Professional Documents
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▪ The IASB published the final version of IFRS 9 Financial Instruments in More than 90% of
assets/liablities are in the
July 2014 scope of IFRS 9 (evidenced
▪ IFRS 9 endorsed by EU on 22 November 2016 in yellow)
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Financial instruments in the Banking industry (liabilities) Financial instruments in the Banking industry (P&L)
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IFRS 9 Classification and Measurement
Overview
IFRS 9 contains 3 main measurement categories for financial assets, as illustrated below:
Classification
Loss (i.e. FVTPL)
FVOCI)
■ Although the permissible measurement categories for financial assets appear to be similar to IAS 39, the criteria for
classification into the appropriate measurement category are significantly different
■ According to IFRS 9.4.1.1, the assessment as to how an asset should be classified is made on the basis of both the
entity’s business model for managing the financial asset and the contractual cash flow characteristics of the
financial asset (i.e. “SPPI test”)
■ A financial asset shall be measured at amortized cost if it is held within a business model whose objective is to hold
financial assets in order to collect contractual cash flows and its contractual terms give rise on specified dates to cash
flows that are Solely Payments of Principal and Interest (SPPI) on the principal amount outstanding
© 2022 Monte dei Paschi di Siena 6 © 2022 Monte dei Paschi di Siena 7
–
No flows and by selling
financial assets? Not an election (required)
Has the entity elected
the irrevocable OCI
option? No
Yes
– Classified as trading if any of the following:
Yes
• Acquired or incurred for purpose of selling or repurchasing in near term
FVOCI FVOCI
(equity instruments)
FVTPL
(debt instruments)
AC • On initial recognition, part of portfolio for which there is evidence of a recent actual
▪ Dividends generally recognised in ▪ Interest revenue, credit impairment pattern of short-term profit-taking
P&L Changes in fair value recognised in and foreign exchange gains or losses
▪ Interest revenue credit
▪ Changes in fair value recognised
in OCI
P&L
▪ Interest revenue, dividends and
recognised in P&L (in the same
manner as for amortized cost assets)
impairment and foreign exchange • Derivative, including bifurcated embedded derivatives
gains or losses recognised in P&L
▪ No reclassification of gains and foreign exchange gains or losses ▪ Other gains and losses recognised in
losses to P&L on derecognition recognised in P&L OCI
▪ On derecognition, gain and losses
recognised in P&L
– Exceptions: Designated and effective hedging instruments, financial guarantee contracts
and no impairment recognised in ▪ On derecognition, gains and ▪ On derecognition, cumulative gains
P&L losses recognised in P&L and losses in OCI reclassified to P&L
▪ No impairment recognised
© 2022 Monte dei Paschi di Siena SPPI test Business Model Assessment 8 © 2022 Monte dei Paschi di Siena 9
Yes Yes
Is it held for trading? Is the business model's Is it held for trading? Is the business model's
No objective achieved both by No objective achieved both by
collecting contractual cash collecting contractual cash
No flows and by selling No flows and by selling
financial assets? financial assets?
Has the entity elected Has the entity elected
the irrevocable OCI Yes the irrevocable OCI Yes
option? No option? No
Yes Yes
The assessment to conduct under IFRS 9 on equity instruments can be synthetically summarized in
the following steps Under IFRS 9, FVOCI election:
▪ Is available for all investments in equity instruments in the scope of IFRS 9 that
Steps of analysis are not held for trading
1 OCI option ▪ Determines a different accounting treatment compared to the FVOCI category
▪ Verify whether the instrument under analysis meets the for debt instruments as:
Definition of
definition of equity instrument provided by IAS 32.11 “An equity − The impairment requirements in IFRS 9 are not applicable
instrument is any contract that evidences a residual interest in − All foreign exchange differences are recognized in OCI
the instrument the assets of an entity after deducting all of its liabilities” − Amounts recognized in OCI are never reclassified to profit or loss even
upon disposal/ derecognition
− Only dividend income is recognized in profit or loss
2
▪ Verify whether the equity instrument meets the definition of held
Held for for trading provided by IFRS 9 - Appendix A
▪ Accordingly, an equity instrument is held for trading if it is
trading acquired principally for the purpose of selling it in the near term
definition or on initial recognition it is part of a portfolio for which there is
evidence of a recent actual pattern of short term profit taking According to the definition provided by IFRS 9, FVOCI election is:
▪ Irrevocable: de-designation is not permitted
▪ Made at inception: at the date of initial application (i.e. DIA) or at the date of acquisition
3
▪ In case of equity instruments not held for trading, decide
whether the OCI option has to be adopted
OCI option * ▪ Formalize within a policy the condition for the OCI option
election
© 2022 Monte dei Paschi di Siena 10 © 2022 Monte dei Paschi di Siena 11
IFRS 9 Classification and Measurement No No
Financial asset in the scope of IFRS 9
Yes Yes
Is it held for trading? Is the business model's Is it held for trading? Is the business model's
No objective achieved both by No objective achieved both by
collecting contractual cash collecting contractual cash
No flows and by selling No flows and by selling
financial assets? financial assets?
