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Bank Reserve: Accounting
Bank Reserve: Accounting
BANK RESERVE
ACCOUNTING DBS Group Holdings Ltd
1.
BANK RESERVE Wit
inve
ACCOUNTING ban
met
assi
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CONTENTS pro
1. Introduction
2.
TO
2. Key Ratios Relating
to Provisions and PE
Non-performing Loans - The CA
Capital Adequacy Ratio Ban
requ
The
3. Credit term
Sing
4. Bad or Doubtful Debts ade
ratio
ade
5. Accounting Treatment for from
Bad or Doubtful Debts
invo
and
6. Principles of Loan Grading
diff
thu
diff
requ
cap
acco
prov
ban
dec
cap
loss
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4. BAD AND DOUBTFUL DEBTS advent of sophisticated loan grading and credit risk TA
management techniques, it has become feasible for banks to
A loan is bad or doubtful when the borrower cannot repay. derive a provision on a formula basis by applying pre- G
The incidence of bad and doubtful loans is a particularly determined factors to all the loans within a portfolio, based, TO
sensitive aspect of a bank’s operations. If the losses are among other things, on historical default experience and S
material they can reduce the capital resources of the bank problem loan resolution rates.
and affect its ability to grow and develop its business. If large
losses are disclosed in the financial statements, it may lead to DBS’ practice, in common with a number of global
a loss of confidence in the bank’s management and a banks, is to record provisions in its overseas subsidiaries
reduction in its credit ratings. This will result in an increase in based on local regulatory requirements for local reporting
the bank’s cost of borrowing and make it more expensive to purposes, and then, if necessary, for the DBSH financial
raise capital. As such, provisions for bad and doubtful debts statements to top-up any potential shortfalls when
at DBS are one of the most important and complicated of all DBS’ own internationally acceptable internal standards
its accounting policies. are applied to its overseas portfolio. As such, the DBSH
Group consolidated financial statements reflect
Most banks make both specific and general provisions
provisioning based on DBS standards. Local subsidiary
against bad and doubtful loans. These provisions have
accounts reflect only those provisions that are necessary to
traditionally been computed separately, but are really S
comply with local regulatory requirements. Historically,
elements of the same overall considerations. The overall
this means that provisions in the DBSH financial
provision should represent the aggregate amount by which
statements are higher as DBS’ standards are more stringent
management considers it necessary to write down its loan
than the standards applied in other Asian jurisdictions in
portfolio in order to state it in the balance sheet at its
which it operates.
estimated ultimate net realisable value. This value should
thus represent the total amount that the bank expects to At DBS, the charge made to the profit and loss account D
recover over time in the normal course of repayment or to write off bad loans or create new specific provisions in the
recovery. year takes into account the specific and general provisions
that were held at the beginning of the year. The charge
Moreover, the overall provision can be determined using
against profits thus represents those specific provisions and
different approaches. Under the traditional approach, which
write offs in the year that are not already covered by the
DBS adopts, management takes the view that the specific
opening balance of provisions together with such amount as
element relates to particular loans that have been identified
is needed to restore the general element of the provisions to Lo
as bad or doubtful, writing them down to estimated net
the level judged necessary at each succeeding year-end by
realisable value at the balance sheet date. The general
management.
element relates primarily to loans that have not been
separately identified as bad or doubtful, but are known from
experience to be present in any loan portfolio. The general
element may also reflect identified loans about which the 4.1 Specific element of the provision
bank has some concern, but for which it is not clear from the
In determining the extent of the specific element of the
evidence available that a specific provision is needed, or for
provisions, management considers the amount of the loan prov
which it is not possible in the circumstances to determine a and its other commitments to the borrower, the payment whe
reasonable estimate of the extent of any specific amounts to history of the borrower, the borrower’s business prospects,
Dou
be provided. A bank’s ability to develop a flexible general the security of the loan [how easily it could be realised and
imp
element is important in a deteriorating situation, such as the for how much] and the costs to obtain repayment.
