option
and principles and less reliant on detailed rules
to prepare their financial statements using IFRS
than GAAP. While there have been convergence
or GAAP for SEC reporting purposes. The
efforts between the Financial Accounting Stan-
majority of comments received on the concept
dards Board (FASB) and the IASB since 2002,
release expressed support for permitting IFRS
there are still numerous differences that exist. In
for U.S. registrants. A “proposing release”
this publication, we have outlined some of the
and/or an IFRS roadmap are expected to be
differences between IFRS and GAAP that are
issued by the SEC during the second or third
specific to hedge funds.
quarter of 2008, which could result in U.S. com-
IFRS is being applied today in more than 100 panies having the option to adopt IFRS by 2010
countries where the use of IFRS is either or 2011. We may even see IFRS as a require-
required or permitted. The major breakthrough ment in the longer term.
occurred in 2002 when the European Union (EU)
But why should you, as a U.S.-based hedge fund
required all European-listed companies to adopt
or fund administrator, start considering IFRS? Is
IFRS by 2005. Since then, several countries out-
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it only because of the appeal of principle-based that has the power to govern the financial and oper-
accounting and the ability to apply professional judg- ating policies of the fund. The identity of the con-
ment to how certain transactions are accounted for trolling party will depend on the following factors:
compared to the rule-based GAAP? One of the reasons (i) the ability of the investment manager to make real
to consider IFRS is that the standard generally focuses investment and other decisions; (ii) the existence
on the “substance” of transactions, which results in of any rights to remove the investment manager;
an accounting presentation reflecting the “economic (iii) the existence of any other interest held by the
reality.” Another important reason to start considering investment manager or its affiliates in the investment
IFRS today is because adoption of IFRS in the U.S. is entity; and (iv) any other statutory, contractual, legal,
inevitable. IFRS provides an opportunity for reduced or regulatory constraints on the power of the invest-
complexity, greater transparency, increased comparabil- ment manager. Therefore, an investment manager
ity, and improved efficiency to investors, capital mar- with real decision-making powers who cannot be
kets, and companies. That is why many countries removed immediately and who has a significant eco-
including the U.S. are either considering or are in the nomic interest in a fund may have to consolidate
process of adopting IFRS. that fund under IFRS. The consolidation model
under IFRS does not provide exemptions to invest-
Is It Just Your Accounting ment companies. For example, and unlike GAAP,
when a feeder fund has control over its master fund,
Policies that Need to Change? the master fund should be consolidated into the
feeder fund.
The adoption of IFRS affects more than a company’s
accounting policies and financial reporting. Many ៑ Investments. Unlike GAAP, which requires all invest-
aspects of an organization’s business could be affected. ments to be recorded at fair value, IFRS would
The adoption of IFRS may have a transformational permit classifying investments as either (i) fair value
impact on financial reporting systems, internal controls, through profit or loss (held for trading or designated
taxes, treasury and cash management with an extended under fair value option); (ii) available-for-sale;
impact on employees, processes, and systems. (iii) held-to-maturity or (iv) loans and receivables. The
subsequent measurement attribute is based on the
Accounting Differences elected classification. Generally, held-to-maturity
classification is not possible for hedge funds and in
between IFRS and U.S. GAAP practice hedge funds typically classify their invest-
The differences outlined below are not intended to be ments as fair value through profit or loss (either held
an all-inclusive list but highlight significant differences for trading or designated under fair value option).
between IFRS and GAAP relevant to hedge funds. ៑ Fair Value. IFRS has not yet adopted fair value
Some of the most notable differences include: measurements guidance similar to SFAS 157 and as
such GAAP differences still exist.2 For example,
៑ Industry Specific Guide. In contrast to GAAP, which
under IFRS long positions must be valued at the bid
provides industry specific guidance for investment
price and short positions must be valued at the ask
companies,1 IFRS does not provide industry specific
price, while assets and liabilities with offsetting mar-
guidance. In fact, hedge funds use the same finan-
ket risks may be valued at mid-market prices for the
cial reporting standards that apply to other compa-
offsetting risk positions and at bid or asking price for
nies across all industries.
net position, as appropriate. Under GAAP, the use of
៑ Consolidation. Under IFRS, a fund should be consol- mid-price is permitted as a practical expedient.
idated by its controlling party—that is, the party
Transitioning to IFRS: Impact to need to capture cash activity with enough detail to
generate the Statement of Cash Flows and classify
Operations and Technology appropriately on statements.
