GB-Sheffield: IFRS9 ECL & Claims Model Framework

At short notice in March 2020, British Business Bank and, in particular, British Business Financial Services Limited ("BBFSL") was designated by the Secretary of State for the Department of Business, Energy and Industrial Strategy ("SoS") and HM Treasury as the body responsible for administering various business interruption loan schemes in order to respond to the impact of the COVID-19 pandemic. Those schemes include the Coronavirus Business Interruption Loan Scheme ("CBILS"), the Coronavirus Large Business Interruption Loan Scheme ("CLBILS"), and the Bounce Back Loan Scheme ("BBLS").

Shortly after the launch of these schemes, the SoS and HM Treasury required certain information and financial forecasts in respect of the various schemes. This required BBFSL, acting on behalf of the SoS and HM Treasury, to procure at extremely short notice a supplier capable of developing and operating a model required to calculate:

•expected credit losses for IFRS9 purposes;

•fair values for IFRS9 and IFRS 13 purposes; and

•expected future claim amounts over the remaining life of each of the schemes.

There was not enough time to carry out a competitive procurement in accordance with the Public Contracts Regulations 2015, but BBB concluded that regulation 32(2)(c) permitted it to negotiate directly with potential suppliers without first publishing a contract notice.

A short list of potential suppliers was drawn up and BBFSL issued a Statement of Requirements as part of a competitive procurement process on 11 August 2020. Following the evaluation of proposals, 4most was awarded a Framework agreement for the purposes of designing, building, testing and operating an IFRS9 solution and claims model.

Under the Framework, BBFSL has the ability to Call - off contracts relating to (a) the design, build and testing of models relating to loan schemes, and (b) the operation of those models.

Additional information: BBFSL was required to provide uninterrupted financial support to businesses impacted by restrictions in response to the management of the COVID-19 pandemic. In order to provide that support, BBFSL needed to be able to measure the credit risk of borrowers and needed to be able to comply with certain financial reporting obligations. Therefore, there was an extremely urgent requirement to procure a supplier capable of designing, building and operating a model capable of calculating (a) ECLs in line with IFRS 9 and IFRS 13 requirements, (b) fair values for IFRS9 and IFRS 13 purposes, and (c) expected future claim amounts under loan schemes administered on behalf of the SoS and HM Treasury.

Regulation 32(2)(c) of the Public Contracts Regulations 2015 applied for the following reasons:

•BBB was reacting to a current situation that was a genuine emergency.

•The need for extreme urgency has been caused by unforeseeable events. The COVID-19 situation is so novel that the impact of measures to curb the spread of and the increase in the number infections could not have been predicted.

•Having regard to the time it would have taken to prepare for and carry out a procurement in compliance with the Public Contracts Regulations 2015, it was impossible to comply with the usual timescales without jeopardising the roll out of the schemes. •BBB acted promptly in responding to a current situation of extreme urgency and proceeded to make the direct award without delay.