disc
recent Asian Crisis, where management knows there are
Any security that the bank holds for a loan is of of f
problems within its portfolio but cannot necessarily identify
considerable importance in determining the extent of a
them with great specificity. In such circumstances, a bank’s
provision, since it may significantly mitigate or eliminate any
general provisions will rise faster than the specific element, 6 of
potential loss that might otherwise be foreseen.
which will catch up once the problem loans have presented
themselves and been identified customer by customer. At DBS, a loan will qualify for a specific provision upon
valu
An alternative approach blurs the distinction between classification upon which a percentage of the difference
Man
the specific and general elements of the provision and this is between loan principal and its related security value [the
grad
favored by a number of North American banks. With the unsecured portion] will be provided. The actual percentage
D B S G R O U P H O L D I N G S LT D
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risk TABLE 1
ks to
pre- GRADE ASSIGNED CRITERIA PROVISION LEVEL EXAMPLES OF COLLATERAL
TO LOAN VALUATION
sed,
and Substandard • Fully secured or For Substandard cases which • For properties, a discount is
• Expected loss is less are fully secured. applied to the valuation to
than 50% of the • No provision is required for arrive at forced sale value.
unsecured amount. the principal amount.
obal • For shares/deposits, which
• Interest provision is 100%. are marked to market, no
aries
discount is applied.
For Substandard cases
ting • For debentures, discount
with security shortfall.
ncial factors generally range
• Principal provision is 10% from 1/3 to 2/3 of book
hen to <50% of unsecured
value of assets.
amount.
ards
• Interest provision is 100%
BSH
lect In addition, a general provision
is made on the outstanding
iary principal.
y to
ally, Substandard/Loss • Primary source of repayment • 100% of unsecured principal
is collateral which is amount.
ncial inadequate to fully cover • Interest provision is 100%
gent the loan.
In addition, a general provision
s in is made on the outstanding
principal.
the
oan provided will depend on management’s judgement and • Payment of the principal and/or interest
ment whether the loan is graded Substandard, Substandard/Loss, is 90 days or more in arrears.
ects,
Doubtful or Loss. The quantum of the provision is directly
and • Debt rescheduling/restructuring takes place
impacted by the security value and this in turn, may be
due to cashflow problems.
discounted in certain circumstances to recognise the impact
• Borrower is unable to repay the loan from
of of forced sale or quick liquidation.
normal sources of income.
of a
Issues in respect of loan grading are explored in Section
any
6 of this Primer.
Generally, the provision levels and basis of collateral 4.2 General element of the provision
pon
valuation for the main classified grades at DBS are at Table 1. A bank with a large portfolio of loans will always find it
nce
Management rarely overrides these guidelines. A loan is difficult to identify all the bad and doubtful loans that exist
[the
graded substandard or worse when: at a balance sheet date and to estimate the extent of the
tage
3 D B S G R O U P H O L D I N G S LT D
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losses that they will produce. The information about its may, due to foreign exchange shortages or restrictions, be
borrowers may not be completely up to date and there will unable to meet their obligations to the lending bank. The
always be factors relevant to the identification and assessment of this risk involves a range of economic,
evaluation of bad and doubtful loans of which the bank has political, social and other factors that are often difficult to
not yet become aware such as deterioration in the value of isolate, analyse or predict. Political instability, strikes,
fixed assets or other factors of production. changes in monetary policy and climatic conditions are all •
It will not always be possible or practicable where there factors that may be relevant.
are many small loans, to determine with certainty whether or
In assessing country risk, DBS considers whether the
when a loan has become bad or what level of specific
political instability of a country or the management of •
provision would be “correct”.
its economy is such that companies in the private sector
The general element of the provision is made to cover
might fail, despite their apparent strength. In addition,
losses which, although not specifically identified, are known
circumstances may exist where certain governments might
from experience to exist in any loan portfolio as well as the prov
prevent companies in their country from honoring their
circumstances described above. The general provision covers disp
instances where impairment has occurred by the balance obligations.
