United States: Interest Rate Swaps

Last Updated: December 12 2016
Article by Kevin O’Brien

Interest rates are relatively low now, but the Federal Reserve Bank and others are predicting that interest rates may be on the rise soon. Many of our bank clients are wondering what can be done to smooth out volatility and manage interest expense in the future. Although there are several techniques that can be employed to manage interest rate risk, there are an increasing number of banks that are contemplating entering into interest rate swaps to manage interest expense on their borrowings.

Among other uses, an interest rate swap can be used to reduce an entity's exposure to variability in interest-related cash outflows on borrowings, such as issuances and quarterly rollovers of short-term borrowings or variable rate debt. Swaps can potentially provide an economical way to convert variable rate debt into fixed rate debt. Sounds simple, but it is complex, as all derivative accounting seems to be. An interest rate swap is just one type of hedge that follows the guidance in Accounting Standards Codification 815 – Derivatives and Hedging (ASC 815).

An interest rate swap is a derivative financial instrument which must be accounted for at fair value. Assuming the criteria are met, designation of a swap as a cash flow hedge allows a bank to effectively record interest expense on its income statement at a fixed interest rate, while recording the fluctuations in fair value of the swap for the effective portion of the hedge in accumulated comprehensive income. Ineffectiveness of the swap, if any, is recorded in earnings on a current basis.

ASC 815 provides comprehensive guidance on derivative and hedging transactions, defines a derivative instrument and specifies how to account for such instruments. In addition, ASC 815 establishes when reporting entities, in certain limited well-defined circumstances, may apply hedge accounting to a relationship involving a designated hedging instrument and hedged exposure.

The full text of ASC 815 can be found in the FASB Accounting Standards Codification and should be read before any derivative is considered.

Per ASC 815-20 Hedging-General, in order to qualify for hedge accounting, the hedging relationship (both at inception of the hedge and on an ongoing basis) shall be expected to be highly effective in achieving offsetting cash flows attributable to the hedged risk during the term of the hedge for a cash flow hedge (ASC 815-20-25-75).

In order for an entity to apply hedge accounting, the entity must, at inception, formally designate and document the objective and the strategy for the hedge; such documentation must include (per ASC 815-20-25-3b 2):

  • The hedged instrument – the derivative, in this case interest rate swap;
  • The hedged item or transaction – the asset, liability or transaction being hedged;
  • The nature of the risk being hedged – interest rate risk; and
  • The method that will be used to retrospectively and prospectively measure the hedge's effectiveness, including the frequency of the measurement, which must be no less than quarterly.

Failure to document the above criteria at inception would preclude a bank from using hedge accounting.

There are many reasons why a hedging instrument might have some ineffectiveness, for example:

  • A difference in the basis of the hedging instrument and the hedged item such as a derivative instrument based on LIBOR and a hedged item based on the prime rate;
  • Differences in critical terms of the hedging instrument and the hedged item such as the term, principal and notional amounts, and pay or receive dates;
  • The hedged item is no longer outstanding, or no longer probable of occurring, such as in cases of quarterly rollovers of short term FHLB borrowings.

If your bank is contemplating the use of an interest rate swap, management should consider the following steps:

  • Review your derivatives policy and update as necessary.
  • Discuss your plans with your ALCO consultant.
  • Perform due diligence on your proposed swap counterparty.
  • Engage the services of a third party to assist you in determining the appropriateness of your planned hedge, completing the required documentation and performing an assessment of the effectiveness of the proposed hedge.
  • Educate your board on the risks of the transaction and potential balance sheet impact. Depending on the movement of interest rates, it is not unusual for a swap to give rise to an accumulated other comprehensive loss, which will need to be reflected as a component of equity.
  • Consult with your BNN service team to ensure that you have appropriate documentation of your planned hedge, that your proposed hedge will meet the accounting criteria for hedge accounting and that you properly understand the accounting implications.

If management decides to move forward and enter into an interest rate swap, measures should be put in place to: assess the ongoing creditworthiness of the counterparty to ensure there is no impairment to be recognized; obtain quarterly fair values of the derivative and to review the assessment of the third party prepared effectiveness test.

In summary, an interest rate swap can be an important component of interest rate management; however the accounting requirements can be complex.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.