Professional Documents
Culture Documents
1
CA Nitin S Bangad
Partner
S M Bangad & Co
Chartered Accountants
Aurangabad & Mumbai
Agenda
Discussion on Master Circular (MC) issued by RBI on
IRAC Norms covering
a) Asset Classification
b) Provisioning
c) Income recognition
d) Project Loans
2 e) Case Studies
f) Restructuring of Advances
Introduction
The system of NPA classification was introduced by RBI for the banks
w.e.f 31/03/1993.
Master Circular (MC) issued by RBI every year, however not in 2016 so
the MC dtd 1st July, 2015 is relevant
One of the most important areas in bank audit, consuming major time
of the auditors.
Identification & Classification of NPA is claimed to be system driven,
however appropriate checks of the parameters needs to be made.
3
Inspite of use of technology & quarterly classification by the bank, no
decrease in MOC’s by statutory auditors at the year end.
Primary responsibility of making proper NPA classifications &
provisioning is of the bank management & statutory auditors.
Introduction Contd …
•Position of Gross NPA’s as per RBI
Rs in Crores
Particulars 31st March, 2015 31st March, 2016
SBI & Associates 73508 121969
Private Banks 33361 56185
Other Nationalized Banks 204960 417988
Categories of NPA
5 Substandard:- An NPA for the period of less than or equal to 12 months from the
date of NPA
Doubtful :- An NPA for a period more than 12 months from the date of NPA. Even
accounts with serious credit impairment / no security below 12 months.
Loss :- Account identified as uncollectible with negligible salvage or recovery value &
not written off in the books.
Asset Classification… Basic Concepts
Out of Order :-
An account will be treated as “out of order” if the outstanding balance in the account
is over the sanctioned limit / DP continuously for more than 90 days.
Even if the outstanding balance is below the sanction limit, but the credits in the
account are not sufficient to cover the interest debited, or as on the Balance Sheet
date there are no credits during the last 90 days, still the account is considered as “out
of order”.
Over due :
Any amount due to the bank not paid on the due date is considered to be overdue.
6
Three aspects for checking of NPA
a) Fresh Identification
b) Proper Movement of classification from one category of NPA to another.
c) Upgradation of loan accounts earlier classified as NPA.
Guidelines on Asset Classification
Availability of security or net worth of the borrower / guarantor should
not be considered while classifying the account.
Classification of account should be based on the record of the recovery
& an account should not be classified as NPA merely for temporary
deficiencies such as non receipt of stock statement, non renewal of limits,
balance outstanding exceeding the limits/ DP, etc. However, the
following would be treated as NPA
a) DP allowed on stock statement older than 3 months & such irregular
drawings permitted for more than 90 days.
7 b) Limits not reviewed / renewed within 180 days from the due date.
c) Outstanding in the account continuously above the DP/limits
The asset classification should be borrower wise and not facility wise,
except in certain cases such as loans to PACS, bills discounted under LC,
etc.
Guidelines on Asset Classification ……Contd…
Borrower wise NPA classification does not extend to the group concerns & the
classification status of each entity in the group needs to be identified separately.
Advances against TDR’s / KVP/IVP, LIC Policies should not be treated as
NPA if sufficient margin is available. Advances against gold ornament / Govt.
securities to be classified as per regular norms.
For advances where moratorium for payment of interest is given, the interest
becomes due only after the end of the moratorium period & hence the account
should not be treated as NPA if the interest is not serviced when debited to the
account.
8 Where there is substantial erosion in the value of security (by more than 50%)
account needs to be directly classified as doubtful. Where the value of security is
less than 10% of the outstanding amount account to be classified as Loss.
In case of frauds entire amount due to the bank / amount for which the bank is
liable (without considering the value of security) to be provided.
Fresh identification of NPA
Loans with Fixed repayment period ie Term Loans/ Demand loans/ Personal
loans :- A loan is treated as a non-performing asset (NPA) if interest and/or
instalment of principal remain overdue for a period of more than 90 days
As per Para 2.1.3 of the MC, “In case of interest payments, banks should, classify an
account as NPA only if the interest due and charged during any quarter is not serviced
fully within 90 days from the end of the quarter”
E.g. :- If interest is charged in a TL A/c. on 31st Oct, 2016 & if the interest is not
serviced within 90 days from 31st Dec, 2016 then only the TL A/c. would be
treated as NPA not otherwise.