Firms wishing to switch from GAAP to IFRS or to pro- ៑ Amortization. Premiums and discounts must be
duce reporting under both standards may require amortized under GAAP. With IFRS, there may not be
changes to their operational and technology environ- a need to segregate amortization from market gain
ments. In many cases, the requirements for IFRS are less (or loss) as the investments carried at fair value will
specific than GAAP and as such, in many cases treat- show the P&L through the fair value.
ment under GAAP will work for IFRS. However, some
៑ Classification of Investor Ownership. GAAP classi-
differences require different accounting treatment or
fies owner interest as equity. Under IFRS, ownership
reporting and therefore will impact how firms operate
may be expresses as equity or as a liability when the
and account for their investment activity. High level
interest is redeemable by the investor. In addition,
considerations include:
IFRS requires that investor capital be split between
៑ Pricing. Firms that are currently valuing investments share capital, premium, and surplus. Firms that were
using only the mid-price under GAAP will need to not previously tracking different types of ownership
accommodate additional prices for valuing their may need to do so to report accurately.
assets. Depending on how firms gather prices and
៑ Recognition of Unrealized and Realized Price
value their investments, this may represent a tech-
and Currency Gains. Under GAAP, firms should
nology change, as many firms are using technology
distinguish between realized and unrealized gains
to automate the process of price collection and
and price and FX gains. IFRS does not require this.
position valuation.
This is an example where GAAP is more specific,
៑ Trade vs. Settle Date Representation. Firms and while this may not change current operations
moving to IFRS who want to report initial recog- for a GAAP firm adopting IFRS, it may require tech-
nition of positions as of settle date will need to nology to report both ways without manual effort
ensure they are capturing settlement date informa- to combine gains for IFRS.
tion. Firms that are tracking positions for GAAP
៑ Functional Currency. It is possible for a fund to have
only based on trade date may not be capturing
different functional currencies under GAAP vs. IFRS.
settle date information today.
If this is the case, firms now need to ensure that
៑ Transaction Costs. Under GAAP, transaction costs additional FX rates to and from additional functional
are often recognized as part of an investment’s cost currencies are captured and must have the ability to
basis. As such, firms may not be tracking these sepa- restate in multiple currencies.
rate from investment cost. Under IFRS, transaction
៑ Segment Reporting. IFRS requires separate sub-
costs may need to be expensed. Firms that are not
reporting for business unit or geographic segments.
currently differentiating transaction costs from the
Firms will need to track and associate all investment
investment cost will need to identify transaction
activities to the appropriate segments.
costs so that different treatments may be applied.
៑ Risk Reporting. IFRS requires disclosures related to
Reporting Specifics the nature and extent of risk exposure of invest-
ments. The types of risk that must be reported
៑ Statement of Cash Flows. This statement is include credit risk, liquidity risk, interest rate risk,
required for IFRS even for firms that may be market risk, and currency risk.
exempted under GAAP. For firms that currently
provide this under GAAP, the potential exists for
classification differences. In both cases, firms will
IMPACT NOTE advent.com
maps, and accounting views. These features make ៑ Customizable Chart of Accounts and General
reporting in two standards possible with a single system Ledger Maps. Firms are able to add and subtract
and minimize the incremental change to support IFRS from Geneva’s chart of accounts as necessary (e.g.
reporting. to create different accounts for owner interest). With
In support of IFRS and GAAP, the system should gener- the General Ledger mapping functionality, firms can
ate compliant accounting results. However, it’s impor- define multiple sets of mapping logic that deter-
tant to note that with IFRS, as with GAAP, certain mines how the general ledger accounts flow through
specific reporting requirements that exist today, or may to different reports. For example, under GAAP real-
exist in the future, are not immediately available. Such ized and unrealized gains are mapped to separate
examples include consolidated or comparative financial classifications on the Statement of Operations. For
statements which require report customizations and IFRS, they may be combined.
qualitative notes and disclosures around risk. ៑ Accounting View. By default, Geneva includes all
There are several key features in Geneva which support applicable transactions on reports. However, to sup-
multiple standards: press consolidation or reclassification entries on
GAAP or IFRS statements, firms may want to
៑ Pricing. Geneva can store multiple prices per invest- exclude specific transactions. Special accounting
ment, including bid and ask prices, and can apply views can be associated to these transactions so
the bid/ask logic required by IFRS. Geneva also that they can be included on some statements but
tracks additional price details to support SFAS 157 excluded from others.
reporting.
៑ Accounting Filters/Business Units. Geneva sup-
៑ Accounting Parameters. Geneva’s Accounting ports tracking sub accounts for different business
Parameter sets allow firms to define a number of segments within a given portfolio. For IFRS report-
accounting rules that can be saved and applied ing, firms can choose to generate statements for
when generating financial reports. The settings in whole funds or for segments separately with no
an Accounting Parameter set include: additional effort.
៑ Book Currency. Each Accounting Parameter set may ៑ Inventory State. Geneva’s inventory state tracking
have a different functional currency. keeps detailed records of unsettled positions and
៑ Price Schedule and Bid/Ask Settings. Each set supports reporting from trade and settle date
applies a different set of pricing rules, which include perspectives.
a price schedule and hierarchy of different sources
and rules for utilizing bid and ask vs. mid-prices for
long and short positions.
៑ Amortization. Amortization settings can be alter-
nated to enable or disable this functionality and to
apply different methods for amortization.
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