Has the entity elected Has the entity elected
the irrevocable OCI Yes the irrevocable OCI Yes
option? No option? No
Yes Yes
The assessment to conduct under IFRS 9 on derivative instruments can be performed in the following
step Standard requirements Observations
“[…] an entity may, at initial recognition, irrevocably ▪ Any financial asset that is managed on a fair value basis is
Steps of analysis
designate a financial asset as measured at fair value through mandatorily measured at FVTPL under IFRS 9 due to its
profit or loss if doing so eliminates or significantly reduces business model
[…] an ‘accounting mismatch’ […]” (IFRS 9.4.1.5) ▪ Under IFRS 9 embedded derivatives are not separated
▪ Verify whether the instrument under analysis meets the definition from a hybrid financial asset and a hybrid contract in its
of derivative instrument provided by IFRS 9 Appendix A entirety is likely not to meet the SPPI criterion (see
▪ A derivative is a financial instrument or other contract within the following slides)
scope of IFRS 9 with all three of the following characteristics:
− its value changes in response to the change in a specified
underlying (e.g. interest rate, commodity price)
− it requires no initial net investment or an initial net
investment that is smaller than would be required for other
Definition of the types of contracts that would be expected to have a similar
instrument response to changes in market factors
− it is settled at a future date
▪ A derivative different from a financial guarantee or a designated
and effective hedging instrument meet the definition of held for
trading provided by IFRS 9 Appendix A, thus it is measured at
FVTPL
© 2022 Monte dei Paschi di Siena 12 © 2022 Monte dei Paschi di Siena 13
Financial asset in the scope of IFRS 9 Financial asset in the scope of IFRS 9
Yes Yes
SPPI Test (performed at financial asset level) tests wether cash flow interests are from: Leverage Clauses that increase volatility of the cash flows (e.g, 2XEuribor6M)
© 2022 Monte dei Paschi di Siena 14 © 2022 Monte dei Paschi di Siena 15
1
Financial asset in the scope of IFRS 9
Yes Yes
The Business Model Assessment to conduct under IFRS 9 can be synthetically summarized in the “An entity’s business model refers to how an entity manages its financial assets in order to generate cash flows.