Export Project Finance :- If the importer has paid the amount, but due to
political reasons the bank abroad is not able to remit the funds, which is
established by documentary evidences then account need not be classified as
NPA up to a period of 1 year from the date of deposit by importers bank.
Fresh identification ……Contd…
Advances to PACS / FSS :- In case of advances granted under the on-lending
system, only the particular credit facility granted to PACSs or FSSs, which is in
default for a period of two crop seasons in case of short duration crops and one
crop season in case of long duration crops, as the case may be, after it has
become due will be classified as NPA and not all the credit facilities sanctioned.
The other direct loans & advances, if any, granted by the bank to the member
borrower of a PACS/ FSS outside the on-lending arrangement will become NPA
even if one of the credit facilities granted to the same borrower becomes NPA.
Advance under Rehabilitation of BIFR/ Term Lending Institutions, etc. :-
12 Even after rehabilitation the existing asset classification to continue.
Upgradation of classification only after one year of satisfactory performance.
For additional facilities sanctioned under package, IRAC norms to be
applicable after one year.
Demonetization- Effect on asset classification
Consequent to demonetization RBI has issued two circulars dtd 21/11/16 &
28/12/16, having effect on asset classification as on Mar-17.
The above circulars provide that an additional period of 60/90 days beyond the
applicable time to be provided to the following borrowers for recognizing a
account to be substandard.
a) Running working capital accounts (OD/CC)/crop loans, with any bank, the
sanctioned limit whereof is Rs. 1 crore or less;
b) Term loans, whether business or personal, secured or otherwise, the original
sanctioned amount whereof is Rs. 1 crore or less, on the books of any bank or any
NBFC, including NBFC (Micro Finance Institution). This shall include housing
loans and agriculture loans;
13 c) Loans sanctioned by banks to NBFC (MFI), NBFCs, Housing Finance Companies,
and Primary Agriculture Credits and by State Cooperative Banks to District Central
Co-operative Banks.
d) The above guidelines will also be applicable to loans extended by DCCBs.
e) The limits at (a) and (b) above are mutually exclusive limits applicable to respective
categories of loans
Demonetization- Effect on asset classification
The above guidelines are subject to the following conditions
It would apply to dues payable between November 1, 2016 and December 31,
2016.
It is also clarified that the aforesaid guideline is a short-term deferment of
classification as substandard due to delay in payment of dues arising during the
period specified above and does not result in restructuring of the loans.
Dues payable before November 1 and after December 31, 2016, will be covered
by the extant instruction for the respective RE with regard to recognition of NPAs.
The additional time given shall only apply to defer the classification of an
existing standard asset as substandard and not for delaying the migration of an
14 account across sub-categories of NPA.
The effect of the above would be that the eligible borrowers would get
additional time for payment of dues of Nov & Dec16 by 60/90 days.
Fresh Identification of NPA’s – How ?
Check if all accounts of the borrower are tagged under a single customer ID
Position of the branch as of the last quarter / month as available.
Loan balance file / CC/OD balance file if available in soft form can be taken
and analysed.
List of SMA accounts reported to higher authorities.
For crop loans to confirm if the area of the branch is covered under any natural
calamity.
Care / caution to be taken for ever greening in the accounts such as.
15
•Cash deposit shown without actual cash receipt (Agri. Loans)
•Cheque purchase shown at the year end but returned in the next year.
•Transfer from sister concerns accounts.
•Recoveries from new limits sanctioned.
Movement of existing NPA’s to other categories
Copy of last years audited classification & MOC to be taken.
Check if old NPA’s properly classified based on the NPA date.
Valuation of securities as per prescribed norms of 3 years.
Shifting of NPA accounts from one category to another, based on
severe credit impairment or heavy erosion in the value of security.
16
Upgradation of NPA’s
Upgradation of current years NPA & previous years NPA to be
thoroughly checked.
Upgradation of loans (other than re-structured) to be done only after
recovery of full arrears of principal & interest due & not the critical
amount due. The status of the account should be “No overdue” instead
of “Overdue within 90 days”.
Upgradation within the NPA category is not permitted i.e. a Doubtful
account cannot be made Sub-standard even if the overdue are reduced to
less than 12 months.
Agri. Advances affected by natural calamities.
17 Banks to decide on their own regarding measures to be taken for
conversion of short term loans or re-schedulement of repayment period &
sanctioning of fresh short term loans subject to guidelines of RBI.
