3(1) Trade receivables includes amounts due from the related parties amounting to H5.00 lakh as on March 31, 2024 (P.Y. H0.04 lakh) (refer Note 36)
3(11) No trade or other receivables are due from directors or other officers of the Company either severally or jointly with any other person. Nor any trade or other receivable are due from firms or private companies respectively in which any director is a partner, a director or a member.
3(iii) Trade receivables are non-interest bearing and are generally on terms of 30 to 90 days.
3 (iv)lmpairment allowance for trade receivable is Nil and therefore related disclosures are not given in the financial statement.
i) Loans and receivables are non-derivative financial assets which generate a fixed or variable interest income for the Company. The carrying value may be affected by changes in the credit risk of the counterparties.
ii) Loans granted by the Company are secured by equitable mortgage/registered mortgage of the property and/or undertaking to create a security and/or personal guarantees and/or hypothecation of assets and/or assignments of life insurance policies. The process of security creation was in progress for loans to the extent of H35,026.27 lakh at March 31, 2024 (P.Y. 22,634.53 lakh)
iii) Loans sanctioned but undisbursed amount is H60,625.86 lakh as on March 31, 2024 (P.Y. H59,372.75 lakh)
iv) The company is not granting any loans against gold jewellery as collateral.
v) The company is not granting any loans against security of shares as collateral.
vi) The Company has assigned a pool of loans amounting to H1,38,107.04 lakh (P.Y. H1,05,955.78 lakh) by way of a direct assignment transaction during the year. These loan assets have been de-recognised from the loan portfolio of the Company as the sale of loan assets is an absolute assignment and transfer on a ‘no-recourse’ basis. The Company continues to act as a servicer to the assignment transaction on behalf of assignee. In terms of the assignment agreement, the Company pays to assignee, on a monthly basis, the pro-rata collection amounts (refer Note no. 47).
vii) The Company has transfered a pool of loans amounting to H433.00 lakh (P.Y. Nil) by way of a Co-lending transaction during the year.
viii) The Company has granted loans to staff secured by equitable mortgage/registered mortgage of the property amounting to H4,488.76 lakh as on March 31, 2024 (P.Y. H4,094.01 lakh).
ix) As per RBI Master Direction - Monitoring of Frauds in NBFCs (Reserve Bank) Directions, 2016 dated September 29, 2016, Loan assets include two loans of H26.18 lakh (P.Y. two loan of H42.97 lakh), which became doubtful due to fraudulent misrepresentation by the borrowers and same has been provided for.
x) Refer to note 1.15.4, loan assets includes cases admitted under SARFESI aggregating H 4,299.55 (P.Y. H3,138.43 lakh) with effect from April 01, 2022
4(a)(1) Grouping financial assets measured on a collective basis
As explained in Note 1.15, the Company calculates ECLs on collective basis on following asset classes:
Ý Housing-Salaried lending
Ý Housing-Self Employed lending
Ý Non Housing-Salaried lending
Ý Non Housing-Self Employed lending
The Company groups these exposure into smaller homogeneous portfolios, based on a combination of internal and external
characteristics of the loans such as product type and customer type.
4(a)(3) Impairment assessment
The references below show where the Company’s impairment assessment and measurement approach is set out in these notes. It should be read in conjunction with the Summary of material accounting policies.
4(a)(3)(i) Definition of default
The Company considers a loan assets as defaulted and considered it as Stage 3 (credit-impaired) for ECL calculations in all cases, when the borrower becomes more than 90 days past due (DPD) on its contractual payments on any day irrespective of reporting cycle. Company upgrade stage 3 cases only if entire arrears of interest and principal are paid by the borrower i.e. DPD becomes zero. The Probability of Default (PD) is an estimate of the likelihood of default over a given time horizon. A default may only happen at a certain time over the assessed year, if the facility has not been previously derecognized and is still in the portfolio.
