3 Summary of material accounting policies
This note provides details of the material accounting policies adopted in the preparation of these financial statements. These policies have been consistently applied to all the years presented, unless otherwise stated.
3.1 Income
(i) Interest income
The Company recognises interest income using effective interest rate (EIR) method as per Ind AS 109 'Financial Instruments' on all financial assets subsequently measured under amortised cost or fair value through other comprehensive income (FVOCI). The Company recognises interest income by applying the EIR to the gross carrying amount of financial assets other than credit-impaired assets.
Interest on financial assets subsequently measured at fair value through profit or loss (FVTPL) is presented under interest income on investment.
Interest rebate for the timely payment of interest by borrowers is recognised once the full interest amount is received on time, adhering to the terms of the respective contract, and is netted against the corresponding interest income.
(ii) Revenue from operations other than interest income
The Company recognises revenue from contracts with customers (other than financial assets to which Ind AS 109 'Financial instruments' is applicable) based on a comprehensive assessment model as set out in Ind AS 115 'Revenue from contracts with customers'.
(a) Fees and commission income The Company recognises:
• Service and administration charges at point in time on completion of contracted service;
• Bounce charges at point in time on realisation, from customer at the time of default;
• Fees on value added services and products at point in time on delivery of services and products to the customer;
• Distribution income at point in time on completion of distribution of third-party products and services; and
• Income of loan foreclosure and prepayment at point in time when the event is concluded.
(b) Income on derecognised (assigned) loans
In direct assignment transactions, the Company recognises the excess interest spread (EIS) as the difference between the interest on the assigned loan portfolio and the rate agreed with the assignee. The Company records the discounted value of expected cash flow of the future EIS, entered with the assignee, upfront in the Statement of Profit and Loss with a corresponding receivable in Balance Sheet as 'Interest only strip receivable'. Any subsequent changes in the fair value of future EIS are recognised in the period in which it occurs. The embedded interest component in the future EIS is recognised as interest income in line with Ind AS 109 'Financial instruments'.
(c) Other operating income
Other operating income is recognised on completion of service.
3.2 Expenditures
(i) Finance costs
Borrowing costs on financial liabilities are recognised using the EIR method as per Ind AS 109 'Financial Instruments'.
(ii) Fees and commission expense
Fees and commission expenses which are not directly linked to the sourcing of financial assets, such as commission/incentive incurred on value added services and products distribution, recovery charges, guarantee fees under guarantee scheme and fees for management of portfolio etc., are recognised in the Statement of Profit and Loss on an accrual basis.
(iii) Employee benefit expenses - Share based payments
The Company operates an equity settled share-based payment arrangement for its own employees as well as employees of its subsidiaries. The Company determines the fair value of the employee stock options on the grant date using the Black Scholes model. The cost of the share option is accounted for on a straight line basis over the respective vesting periods of the grant. The cost attributable to the services rendered by the employees of the Company is recognised as employee benefits expenses in profit or loss.
(iv) Other expenses
Expenses are recognised on accrual basis inclusive of goods and services tax for which input credit is not statutorily permitted.
3.3 Financial instruments Recognition of Financial Instruments
All financial instruments are recognised on the date when the Company becomes party to the contractual provisions of the financial instruments. For tradeable securities, the Company recognises the financial instruments on settlement date.
(i) Financial assets
Initial measurement
All financial assets are recognised initially at fair value adjusted for transaction costs and income that are directly attributable to the acquisition of the financial asset except for following:
• Investment in subsidiaries and associates which are recorded at cost as permissible under Ind AS 27 'Separate Financial Statements';
• Financial assets measured at FVTPL wherein transaction cost is charged to Statement of Profit and Loss; and
• Trade receivables that do not contain a significant financing component (as defined in Ind AS 115) which are recorded at transaction price.
Subsequent measurement
For subsequent measurement, financial assets are classified into four categories as per the Company's Board approved policy:
(a) Debt instruments at amortised cost
(b) Debt instruments at FVOCI
(c) Equity/Debt instruments at FVTPL
(d) Equity instruments designated under FVOCI
The classification depends on the SPPI assessment based on contractual terms of the cash flows of the financial assets, and the business model assessment for managing financial assets. In case of equity instruments, it depends on the intention of the Company whether strategic or non-strategic. The said classification methodology is detailed below-
Solely payment of principal and interest (SPPI) assessment
In making this assessment, the Company considers whether the contractual cash flows represents sole payments of principal and interest. Principal for the purpose of this test refers to the fair value of the financial asset at initial recognition and interest represents the time value of money at an agreed contractual rate.