following macro-steps That is, the entity’s business model determines whether cash flows will result from collecting contractual cash
flows, selling financial assets or both.” (IFRS 9.B4.1.2A)
Steps of analysis
The standard provides the following example of relevant and objective evidence to identify for assessing the
1 business model:
▪ Enhance documentation of the relevant business
Identify relevant objectives and operating policies ▪ An entity considers frequency, volume and timing of sales in prior periods, the reasons for such sales, and
and objective ▪ Establish processes and controls over gathering and its expectations about future sales activity
evidence assessing relevant and objective evidence, to support Sales activities (see ▪ Information about sales is not considered in isolation but as part of a holistic assessment of how the entity’s
the assessment on an ongoing basis IFRS 9.B4.1.2B) objective is achieved and cash flows are realized
▪ Information about past sales has to be considered taking into account the conditions that existed at that
time as compared to current conditions
2 Performance
Define each ▪ How the performance of the business model (and the financial assets held within that business model) are
evaluation (see IFRS
▪ Specify within a policy the characteristics that drivers evaluated and reported to the entity’s key management personnel
business model 9.B4.1.2C)
above identified assume in each business model
criterion
Risks managed (see ▪ Risks that affect the performance of the business model (and the financial assets held within that business
IFRS 9.B4.1.2C) model) and the way those risks are managed
3
▪ Perform an adequate segregation of portfolios to Management
Identify ▪ How managers of the business are compensated (e.g. whether the compensation is based on the
identify groups of financial assets managed together compensation (see
portfolios/ fair value of the assets managed or the contractual cash flows collected)
to achieve a particular business objective IFRS 9.B4.1.2C)
subportfolios for
▪ Apply to each group the rules defined in the previous
the assessment ▪ No “bright-lines” for assessing the impact of sales activity – i.e. no definition of
steps Observation
significance and frequency of sales
© 2022 Monte dei Paschi di Siena 16 © 2022 Monte dei Paschi di Siena 17
IFRS 9 Classification and Measurement 2 2
Financial asset in the scope of IFRS 9 Financial asset in the scope of IFRS 9
Yes Yes
Is it held for trading? Is the business model's Is it held for trading? Is the business model's
No objective achieved both by No objective achieved both by
collecting contractual cash collecting contractual cash
No flows and by selling No flows and by selling
financial assets? financial assets?
Has the entity elected Has the entity elected
the irrevocable OCI Yes the irrevocable OCI Yes
option? No option? No
Yes Yes
“Financial assets that are held within a business model whose objective is to hold assets in order to collect contractual cash flows are “[…] In this type of business model, the entity’s key management personnel have made a decision that both collecting contractual
managed to realize cash flows by collecting contractual payments over the life of the instrument […]” (IFRS 9.B4.1.2C) cash flows and selling financial assets are integral to achieving the objective of the business model. There are various objectives that
Relevant and objective evidence within a held-to-collect business model show the following characteristics: may be consistent with this type of business model. For example, the objective of the business model may be to manage everyday
liquidity needs, to maintain a particular interest yield profile or to match the duration of the financial assets to the duration of the
liabilities that those assets are funding […]” (IFRS 9.B4.1.4A)
IFRS 9.B4.1.3A-B give the following examples of sales that may be consistent with the HTC business Relevant and objective evidence within a held-to-collect business model show the following characteristics
model:
▪ Sales infrequent (even if significant in value) or insignificant in value both individually and in
aggregate (even if frequent)
▪ Sales take place close to the maturity of the financial asset and the proceeds from the sales According to IFRS 9.B4.1.4B:
approximate the collection of the remaining contractual cash flows ▪ Compared to a HTC criterion, this business model will typically involve greater frequency and value
Sales activities ▪ Sales due to an increase in the credit risk of a financial asset irrespective of their frequency and Sales activities of sales
value: ▪ However, there is no threshold for the frequency or value of sales that must occur in this business
− This is the case of a sale of a financial asset which no longer meets the credit criteria model
specified in the entity’s documented investment policy (the increase in credit risk may be
demonstrated in other ways, in absence of such a policy)
Sales made in managing concentrations of credit risk do not represent an exemption ▪ For example, performance is evaluated based on the overall return generated by a portfolio held to
Performance
An entity need not hold all of these assets until maturity collect contractual cash flows and, when an opportunity arises, sold to re-invest the cash in financial
evaluation
assets with a higher return
Performance ▪ For example, reports to management focus on the credit quality and contractual returns; fair value is
evaluation considered from a liquidity perspective
Risks managed ▪ Risks managed are for example credit risk, interest yield risk, liquidity risk
Risks managed ▪ Credit risk affects the performance of the business model as credit quality is relevant to the entity’s ability to
collect contractual cash flows
Management ▪ With regard to the example above, compensation in based on the overall return generated by the
Management compensation portfolio
▪ Compensation in based on the credit quality and contractual returns
compensation
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2
Financial asset in the scope of IFRS 9
No
No
No
Is the business model's
objective achieved both by
collecting contractual cash
flows and by selling
financial assets?
Yes
option?