trad
sheet date and not future losses arising from future events. DBS currently holds country provisions against Indonesia, cou
In determining an appropriate level of general provision, Malaysia, Thailand, South Korea and The Philippines. sett
management considers the following:
D B S G R O U P H O L D I N G S LT D
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, be currency balances that are sufficient to meet the becomes doubtful. Some banks may use the fact that interest
The country’s external debt obligations as they fall due. is overdue by some given period as a starting point for
mic, This requires an assessment not only of the quality of identifying when this happens, although this should not lead
t to its economic management, but also of the economy automatically to interest being considered doubtful. In the
kes, itself and the actual or potential strains upon it; United States, banks are required to suspend interest when
e all • Whether, through taxation or borrowing, that repayments of principal or interest become overdue by more
government can obtain from domestic or international than 90 days.
the sources the funds it needs to settle its obligations; and
The use of the suspense method of accounting for unpaid
t of • Whether that government will in fact use the available interest reduces the levels of provisioning that would otherwise
ctor funds to meet its obligations when they fall due. be made. To avoid distorting comparisons, many banks disclose
ion,
There is a secondary market in problem country debt that the amount held in suspense and movements to and from
ight
provides a further basis for provisions if there is an intention to suspense. When there is no longer any realistic prospect of
heir
dispose of the debt. The liquidity and volatility of instruments recovering the unpaid interest, the balance in suspense should
traded in this market, and the degree of likelihood that it be written off in the same way as the provision.
esia, could in fact be used, must be taken into account when Where cash is received from borrowers with non-
setting provisions. performing loans, payments are applied to cover
uncollected interest before reducing overdue principal
DBS does not hold any separate Sovereign Risk provisions.
amounts.
All such risks are assessed in the overall consideration of
Specific, General and Country Risks. As noted above, U.S. banks typically stop accruing
interest when loans are overdue by 90 days or more, or
when recovery is doubtful. DBS continues to charge
ning interest to a doubtful customer’s account for collection
and 5. ACCOUNTING TREATMENT OF purposes, the interest being recognised as income with full
able provisioning. This addition of interest continues until such
BAD AND DOUBTFUL DEBTS time as its recovery is considered to be unlikely. Whilst this
The book entries associated with provisions for bad and practice does not affect net income, in comparison with
sing U.S. practice, it has the effect of increasing the reported
doubtful loans are relatively simple and do not require any
and level of non-performing loans and provisions.
explanation. However, some of the underlying principles
ncial
require consideration.
tary
on
5.2 Write-offs
ons,
have 5.1 Loan interest It is a matter of judgement when a bad loan should be
ance written out of the accounting records completely. In
A bank is normally entitled to receive income on a loan until it is
nks. principle, an irrecoverable loan, or portion of a loan, should
repaid or, if the borrower becomes insolvent and no assets
ents be written off when there is no realistic prospect of
remain. The fact that a bank has classified a loan as doubtful does
hold recovery and the bank’s normal relationship with the
not remove its entitlement to income; it merely casts doubt on borrower has ceased to exist. The decision on timing is
have whether the bank will be able to collect it. In these circumstances, important because, when the loan is written off, the
the bank should continue to charge the customer’s account with absolute level of provisions disclosed in the financial
interest, the matching entries having in the past either been to statements falls. It is important, therefore, that the banks
credit the profit and loss account and raise provisions as implement write offs on a systematic and consistent basis.
appropriate, or to credit the interest to a suspense account, which
DBS may write off problem loans more slowly than is
to is then netted against the balance due from the customer in the
the practice in other jurisdictions including the U.S. As a
sing balance sheet. DBS uses a combination of the two methods result, DBS may report a somewhat higher level of loans
the depending on circumstances. However, the latter approach, than if it had followed such U.S. practice and also a higher
which is known as the suspense method, is less prominent at DBS. level of non-performing and classified loans. Net income,
s It is a matter of judgement when the collectibility of interest however, is unaffected.