Business model assessment:
The Company has a Board approved policy for determination of the business model. The policy consider whether the objective of the business model, at initial recognition, is to hold the financial asset only to collect its contractual cash flows or, to also sell the financial asset. The Company determines business model that best reflects how it manages groups of financial assets to achieve its business objective. The Company's business model is not assessed on an instrument-by-instrument basis, but at a higher level of aggregated portfolios.
[a) Debt instruments at amortised cost
The Company measures its debt instruments at amortised cost if both the following conditions are met:
• The asset is held within a business model of collecting contractual cash flows; and
• Contractual terms of the asset give rise on specified dates to cash flows that are Solely Payments of Principal and Interest (SPPI) on the principal amount outstanding.
The Company may enter into following transactions without affecting the business model of the Company:
• Considering the economic viability of carrying the delinquent portfolios on the books of the Company, it may enter into immaterial/infrequent transactions to sell these portfolios to third parties.
• Assignment of non credit impaired assets and sale of credit impaired asssets which are infrequent and insignificant and below the threshold provided by the Management.
(b) Debt instruments at FVOCI
The Company subsequently measures its debt instruments as FVOCI, only if both of the following criteria are met:
• The objective of the business model is achieved both by collecting contractual cash flows and selling the financial assets; and
• Contractual terms of the asset give rise on specified dates to cash flows that are Solely Payments of Principal and Interest (SPPI) on the principal amount outstanding.
The Company measures debt instruments included within the FVOCI category at each reporting date at fair value with such changes being recognised in Other Comprehensive Income (OCI).
The Company recognises interest income on these assets in Statement of Profit and Loss. The ECL calculation for debt instruments at FVOCI is explained in subsequent notes in this section.
On derecognition of the asset, the Company reclassifies cumulative gain or loss previously recognised in OCI to profit or loss.
[c) Equity/Debt instruments at FVTPL
The Company operates a trading portfolio as a part of its treasury strategy and classifies its equity and debt instruments which are held for trading under FVTPL category. As a part of its hedging strategy, the Company enters into derivative contracts and classifies such contracts under FVTPL.
Gains and losses on changes in fair value of equity and debt instruments are recognised on net basis through profit or loss.
(d) Equity instruments designated under FVOCI
Investments in equity instruments other than in subsidiaries and associates are measured at fair value.
The Company has strategic investments in equity for which it has elected to present subsequent changes in fair value in other comprehensive income. The classification is made on initial recognition and is irrevocable.
All fair value changes of the aforesaid equity instruments are recognised in OCI. On sale of these investments, the Company transfers the realised gains/losses from OCI to retained earnings.
Derecognition of financial assets
The Company derecognises a financial asset (or, where applicable, a part of a financial asset) when:
• The right to receive cash flows from the asset has expired; or
• The financial assets are written-off; or
• The Company has transferred its right to receive cash flows from the asset or has assumed an obligation to pay the received cash flows in full without material delay to a third party under an assignment arrangement and the Company has transferred substantially all the risks and rewards of the asset. Once the asset is derecognised, the Company does not have any continuing involvement in the same.
The financial assets transferred through the assignment route are derecognised to the extent of transferred portion as the Company neither has any continuing involvement in the same nor does it retain any control. On derecognition of a financial asset, the difference between the carrying amount (measured at the date of derecognition) and the consideration received (including any new asset obtained less any new liability assumed) is recognised in profit or loss.
The Company, based on economic viability of certain portfolios measured at amortised cost, may enter into infrequent and insignificant transactions of assignment and sale of non NPA portfolios within the threshold defined in business model policy which doesn't affect the business model of the Company.
In case of securitisation transactions by way of pass through certificate (PTC), the Company continues to retain the financial assets on the Balance sheet and recognises a collateralised borrowing for the proceeds received.
Write-off
Financial assets are written off when the Company has no reasonable expectation of recovery or expected recovery is not significant basis experience. Where the amount to be written off is greater than the accumulated loss allowance, the difference is recorded as an expense in the period of write off. However, financial assets that are written off could still be subject to enforcement activities under the Company's recovery procedures. Any recoveries made from written off assets are netted off from impairment on financial instrument in Statement of Profit and Loss account.