Yes
FVOCI FVOCI
FVTPL AC
(equity instruments) (debt instruments)
“Financial assets are measured at fair value through profit or loss if they are not held within a business model whose objective is to Is the instrument a derivative or
hold assets to collect contractual cash flows or within a business model whose objective is achieved by both collecting contractual Yes
financial liability that is held for
cash flows and selling financial assets […]” (IFRS 9.B4.1.5) trading?
Relevant and objective evidence within a held-to-collect business model show the following characteristics:
No Would split Yes FVTPL
presentation of changes
Is it designated under the fair value Yes due to credit risk create
FV changes not due to credit
According to IFRS 9.B4.1.5-6 one business model that results in measurement at fair value option*? or enlarge an
risk
through profit or loss is one in which: accounting mismatch in
Sales activities No
▪ The entity manages the financial assets with the objective of realizing cash flows through the sale P&L?
of the assets; such an objective will typically result in active buying and selling No
▪ The portfolio meets the definition of held for trading FV changes due to credit
risk FVOCI
Does it contain a separable
embedded derivative(s)?
Performance ▪ The entity is primarily focused on fair value information to make decisions and performance is
evaluation evaluated on a fair value basis Yes
Separate the host and
the embedded
Risks managed ▪ For example, market risk derivative(s)
No
© 2022 Monte dei Paschi di Siena 20 © 2022 Monte dei Paschi di Siena 21
No Yes
FVTPL
Yes
Host Derivative(s)
AC
Under IFRS 9.5.7.7, fair value changes on financial liabilities designated under the fair value
option are presented as follow:
▪ The amount of change in the fair value that is attributable to changes in the credit risk of
the liability is presented in OCI
Own credit
risk ▪ The remaining amount of change in the fair value is presented in profit or loss
Amounts presented in OCI are never reclassified to profit or loss. However, an entity may
transfer the cumulative gain or loss within equity (see IFRS 9.B5.7.9)
Financial Assets–Impairment
© 2022 Monte dei Paschi di Siena 22 © 2022 Monte dei Paschi di Siena 23
IFRS 9 Impairment Model IFRS 9 Impairment Model
Scope Expected Credit Losses - Significant Credit Deterioration (PD Threshold Method)
▪ Financial guarantee contracts to which IFRS 9 applies and that are not accounted at FVTPL At0 Significant deterioration
At1
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The term "significant increase" is not defined in IFRS 9. Determinig whether there has been a significant increase in credit risk is one of
(*) For purchased – originated credit impaired assets, the credit-adjusted EIR (i.e. the EIR calculated on the contractual cash flows NET of initial loss expectations) is used instead of the EIR the most critical and difficult judgement areas in the model. Entities will need to decide how they will define this key term in the context
(**) See below for further details
of their instruments
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The following non-exhaustive list of information may be relevant in assessing changes in credit risk (IFRS 9. B5.5.17):
As an exception from the general requirements, an entity may assume that the criterion for recognising lifetime expected
credit losse is not met if the credit risk on the financial instrument is low at the reporting date.
a) significant changes in internal price indicators of credit risk as a result of a change in credit risk since inception, including, but not
limited to the credit spread that would result if a particular financial instrument or similar financial instrument with the same terms and the If a financial instrument is determined to have low credit risk at the reporting date an entity
same counterparty were newly originated or issued at the reporting date. may assume that the credit risk of the financial instrument has not increased significantly since initial recognition.
b) other changes in the rates or terms of an existing financial instrument that would be significantly different if the instrument was
newly originated or issued at the reporting date (such as more stringent covenants, increased amounts of collateral or guarantees, or higher
income coverage) because of changes in the credit risk of the financial instrument since initial recognition.
c) significant changes in external market indicators of credit risk for a particular financial instrument or similar financial instruments with IFRS 9 states that the credit risk is low if (IFRS 9.B5.5.22):
the same expected life. ❖ The instrument has a low credit risk of default;
d) an actual or expected significant change in the financial instrument’s external credit rating.