5 D B S G R O U P H O L D I N G S LT D
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5.3 Recoveries estimating the future cash flows, including interest, and
TA
discounting these at the interest rate implicit in the loan. If
Recoveries are the amounts that a bank receives from loans
the net present value is less than book value, then a
that it has previously written off. A common practice is to
provision is required. This approach automatically
credit such amounts to the profit and loss account as a
recognises funding costs by building in the time value of Pr
reduction in the aggregate charge for bad and doubtful no
money.
loans. If significant recoveries occur frequently, this may
indicate that the bank’s policy for writing off loans is too
Co
conservative and needs to be reconsidered. no
5.6 Asymmetrical Provisioning - Effect
of Operating in Different Jurisdictions
5.4 Provisions for predicted loan losses With the acquisition of subsidiaries in 1997, 1998 and
Co
to
There can be a timing difference between the reporting of 1999, DBS has had to consider its basis of loan re
income from assets and the provisions that have classification and provisioning methodology in jurisdictions
subsequently to be raised when the same assets are outside Singapore. It is quite common for global banks to
impaired. Provisioning usually coincides with the interruption adopt different non-performing loan classifications and Re
in the revenue stream when the asset moves from provisioning policies to fit each of the various jurisdictions
performing to non-performing. Therefore, there is a double in which they operate, yet to ensure that head office and
reduction in profits. In contrast, when the business cycle holding company consolidated financial reporting practices
improves with new loans being added to the books and non- follow a consistent set of guidelines.
Cl
performing loans become performing there is a double no
DBS’ practice, in common with a number of global
boost to income with both an increased interest margin and banks, is to record provisions for its overseas subsidiaries
the release of provisions. based on local regulatory requirements, and then, if
Some regulators have suggested that fluctuations in the necessary, to top-up any potential shortfalls when DBS’
profit cycle could be addressed by setting aside a provision own (internationally acceptable) internal standards are
against the “expected loss” at the time a loan is made or by applied to its overseas portfolio. As such, the DBSH Group
deferring the recognition of part of the income from new consolidated financial statements reflect provisioning
are
lending. This concept has not been universally accepted by based on DBS standards. Local subsidiary accounts reflect
gran
bankers or accountants and is not currently practised at only those provisions that are necessary to comply with
DBS. - “
local regulatory requirements.
“Su
It is therefore possible that a loan may have a provision DBS
of 50% in the subsidiary books in order to meet local dev
5.5 Funding costs of regulatory requirements but will be provided at 100% in whi
doubtful loans the DBSH consolidated accounts if so required by DBS’ own inclu
Where the collectibility of part of a loan is identified as standards.
doubtful the bank will not only incur a loss due to the Subtle differences in loan classification and provisioning able
need to provide against, and possibly ultimately write off, are noted by DBS in operating its overseas subsidiaries. A n
part of the loan principal. If, as is likely, the borrower also Table 2 sets out some examples in jurisdictions in which Men
fails to pay the full amount of interest, the bank will be DBS has a presence. perf
receiving a reduced amount of income while still paying the Non
full cost of the deposits or other resources which are used
to fund the loan.
funding costs of doubtful loans. This situation can be Many banks have introduced loan-grading systems to
contrasted with that in the U.S. where accounting standards classify their exposures into a number of different
now require banks to consider the net present value of a categories. Letters, numbers or words may represent the
loan, subject to the availability of any security, when categories but in essence the characteristics are the same.
assessing the amount of any bad debt provisions, called DBS currently uses the categories found in MAS Notice 612
allowances for loan losses. This is usually achieved by for grading its loans.
D B S G R O U P H O L D I N G S LT D
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and
TABLE 2
n. If
n a
SINGAPORE THAILAND HONG KONG
cally
e of Provisions against Required provisions Not all estimated provisions Required provisions are fully
non-performing loans are fully made. required to be booked against made.
NPLs until 31 December 2000.
Classification of • Uses qualitative and • Largely determined using • Largely quantitative criteria;
non-performing loans quantitative characteristics. timeband; some qualitative some qualitative elements
obal elements taken into account. taken into account.
