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BT 142897

QUESTIONS for Christos

Private Placement changes. Can you now create a call/put/prerefund announcement for a Private Placement? Why the change? Must the security in Issue Viewer have more than Private Placement set to Y to create the CA annoucement? Would only Insurance clients do it or would core clients too? 

Should we add an example to the Corporate Action section for calls/puts/prerefunds that use this treatment?

should we document the calculated values? are they calculated at transaction level? Position? 

unsure how to document report impact. more or less detail? define the new columns? 

INSURANCE How do you identify a security with a make whole provision? Are clients supposed to do that as part of setup? ? BRD says you can identify on SMF. Insurance Guide says Bond Characteristic field = Y for bond when Call = Y and Make Whole Call Flag = Y.  BT 140270 from 2016 says to put Make Whole Call field back on Long Term Debt panel. BT 136014 says the announcement doesn't reflect this field. 

Release Note (for reference only)

The NAIC has updated the accounting requirements relating to prepayment penalties, acceleration fees, and make-whole call provision fees on bonds. Insurance companies were following different accounting treatments in reporting these fees on transactions. Some companies were including the prepayment penalties and acceleration fees as part of consideration in determining the realized gain/loss at disposition, while other companies were accounting for the prepayment fees and acceleration fees as investment income. This difference in accounting treatment led to differences in amounts reported for realized gains/losses and investment income based on the accounting treatment elected by company. As a result, companies were reporting prepayment penalties, acceleration fees, and make-whole call provision fees received on call and principal repayment corporate actions on bonds as gain/loss rather than investment income.

Eagle Accounting can process calls and principal repayment corporate actions, by accounting basis, in accordance with the NAIC treatment detailed. Insurance clients can set a new Entity Accounting Basis tag, Income/Prepayment Fee Treatment (tag 16739,) to one of the following values: All, Calls Only, Principal Repayments Only, None. If this new field is not set (that is, left NULL), it is treated as None in the STAR calc rules.

In conjunction with this entity basis setting, you must make an additional setting on all corporate actions set up as Tran Type (tag 1257) equal to CA_CASH_CLOSE. You can set the new corporate action field, Income/Prepayment Fee Treatment (tag 2290), to one of the following values: Call, Principal Repayment, None. If this new field is not set (that is, left NULL), it is treated as None in the STAR calc rules.

The system now processes corporate actions in entities using this new functionality when the entity basis and corporate action settings match.

Understand the Income/Prepayment Fee Treatment

The income/prepayment fee treatment enables Eagle's insurance clients to apply an accounting treatment in Eagle Accounting that supports NAIC accounting requirements relating to prepayment penalties, acceleration fees, and make-whole call provision fees on bonds. Insurance clients can elect this treatment at the accounting basis level and have Eagle Accounting apply the income/prepayment fee treatment to call and/or principal repayment corporate actions during corporate action processing. 

You can use the income/prepayment fee treatment to:

  • account for prepayment fees and acceleration fees and make-whole call provisions as investment income
  • identify acceleration fees and prepayment fees on dispositions and not considered them in determining realized gains/losses on dispositions
  • identify and account for make-whole call provision amounts received for an investment on disposition as investment income.

business objectives need review

Set Up Entities and Accounting Bases

UPDATE all entity and basis panel option pages

UPDATE Create Calls/Puts/Refund Panel options

UDPATE About Entity Setup for Calls, Puts, and Pre-refunds. 

Eagle Insurance clients can identify this setting for each accounting basis where they want to apply this methodology by setting the Income/Prepayment Fee Treatment field. This field is available in the Corporate Action Fields section of the Create/Edit Entity panel, the Create Master Fund panel, the Add a Basis to a Portfolio panel, and the Edit Master Fund/Sector panel. A description follows. 

Option

Tag

Description

Income/Prepayment Fee Treatment16739

Identifies the types of corporate actions for the entity's selected accounting basis that use the income/prepayment fee treatment. The income/prepayment fee treatment supports NAIC accounting requirements relating to prepayment penalties, acceleration fees, and make-whole call provision fees on bonds. For use with Eagle's insurance accounting solution. The system uses this setting in conjunction with the Income/Prepayment Fee Treatment field set at the corporate action transaction level. Options include:

  • All. The system can apply the NAIC income/prepayment fee treatment to calls and principal repayments. 
  • Calls Only. The system can apply the NAIC income/prepayment fee treatment only to calls. 
  • Principal Repayments Only. The system can apply the NAIC income/prepayment fee treatment only to principal prepayments. 
  • None. Also applied to null values for this field. The system cannot apply the NAIC income/prepayment fee treatment to corporate actions.