In cases of conversion or re-schedulement, the term loan as well as fresh
short-term loan may be treated as current dues and need not be classified
as NPA.
Provisioning Norms
Standard Asset Farm Agricultural and SMEs 0.25 %
Commercial Real Estate (CRE) 1.00 %
(CRE) Residential Housing 0.75 %
All Others not included above 0.40 %
Housing Loans (Teaser) 2.00%
Sub Standard Asset Outstanding (secured) 15.00 %
Outstanding (Unsecured ) 25.00%
Bad & Doubtful Asset Doubtful I – upto 1 year (Secured Portion) 25.00 %
Doubtful II – 1 to 3 years (Secured Portion) 40.00 %
Doubtful III – more than 3 years 100.00 %
Unsecured Portion of all I, II 100.00%
Loss Asset Total Outstanding 100.00 %
18
Income Recognition
The policy followed by the bank on IRAC should be objective & based on
record of recovery & not subjective.
Income on NPA accounts to be recognized only when actually received & not
on accrual basis (even for Govt. guaranteed A/c’s). However, the recovery
should not be from fresh / additional facilities sanctioned.
Interest on advances against TDR, KVP / IVP, LIC policy, etc. to be
recognized on accrual basis if adequate margin is available.
Fees & commissions earned by the bank on re-scheduled loans should be
treated as income on accrual basis over the period of the loan.
19
In case of NPA A/c., if the income credited on accrual basis in the past is not
realized then such income needs to be reversed.
Bank should follow an accounting policy, for appropriation of recoveries in
NPA A/c., which is uniform & consistent if there is no clear agreement between
the bank & borrower regarding the appropriation of recoveries.
Early recognition of Financial Distress
As per RBI guidelines effective from April 1, 2014 banks have to further classify
the “Standard” accounts into four categories, with a view of early detection of
financial distress.
Central Repository of Information on Large Credits (CRILC) is formed by RBI
& banks to report the status of all accounts where the aggregate FB& NFB limits
are more than Rs 5 Cr.
23
Project Loans
Project Loan: A Term Loan extended for the purpose of setting up of an
economic venture.
For these loans banks are allowed to continue the status of loans as “Standard”
in the following cases subject to certain conditions
24 a) Deferment of DCCO
b) Change in ownership
c) Increase in project outlay due to increase in scope & size of the project
Income Recognition
On accrual basis for standard accounts & cash basis for NPA
30
In case of FITL a provision for an equal amount treated as
income needs to be made in an account “Sundry Liabilities A/c
(Interest capitalization)”
Project Loan- Other Issues
Mere extension of DCCO within permitted time limits & consequential
shift in repayment period by equal or shorter duration would not mean
restructure, provided all other terms & conditions remain unchanged.
32
Case Study
A term loan is granted & EMIs are payable at the start of every month on
1st day of the month. What will be the date of becoming NPA (sub-
standard) in the following cases.
Term loan amount Rs 90 lacs & EMI due on 1st Oct,2016 is not
received till 31.3.17.
Term loan amount Rs 90 lacs & EMI due on 1st Nov,2016 is not
received till 31.3.17.
Term loan amount Rs 110 lacs & EMI due on 1st Nov,2016 is not
33 received till 31.3.17.
Case Study
Housing loan of Rs 47.85 lacs was disbursed on 1/5/2012 for ready
possession flat & repayment was to commence after moratorium of 6 months
i.e. 1st Nov, 2012 & repayable by way of 180 EMIs (principal + Int) of Rs
50000 per month.
Following is the position of yearly EMIs due & EMIs received as on 31.3.17
Financial Year Amount received towards EMI’s (Rs)
2012-13 225000
2013-14 540000
2014-15 505000
2015-16 540000
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2016-17 525000
Total 2335000
What will be the classification of all the above a/cs in the following cases
(assuming other accounts are being operated as per guidelines) :-
35 1) Term loan has been classified as sub-standard due to non-payment of
dues as on 31.3.17.
2) Bill discounting under LC has been classified as NPA as on 31.3.17
Case Study
37
Restructuring of Advances
38
Restructuring of Advances
Four Broad Catagories:
Advances extended to Industrial Units(IU)
Advances extended to IU under CDR
Advances to SME
All other advances
Exception: Advances restructured due to natural calamities relating
to Agriculture
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Eligibility
Any account classified under standard, sub standard and doubtful
categories.
Restructuring of Advances………. Contd..
Restructuring cannot be done retrospectively.
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