❖ The borrower has a strong capacity to meet its contractual cash flow obligations in the near term;
e) an actual or expected internal credit rating downgrade for the borrower or decrease in behavioural scoring used to assess credit risk
internally. Internal credit ratings and internal behavioural scoring are more reliable when they are mapped to external ratings or supported Low credit risk ❖ Adverse changes in economic and business conditions in the longer term may, but will not necessarily, reduce
by default studies. the borrower's ability to fulfil its obligations
f) existing or forecast adverse changes in business, financial or economic conditions that are expected to cause a significant change in the
borrower’s ability to meet its debt obligations, such as an actual or expected increase in interest rates or an actual or expected significant The low credit risk notion is not a bright-line trigger for lifetime ECL
increase in unemployment rates.
g) an actual or expected significant change in the operating results of the borrower. Examples include actual or expected declining
revenues or margins, increasing operating risks, working capital deficiencies, decreasing asset quality, increased balance sheet leverage, Observation
liquidity, management problems or changes in the scope of business or organisational structure (such as the discontinuance of a segment of
the business) that results in a significant change in the borrower’s ability to meet its debt obligations. IFRS 9 states that the financial instrument with an external rating of "investment grade" is an example of an instrument that may be
h) significant increases in credit risk on other financial instruments of the same borrower considered to have low credit risk (IFRS 9.B5.5.23)
i) an actual or expected significant adverse change in the regulatory, economic, or technological environment of the borrower that
results in a significant change in the borrower’s ability to meet its debt obligations, such as a decline in the demand for the borrower’s sales However an external rating is a lagging indicator, as it does not reflects events that occur or other relevant information that become
product because of a shift in technology. avaible after the rating agency last updated its rating. In addition, the definition used by a ratings agency may not be consistent with the
j) … definition of default used by the entity.
Therefore, in order to conclude that an instrument with an external rating equivalent to "investment grade" has low credit risk, the entity
will need to consider whether there is evidence of an increase in credit risk that is not yet reflected in the rating.
© 2022 Monte dei Paschi di Siena 28 © 2022 Monte dei Paschi di Siena 29
IFRS 9 Impairment Model
IFRS 9 Impairment Model
The expected credit loss concept 12-months EL calculation
The probability-weighted estimate of credit losses (ie the present value of all cash
Expected credit losses
shortfalls) over the expected life of the financial instrument (IFRS 9.B5.5.28) ■ EAD –Exposure at Default
■ Cash and undrawn credit lines
IFRS 9 requirements
© 2022 Monte dei Paschi di Siena 30 © 2022 Monte dei Paschi di Siena 31
© 2022 Monte dei Paschi di Siena 32 © 2022 Monte dei Paschi di Siena 33
Hedge Accounting
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Exposure Identification & Hedge Accounting Models Fair Value Hedge (cont’d)
Exposure?
Measurement of derivative
E
A
Change in fair value R
Fair
Cash Net N
Value
Flow Investment
Measurement of hedged item I
Offsetting gain or loss N
• Exposure to changes in FV • Exposure to changes in cash • Consolidated financial attributable to risk being hedged
flows statements
G
• Affects earnings
• Recorded fixed rate assets • Affects earnings in future S
and liabilities periods
• Firm commitment • Recorded floating rate assets
and liabilities Net effect — ineffectiveness will be seen in the P&L
• Forecasted transactions
• Fx firm commitment
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• Two or more derivatives may be jointly designated as hedging – Designation of portions of time not permitted
instrument.
© 2022 Monte dei Paschi di Siena 38 © 2022 Monte dei Paschi di Siena 39
• Only external derivatives can be designated as hedging instruments • Formal documentation is required at the inception of the hedge
(not other assets/liabilities except for foreign currency risk). relationship and must include:
• Only external assets/liabilities or transactions can be designated as – Identification of the hedging instrument and the hedged item or
hedged items (intragroup forecasted transactions can under certain transaction
circumstances be hedged items in the consolidated financial – The nature of the risk being hedged
statements).
– The risk management objective/strategy
• If hedged item = portfolio of assets/liabilities:
– How effectiveness will be assessed
– Change in FV of each individual asset/liability must be approximately
proportional to change in FV of portfolio
– e.g., for the hedged risk, if the portfolio increases 10%, each individual item
should be expected to increase 8% - 12.5%
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Hedge Effectiveness Monitoring Hedge Effectiveness
• Effectiveness—The ability to generate offsetting changes in fair value • If ineffective, entire hedge does not qualify for hedge accounting.
or cash flows. – Hedge activity recorded prior to failure is not impacted.