Impairment of financial assets - General approach
Expected credit losses ('ECL') are recognised for all financial assets except those classified as FVTPL and equity instruments as per the Board approved policy.
The Company follows a staging methodology for ECL computation. Financial assets where no significant increase in credit risk has been observed since inception are classified in 'stage 1' for which a 12 month ECL is recognised. Financial assets which have significant increase in credit risk since inception are considered to be in 'stage 2' and those which are in default or for which there is an objective evidence of impairment are considered to be in 'stage 3'. Life time ECL is recognised for stage 2 and stage 3 financial assets.
Stage 1 (12-month ECL) is provided basis the default events that are likely to occur in the next 12 months from the reporting date. Stage 2 and stage 3 (lifetime ECL) is provided for basis all possible default events likely to occur during the life of the financial instrument.
Financial assets are written off in full, when there is no realistic prospect of recovery. The Company may apply enforcement activities to certain qualifying financial assets written off.
Treatment of the different stages of financial assets and the methodology of determination of ECL
[a) Credit impaired (stage 3)
The Company classifies a financial asset as credit impaired (stage 3) when one or more events indicate impairment in the recoverability of future cash flows. The assessment is based on relevant objective evidence, including the following:
• Contractual payments of principal and/or interest are overdue for more than 90 days.
• Where any loan account of a customer is stage 3, all other loan accounts of the same customer are classified as Stage 3 and remain so until overdues across all accounts are fully cleared.
• Where any loan account of a customer has been written off or settled under a one time compromise settlement, all other active loan accounts of such customer are classified as Stage 3 for 12 months from the date of such event. Thereafter, such accounts are upgraded to stage 1 only upon clearance of all arrears of principal and interest.
• Restructured loans, involving modification of contractual terms due to financial distress of the borrower, are classified as Stage 3. Restructuring does not result in derecognition of the financial asset. Such loans are upgraded to Stage 1 only if:
- The restructured loan is not in default until repayment of at least 10% of the principal outstanding or completion of 12 months, whichever is later; and
- No other loan account of the same customer is in default during this period.
• Loan accounts where a one time compromise settlement is offered or where recovery is pursued through repossession of security involving waiver of interest and/or principal are classified as Stage 3.
• Loan is otherwise considered to be in default based on the Company's internal credit risk assessment or other objective evidence indicating unlikelihood of timely repayment.
(b) Significant increase in credit risk [stage 2)
The Company considers loan accounts which are overdue for more than 1 day but up to 90 days as on the reporting date as an indication of significant increase in credit risk. Additionally, for mortgage loans, the Company recognises stage 2 based on other indicators such as frequent delays in payments beyond due dates.
The measurement of risk of defaults under stage 2 is computed on homogenous portfolios, generally by nature of loans, tenors, location (urban/rural) and borrower profiles. The default risk is assessed using PD (probability of default) derived from past behavioural trends of default across the identified homogenous
portfolios. These past trends factor in the customer behavioural trends. The assessed PDs are then aligned considering future economic conditions that are determined to have a bearing on ECL.
[c) Without significant increase in credit risk since initial recognition (stage 1)
ECL resulting from default events that are possible in the next 12 months are recognised for financial assets in stage 1. The Company has ascertained default possibilities on past behavioural trends witnessed for each homogenous portfolio using behavioural analysis and other performance indicators, determined statistically.
(d) Measurement of ECL
The Company calculates ECL based on discounted present value of probability weighted scenarios to measure the expected cash shortfall. Cash shortfall is the difference between the cash flows that are due to the Company in accordance with the contract and the cash flows that the Company expects to receive.
It incorporates all information that is relevant including past events, current conditions and current profile of customers. Additionally, forecasts of future macro situations and economic conditions are considered as part of forward economic guidance (FEG) model. Forward looking economic scenarios determined with reference to external forecasts of economic parameters that have demonstrated a high correlation to the performance of our portfolios over a period of time have been applied to determine impact of macro-economic factors. In addition, the estimation of ECL takes into account the time value of money.
