By Dipo Olowookere
Togo-based Ecobank Transnational Incorporated (ETI) has refuted a media report claiming it tampered with its accounts in order to make shareholders feel the company was doing well.
In a report by South Africa-based Sunday Times, it was claimed the Financial Reporting Council of Nigeria (FRCN) was already looking into the matter raised by a former CFO of Ecobank’s card division, Altu Sadie, that the financial institution applied incorrect exchange rates, which resulted in it overstating balance sheet items and income statements.
It was reported that the principal manager in the directorate of inspection and monitoring at FRCN, Olumuyiwa Ajibade, confirmed that “The council is working on it (issue). That’s as much as we can divulge at this time.”
Reacting to the issue, Ecobank, in a statement made available to Business Post on Wednesday, December 19, 2018, denied the “unfounded allegations,” urging its “shareholders, creditors, and other stakeholders” to disregard them.
It noted that, “The deterioration of the Naira in 2016 led to the creation of different windows for various segments of the economy leading to foreign currencies being traded in these markets/windows at different rates and thus leading to a multiple exchange rate system in Nigeria.
“The existence of multiple FX markets with different exchange rates as well as the accessibility to such markets necessitates the review of the appropriate exchange rates that entities should use in accounting for and reporting its foreign currency transactions as well as foreign investments into Nigeria under International Financial Reporting Standards (IFRSs). IAS 21 ‘The effects of changes in foreign exchange rates’, requires that a foreign currency transaction should be recorded at initial recognition in the functional currency using the spot exchange rate at the date of transaction (IAS 21, paragraph 21). IAS 21 paragraph 8 defines the spot exchange rate as the exchange rate for immediate delivery. Where a country has multiple exchange rates, an official quoted rate should be used as the spot rate.
“Nigeria currently has multiple exchange rates and judgment is required to determine which exchange rate qualifies as a spot rate that can be used for translation under IAS 21. In determining whether a rate is a spot rate, an entity is required to consider whether the currency is available at an official quoted rate and whether the quoted rate is available for immediate delivery.
“The CBN official rate, Nigeria Inter-bank Foreign Exchange Fixing (NIFEX) rates and the Nigerian Autonomous Foreign Exchange Fixing (NAFEX) rates are all quoted and can be used to convert or translate foreign currency transactions. Thus, the CBN official, NIFEX or NAFEX rates all technically comply with the requirements of IAS 21.
“As a policy within Ecobank Group, we use the official rate in the respective jurisdictions in which we operate to translate the results and balances of our affiliates into the Group’s reporting currency, the US Dollar. As a result, and in exercising the judgment allowed for within IAS 21, the Group currently uses the CBN official rate which is one of the 3 quoted rates and the official exchange rate according to the CBN.
“The use of this rate complies with IAS 21 and has been publicly disclosed to the market in all our press releases along with the impact of using the other available rates.
“This is done so that users of our financial statements can easily quantify and adjust for the use of the other exchange rates if necessary. Most of our peers in Nigeria used the CBN rate in 2017, before switching to NIFEX towards the end of the year. In 2018, they have gradually settled at a blend of both NIFEX and NAFEX.
“The use of the CBN rate is in accordance with the group’s policy which is to apply the official rates. This policy and its application are compliant with IFRS and specifically IAS 21.
“To enable comparison and to ensure that the user of the group’s financial statements is not prejudiced in any way, we have adequately disclosed in our various press releases and investor presentations the fact that we have used the CBN official rate in addition to disclosing the expected impact on our results of using alternative available rates.
“At its November board meeting, the Board of ETI approved the adoption of the NAFEX rate as the rate to be used for the translation of our operations in Nigeria. The change has been necessitated and approved in response to developments in the industry especially with the ETI’s peers moving away from the use of the CBN official rate.
“Ecobank Group adopted IFRS 9 as issued by the IASB in July 2014 with a date of transition of 1 January 2018, which resulted in changes in accounting policies and adjustments to the amounts previously recognised in the financial statements.
“Similarly to our peers in Nigeria, as well as other African and global banks, and, as permitted by the transitional provisions of IFRS 9, the Group has elected not to restate comparative figures. Adjustments to the carrying amounts of financial assets and liabilities at the date of transition were recognised in the opening retained earnings and other reserves of the current period. Overall, the adoption of the standard resulted in the group recording higher impairment allowance than that recognised under IAS 39. This had a negative impact on the group equity by $299m.