• Borrower basis
aries • Account basis • Borrower basis
, if
DBS’
are
oup
MAS Notice 612 dictates that all Singapore banks For classified loans, i.e. those graded “Substandard”,
ning
are required to conduct systematic review of all credit facilities “Substandard/Loss,” “Doubtful” or “Loss”, DBS is required
flect
granted, and to classify the loans according to five categories1 to provide for deterioration in credit quality after taking into
with
- “ P a s s e d ” , “ S p e c i a l M e n t i o n ” , “ S u b s t a n d a rd ” , consideration the realisable value of the collateral. Classified
“Substandard/Loss,” “Doubtful” and “Loss”. Over the years, loans are also disclosed as non-performing loans in the DBSH
sion DBS has built on the principles of MAS Notice 612 and financial statements.
ocal developed its own set of internal loan classification guidelines, In computing the level of specific provision for non-
% in which are consistently adopted across the entire Group, performing loans, collateral values are discounted2.
own including overseas branches and subsidiaries.
Essentially, a loan is a not classified loan if the borrower is
ning able to service its obligations from normal sources of income. 6.1 Qualitative Grading
ries. A non-classified loan is graded as “Passed” or “Special
As described in MAS Notice 612, the loan grading process
hich Mention”, and a bank is not required to disclose as non-
involves both quantitative and, perhaps unusually qualitative
performing or make any specific provisions against such loans.
considerations. The latter is not a practice that is common
Non-classified loans are also known as performing loans.
amongst Asian banks and requires a degree of management
G 1 (a) Passed - to indicate loans with good credit quality; (f) Loss - to indicate outstanding debt regarded as uncollectible.
(b) Special mention - to indicate evidence of potential weakness
to in the borrowers’ credit worthiness; 2 MAS requires collateral values to be discounted to realisable value.
rent (c) Substandard - to indicate that normal repayment may be in DBS internally adopts the following guidelines:
jeopardy by reason of an adverse trend of severe financial (a) For properties, a discount is applied to the valuation to
the weakness; arrive at forced sale value.
me. (d) Substandard / Loss - to indicate classified loans where there is (b) For shares/deposits, which are marked to market, no discount
insufficient collateral and the unsecured or loss portion needs is applied.
612
to be fully provided;
(c) For debentures, discount factors generally range from 1/3 to
(e) Doubtful - to indicate that full liquidation of outstanding debt 2/3 of book value of assets.
appears questionable and the account suggests that there will
be a loss, the exact amount of which cannot be determined as
yet; and
7 D B S G R O U P H O L D I N G S LT D
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judgement. As such, grading levels may be influenced by the may report a somewhat higher level of non-performing TA
culture of the bank’s management who are making the loans than if it had followed other countries’ practices.
qualitative judgement. In general, the practice of introducing
qualitative judgement into the grading process has the effect
In
of increasing both non-performing loan and provision levels 6.3 Disclosure of MAS Notice 612
in comparison with banks which do not practise this. Sin
Classified Loans as Non-Performing No
An example of a qualitative judgement is to classify a Loans in the DBSH Financial Statements N
loan on which payments are on schedule as substandard by R
virtue of the fact that the customer has negative net worth The current public financial disclosure on non-performing
together with cash losses at the date of his last financial loans for Singapore banks specifies the reporting of all
Re
statements. classified loans as defined by MAS Notice 612. The inherent No
assumption is that all classified loans are considered “non-
An example of a quantitative guideline is one where a N
performing”. This may not necessarily always be the case.