• Prospective expectation of highly effective hedge relationship: • Even effective, some ineffectiveness occurs unless 100% effective.
– At inception, and
– Ineffective portion recorded in P&L.
– At least at each reporting date.
• Retrospectively analyze actual effectiveness results:
– Effectiveness.
– Assess historic effectiveness (either periodic or cumulative, depending on
policy).
– Determine if the effectiveness is expected to continue (prospective test).
© 2022 Monte dei Paschi di Siena 42 © 2022 Monte dei Paschi di Siena 43
measurement of ineffectiveness. T0
accounting entries BS P&L
Loan classified at AC (amortised cost) DR CR A E/L C R
Embedded
Fair Value t1 91 100 100 0 0 0 0 loss of value
– P/L impact
SWAP accounting entries BS P&L
by
Notional value 100 DR CR A E/L C R
Pay leg (fixed rate) 4% Hedge effect (P&L) 9 9 loan (BS) loan 91 5 Profit Hedge effect 9 10 FV gain (swap)
Receive leg (variable rate) Euribor 3M+3% Cash inflow (BS) 4 4 Interest income (P&L) cash outflow -100 4 Loan Interest income
Fair Value t0 0 swap (BS) 10 10 FV gain (P&L) swap 10 swap interest income/expense
• Based on actual results. Fair Value t1 10 Swap net cashflow 0
23
0 Interest income (P&L)
23
Cash inflow 4
5 5 9 14
expected.
© 2022 Monte dei Paschi di Siena 44 © 2022 Monte dei Paschi di Siena 45
Derecognition of a
Financial Asset
© 2022 Monte dei Paschi di Siena 46 © 2022 Monte dei Paschi di Siena 47
Derecognition Decision Tree Derecognition Decision Tree
STEP #1: Consolidate all subsidiaries (including SPEs) pursuant to IFRS 10
YES NO
STEP #8: Has the entity retained control over the NO Derecognize the
STEP #5: Has the entity assumed a contractual obligation to pay the cash NO Continue to Transferred Asset
transferred asset?
flows of the asset to a third party Recognize the and Recognize G/L
Transferred Asset YES
YES
STEP #9: Continue to recognize the transferred asset to the extent of
STEP #6: Has the entity transferred substantially all the risks and rewards of YES
Derecognize the continuing involvement
ownership?
NO Transferred Asset
and Recognize G/L
Next
slide
© 2022 Monte dei Paschi di Siena 48 © 2022 Monte dei Paschi di Siena 49
© 2022 Monte dei Paschi di Siena 50 © 2022 Monte dei Paschi di Siena 51
• Case 1: the Bank underwrites all notes issued by the SPV • Case 2: all notes issued by the SPV are underwritten by market investors
• Conclusion • Conclusion
• The Bank has retained substantially all the risks and rewards of ownership of the NPLs. • The Bank has transferred substantially all the risks and rewards of ownership of the NPLs.
Then the Bank continues to recognize the NPLs (but doesn’t recognize the notes) Then the Bank derecognizes the NPLs
© 2022 Monte dei Paschi di Siena 52 © 2022 Monte dei Paschi di Siena 53
Derecognition (example) Derecognition (example)
• Case 3: The Bank underwrites 10% of the junior notes and 30% of mezzanine • If the result of the test is <=10% then the Bank derecognizes the assets
notes. The remaining notes are underwritten by market investors
• If the result of the test is >10% then there are two possible outcomes:
Cash
1. The Bank doesn’t control the assets transferred; then it derecognizes the NPLs
1.800 Cash
1.800 2. The Bank controls the assets transferred; then it recognizes a pro rata share of the
Notes
Bank 200 SPV Investors NPLs
Notes
Control is defined as the ability for the transferee to sell the asset
NPLs 1.800
2.000
• The Bank has to assess to what extent has retained the risks and rewards of
ownership of the NPLs. It compares
σNPV Notes
σNPV NPLs
• σ(NPVNotes )= variability of the net present values of the underwritten notes
• σ(NPVNPLs )= variability of the net present values of the NPLs
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