NOTE:  When you enable use of the income/prepayment fee treatment for specific types of corporate actions at the entity/basis level, be aware that the system does not consider the basis level Redemption Gain/Loss Indicator setting for transactions that use the income/prepayment fee treatment. If you set the Redemption Gain/Loss Indicator field to Amortization, the system treats those transactions as if you set the Redemption Gain/Loss Indicator field to Gain/Loss.

Set Up Securities for Insurance Accounting

You can identify securities that have make-whole call provisions on the security master file. For more information about using the bond characteristic of Make Whole Call with Eagle Insurance, see Maintain Security Master File (SMF) Information.

Make Whole Callable is not in IV Long Term Debt panel. Bug to add it. 

PRIVATE PLACEMENT: how to identify?

You can identify securities securities with a make whole call provision or with private placements using the following options. 

Option

Tag

Description

Make-Whole Callable10346

Indicates whether the security can have make-whole call provision fees. 


?????? THere are no Yes or No options to select. How do you enter a value?

Private Placement

1421

Indicates whether the security is a private placement. Options include:

  • Yes
  • No

This field is used for reference only.

?????? Do you need to know about this for this enhancement? Already documented for IV

Set Up and Process Corporate Actions

UPDATE Create Calls/Puts/Refund Panel Options page. The annoucement current is for Call, Put, Principal Repayment Type CA, and those are the reason codes. Now? 

The following fields were added to the Create Calls/Put/Refund panel in RDC.

Option

Tag

Description

Private Placement1421Displays the security's Private Placement field value, A value of Y indicates that the security is a private placement. 
Income/Prepayment Fee Treatment16739

Indicates whether the selected call or principal repayment is eligible for the system to apply the income/prepayment fee treatment. The income/payment fee treatment supports the NAIC accounting requirements relating to prepayment penalties, acceleration fees, and make-whole call provision fees on bonds. For use with Eagle's insurance accounting solution. The system applies this accounting treatment during corporate action processing only if the transaction's accounting basis also has the Income/Prepayment Fee Treatment field set to enable processing for selected type of corporate action. This field appear only if you set the Corporate Action Type field to Call or Principal Repayment. Options include:

  • Call. Indicates the system can apply the NAIC income/prepayment fee treatment to this call only if the transaction's accounting basis also has its Income/Prepayment Fee Treatment field set to All or Calls Only. This value appears if you set the Corporate Action Type field to Call, but you can change it.
  • Principal Repayment. Indicates the system can apply the NAIC income/prepayment fee treatment to this principal repayment only if the transaction's accounting basis also has its Income/Prepayment Fee Treatment field set to All or Principal Repayments Only. This value appears if you set the Corporate Action Type field to Principal Repayment, but you can change it.
  • None. Indicates that the system cannot apply the NAIC income/prepayment fee treatment to this corporate action.

For corporate action transactions that qualify for the income/prepayment fee treatment, Eagle Accounting calculates these values as follows: 

Local Security Gain/(Loss) = Par Value – Local Amortized Cost

Base Security Gain/(Loss) = (Par Value / Trade Date FX Rate) – Base Amortized Cost

Local Income/Prepayment Fee = Local Proceeds – Par Value

Base Income/Prepayment Fee = Base Proceeds – (Par Value / Trade Date FX Rate)

Local Principal Cash = Par Value

Base Principal Cash = Par Value / Trade Date FX Rate

Local Income Cash = Local Traded Interest + Local Income/Prepayment Fee

Base Income Cash = Base Traded Interest + Base Income/Prepayment Fee

Reporting

Eagle Accounting's core accounting standard report package reflects realized security gain/loss and prepayment fees/acceleration fees/make-whole call provision amounts on calls and principal repayment transactions of fixed income securities in entity bases electing this treatment. Several core accounting reports include the following columns in the report results:

  • INC_REPAY_FEE_LOCAL. Tag 16741. 
  • INC_REPAY_FEE_BASE. Tag 16742. 

Insurance reports also reflect this data. The Prepayment Penalty and Acceleration Fee disclosure displays a count of the number of positions and the aggregate amount of income for securities sold, redeemed or otherwise disposed of, which generate investment income as a result of a prepayment penalty and/or acceleration fee.


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