“The main drivers for the significant increase in IFRS 9 impairment figures when compared to IAS 39 impairment figures are:
• Replacement of the emergency period under IAS 39 with 12 months ECL on all exposures under IFRS 9.
• IFRS 9 introduces the stage 2 bucket where higher impairment (Lifetime losses) is recognised for facilities with significant increase in credit risk. Under IAS 39, same assets were classified as performing with minimal impairment recognised.
• Off balance sheet exposure & undrawn balances: Under IAS 39, impairment was not required to be recognised on these items, however, IFRS 9 requires that impairment provision on these items is calculated.
• Other financial instruments: Historically very little or no impairment has been held on non-customer loans/ instruments such as placements with other banks, government treasury bills and bonds, corporate bonds, items in the course of clearing and other debtors. These are now clearly within the scope of IFRS 9 and impairment has been computed on these.
“IFRS 9 2014 does not require restatement of comparativeperiod financial statements except in limited circumstances related to hedgeaccounting (not applicable to Ecobank Group) or when an entity chooses torestate (the Group has not, nor have most of its peers).
“The standard requiresthat where comparative periods are not restated, the difference between theprevious carrying amounts and the new carrying amounts be recorded in openingretained earnings or other components of equity, as appropriate. This is theapproach that has been followed by the Group and as a result the transitionimpact of $299m has been recognised in equity.
“In conclusion, we can confirm to allstakeholders that there were no misstatements in our financial statements asalleged in our financial statement for the year ended 31 December 2017 or inour three quarterly reports released during the 2018 year.
“We also note thatthis unfounded allegation was made by a former employee of the Group who iscurrently in court claiming payment of 13 years’ salary for an alleged unlawfultermination of his employment contract.”
1) Ecobank states in its reply “…an entity is required to consider whether the currency is available at an official quoted rate and whether the quoted rate is available for immediate delivery” Ecobank’s published reports notes that increased liquidity is due to NAFEX: Ecobank publishes the NAFEX rate as the official market rate and also comments on page 105 of the 2017 AFS “… non-interest revenue increased 4%…..That increase was primarily driven by client-related FX sales and trading, which significantly benefited from improvements in FX liquidity and client momentum in the NAFEX window in Nigeria” Ecobank also comments “…. due to an increase in income from client-related FX sales and trading, which benefited from improved FX liquidity and client momentum in the “’Investors’ and Exporters’ FX window”, in Nigeria “in its 21 March 2018 press release.
2) PWC guidance January 2018: In January 2018 PWC published a report under their current Financial reporting issues “Accounting considerations for foreign Currency transactions and balances in Nigeria under IFRSs” On page 6 they make it very clear that: “The translation of the financial statements of a foreign operation located in Nigeria should be translated at the NIFEX OR NAFEX rate because these are the two applicable rates at which they can remit proceeds from the investment whether from dividends or sale”. This also applies to any associate, joint venture or branch investments in a foreign operation that Entity A might have within Nigeria.” This is specifically applicable to Ecobank as they are headquartered in Togo and not a Nigerian bank and have to repatriate dividends / earnings. The PWC guidance on page 9 makes it very clear under disclosures: “The rate (or rates) used and the implications should be disclosed clearly. The rate (or rates) used might also be a significant accounting judgment as such the basis for such judgment should be disclosed in the financial statements under the ‘significant accounting estimates and judgements’ note”. Ecobank has not disclosed the reason for its judgement while all its peers came to a different conclusion using NAFEX / NIFEX as per Ecobank’s response.
3) The EY GAAP manual 2017 is also very clear on what rate must be used.
I. “…the rate applicable to dividend remittance”
(a) Ecobank must remit dividends using NAFEX as it is based in Togo
II. “The rate(s) selected will depend on the entity’s individual facts and circumstances, particularly its legal ability to convert currency or to settle transactions using a specific rate and its intent to use a particular mechanism, including whether the rate available through that mechanism is published or readily determinable” Ecobank uses NAFEX rates to settle transactions per its AFS 2017
4) Fitch report published 15 February 2018
“In our view, the exchange rate used under the Nigerian Autonomous Foreign Exchange Rate Fixing (NAFEX) mechanism is the closest to a true market rate. NAFEX was introduced last year and rates are set by market participants, giving investors and exporters a more transparent way to sell FC. NAFEX attracts greater volumes than other exchange mechanisms. The NAFEX exchange rate is about NGN360/USD”