The Company has calculated ECL using three main components: a probability of default (PD), a loss given default (LGD) and the exposure at default (EAD). ECL is calculated by multiplying the PD, LGD and EAD and adjusted for time value of money using a rate which is a reasonable approximation of EIR.
• Determination of PD is covered above for each stages of ECL.
• EAD represents the expected balance at default, taking into account the repayment of principal and interest from the Balance Sheet date to the date of default together with any expected drawdowns of committed facilities.
• LGD represents expected losses on the EAD in the event of default, taking into account, among other attributes, the mitigating effect of collateral value at the time it is expected to be realised and the time value of money.
The Company recalibrates above components of its ECL model on a annual basis by using the available incremental and recent information, except where this information does not represent the future outcome. Further, the Company assesses changes to its statistical techniques for a granular estimation of ECL.
A more detailed description of the methodology used for ECL is covered in the 'credit risk' section of note no. 49.
(ii) Financial liabilities Initial measurement
The Company recognises all financial liabilities initially at fair value adjusted for transaction costs that are directly attributable to the issue of financial liabilities except in the case of financial liabilities recorded at FVTPL where the transaction costs are charged to profit or loss. Generally, the transaction price is treated as fair value unless there are circumstances which prove to the contrary in which case, the difference, if material, is charged to profit or loss.
Subsequent measurement
The Company subsequently measures all financial liabilities at amortised cost using the EIR method, except for derivative contracts which are measured at FVTPL and accounted for by applying the hedge accounting requirements under Ind AS 109.
Derecognition
The Company derecognises a financial liability when the obligation under the liability is discharged, cancelled or expired through repayments or waivers.
3.4 Investment in subsidiaries and associates
The Company recognises investments in subsidiaries and associates at cost and are not adjusted to fair value at the end of each reporting period as allowed by Ind AS 27 'Separate financial statements'.
3.5 Taxes
Income tax comprises current tax and deferred tax. It is recognised in the Statement of Profit and Loss except to the extent that it relates to items recognised in other comprehensive income or directly in equity, in which case the tax is recognised in the same statement as the related item appears.
Current tax is recognised based on tax rates and tax laws enacted, or substantively enacted, at the reporting date and on any adjustment to tax payable in respect of previous years.
Deferred tax is recognised for temporary differences between the accounting base of assets and liabilities in the Balance sheet, and their tax bases. Deferred tax is calculated using the tax rates expected to apply in the periods in which the assets will be realised or the liabilities settled.
The carrying amount of deferred tax assets is reviewed at each reporting date by the Company and reduced to the extent that it is no longer probable that sufficient taxable profit will be available to allow all or part of the deferred tax asset to be utilised.
Deferred tax assets and deferred tax liabilities are offset basis the criteria given under Ind AS 12 Income Taxes.
3.6 Property, plant and equipment and depreciation thereof
The Company measures property, plant and equipment initially at cost and subsequently at cost less accumulated depreciation and impairment losses, if any.
The Company provides for depreciation on a pro-rata basis, with reference to the month in which such asset is added or sold, for all tangible assets on straight line method over the useful life of assets assuming no residual value at the end of useful life of the asset. Details of useful life is given in note no.13.
An item of property, plant and equipment and any significant part initially recognised is derecognised upon disposal or when no future economic benefits are expected from its use or disposal. Any gain or loss arising on derecognition of an item of PPE is determined as the difference between the net disposal proceeds and the carrying amount of the asset and is recognised in the Statement of Profit and Loss.
3.7 Intangible assets and amortisation thereof
The Company measures Intangible assets, representing softwares, licenses etc. initially at cost and subsequently at cost less accumulated amortisation and accumulated impairment, if any.
The Company recognises internally generated intangible assets when the Company is certain that intangible asset would support/result in furtherance of Company's existing and/or new business and cost of such intangible asset identifiable and reliably measurable. The cost of an internally generated intangible asset comprises of all directly attributable costs necessary to create, produce, and prepare the asset to be capable of operating in the manner intended by the Company.
All the intangible assets including those internally generated are amortised using the straight line method over a period of five years, which is the Management's estimate of its useful life.
An intangible asset is derecognised on disposal, or when no future economic benefits are expected from use or disposal. Gains or losses arising from derecognition of an intangible asset, measured as the difference between the net disposal proceeds and the carrying amount of the asset are recognised in the Statement of Profit and Loss when the asset is derecognised.
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