R
loan has not been serviced for three months or more being
automatically classified as substandard (or worse). For example, DBS grades certain performing loans as
“Substandard” (or worse) for situations which warrant closer Ot
No
monitoring by risk managers, for example, credit facilities
with technical breach of a loan covenant, or where N
6.2 Treatment of Restructured R
borrowers are in a negative net worth position. Whilst these
or Rescheduled Loans loans are classified under MAS Notice 612, and, as such, are
At DBS, a case will be classified as substandard (or worse) if disclosed as non-performing in the financial statements, they
there is a need to reschedule or restructure loan repayments may not necessarily be considered non-performing under Lo
due to the borrowers’ inability to generate sufficient cash other authoritative reporting criteria. As at 31 December wh
income to service the loan in accordance with its original 1999, for example, S$1.35 billion of DBS Group’s S$8.1 cla
re
terms. billion of loans, which were disclosed as non-performing,
were technically performing cases. To
Upon restructuring, DBS will take an immediate write-off
for any haircut (discount) given to the borrower on principal To address this disclosure issue, as from 31 December NB
repayment. This is accordance with accepted banking 1999, DBS has included the following analyses of its loan
practice. It is the bank’s policy, that most restructurings are portfolio:
carried out at interest rates which are on commercially the
• An analysis of the loan portfolio setting forth classified
same terms or better than the original borrowings. In cases
and non-classified loans under MAS Notice 612 criteria
where the new terms are below funding or at reduced rates,
set forth on page 102 of the Annual Report; and
the bank will take the related losses over the remaining
• An analysis of the loan portfolio setting forth performing
period of the loans. Whilst this is a common practice in Asia, 6.4
it is not so in the U.S. and non-performing loans using US Securities and
Exchange Commission (“SEC”) requirements3 applicable
su
For declassification purposes, a loan can be upgraded to to bank holding companies which is set forth in Table 3. DBS
performing only after the borrower has met the revised will
repayment schedule for a year. Whilst this period is DBS believes that these additional disclosures will ensure with
considered to be prudent by DBS management, it is a far not only comparability amongst the Singapore banks but boo
longer period than is applied by a number of other banks in also allow for greater understanding of DBS’ non-performing disc
Asia (or the U.S.). In a number of jurisdictions loans can be loan position by its shareholders and other international acco
declassified as at the date of restructuring. As a result, DBSH constituents. abo
3 Under the SEC requirements, “non-performing loans” are defined (b) Accrual Loans which are contractually past due 90 days or con
as those in the following categories: more as to principal or interest repayment and;
(a) Non accrual loans; (c) Troubled debt restructuring.
requ
the
will
D B S G R O U P H O L D I N G S LT D
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Singapore
Non accrual loans 1,858.8 1,788.8
6.5 Loan Security
ts Non-Restructured 1,471.1 1,515.7
Restructured 387.7 273.1 A bank may lend with or without security.
ming
f all When it takes security, the bank does not usually do so
Regional Countries
rent with the expectation or intention of obtaining repayment of
Non accrual loans 4,172.9 4,086.9
non- the loan by realising that security. It takes security as a
Non-Restructured 3,665.7 4,056.8
e. means of reducing the risk that a loan will not be recovered
Restructured 507.2 30.1
in full, if the borrower defaults. Some of the types of assets
s as
Other Countries typically used as security are (a) land and buildings; (b)
oser
Non accrual loans 769.7 267.2 trading assets of a business; (c) stocks and shares; (d) ships
ities
Non-Restructured 695.4 265.8 and other specialised assets; and (e) deposits and
here
Restructured 74.3 1.4 placements. In assessing the value of security, banks often
hese
apply percentage discounts to such assets. Discounts might
are 6,801.4 6,142.9
vary from 20% (for example in the case of Singapore
they
Loans not included above
properties) to more than 50% (for fixed and floating
nder
which are accruing, but charges over assets of a business). In essence, the discount
mber
classified troubled debt applied varies with the type and quality of the security.
$8.1
restructuring 7.3 -
ing, Land and buildings, commercial and residential, form a
Total 6,808.7 6,142.9 significant portion of loan security at DBS today. Historically,
residential property security has carried a relatively low
mber NB. There are no non-accruing loans which are contractually past due
90 days or more with regard to principal or interest payments. degree of risk for a bank, provided that the property is
oan
These loans are classified as NPLs under MAS guidelines for which adequately covered by insurance and the bank has not lent
the practice is not to recognise interest income until received.
too high a percentage of the property’s value. DBS generally
fied lends up to 80% of security valuation on mortgage facilities
teria at inception.
9 D B S G R O U P H O L D I N G S LT D