4(a)(3)(ii) The Company’s process for managing risk
Credit risk is the risk that a customer or counterparty will default on its contractual obligations resulting in financial loss to the Company. The Company’s main income generating activity is lending to customers and therefore credit risk is a principal risk. Credit risk mainly arises from loans and advances to customers, investments in debt securities and derivatives that are an asset position. The Company considers all elements of credit risk exposure such as counterparty default risk, geographical risk and sector risk for risk management purposes.
4(a)(3)(iii) Exposure at default
The exposure at default (EAD) represents the gross carrying amount of the loan assets subject to the impairment calculation, addressing both the client’s ability to increase its exposure while approaching default and potential early repayments too.
To calculate the EAD for a Stage 1 loan, the Company assesses the possible default events within 12 months for the calculation of the 12mECL. For Stage 2 and Stage 3 financial assets, the exposure at default is considered for events over the lifetime of the loan assets.
4(a)(3)(iv) Loss given default
The Company segments its retail lending products into smaller homogeneous portfolios (housing and non housing), based on key characteristics that are relevant to the estimation of future cash flows. The data applied is collected loss data and involves a wider set of transaction characteristics (e.g., product type, wider range of collateral types) as well as borrower characteristics.
4(a)(3)(v) Significant increase in credit risk
The Company continuously monitors all assets subject to ECL. In order to determine whether a loan asset or a portfolio of loan assets is subject to 12mECL or LTECL, the Company assesses whether there has been a significant increase in credit risk since initial recognition. The Company considers an exposure to have significantly increased in credit risk when contractual payments are more than 30 days past due .
During the financial year ended March 31, 2022, RBI issued resolution framework 2.0 dated May 05, 2021 accordance with that Company offered moratorium on payment of all installment and/or interest as applicable to all eligiable borrowers. For all such accounts that were granted moratorium, the prudential assets classification remained standstill during the moratorium period (i.e. the number of days past due shall exclude the moratorium period for the purposes of asset classification under Income Recognition, Asset Classification and Provisioning Norms). The Company continues to monitor such cases and takes necessary action based on the repayments and the resolution framework 2.0.
When estimating ECL on a collective basis for a group of similar assets, the Company applies the same principles for assessing whether there has been a significant increase in credit risk since initial recognition.
4(a)(3)(vi) Risk assessment model
The Company has designed and operates its risk assessment model that factors in both quantitative as well as qualitative information on the loans and the borrowers. The model uses historical empirical data to arrive at factors that are indicative of future credit risk and segments the portfolio on the basis of combinations of these parameters into smaller homogenous portfolios from the perspective of credit behaviour.
4(a)(4) Collateral
The Company holds collateral to mitigate credit risk associated with financial assets.The main types of collateral are registered /equitable mortgage property. The collateral presented relates to loan assets that are measured at amortised cost.
The Company did not hold any loan assets for which no loss allowance is recognised because of collateral at March 31, 2024. Refer note 44(C) for risk concentration based on Loan to value(LTV).
5(b) The Board of Directors of the Company in its meeting held on October 26, 2023 approved Voluntary Liquidation of wholly owned Subsidiary - Aavas Finserv Limited. Effective from November 03, 2023, the control of the subsidiary has been transferred to the official liquidator. The Company has received money amounting HI,172.02 lakh towards its carrying value of the Investment.
13(a) Secured term loans from National Housing Bank (NHB) carry rate of interest in the range of 2.80% to 8.50% p.a. The loans are having tenure of 7 to 15 years from the date of disbursement and are repayable in quarterly instalments. These loans are secured by hypothecation (exclusive charge) of the loans given by the Company.
13(b) Secured term loans from Banks include loans from various banks and carry rate of interest in the range of 6.80% to 9.40% p.a. The loans are having tenure of 5 to 15 years from the date of disbursement and are repayable in monthly or quarterly or yearly instalments. These loans are secured by hypothecation (exclusive charge) of the loans given by the Company. Secured term loan from banks also include auto loans of H382.18 lakh (P.Y. H370.43 lakh) carrying rate of interest in the range of 7.35% to 10.10% p.a. which are secured by hypothecation of Company's vehicles.
13(c) Secured loans from financial institutions include loan from Small Industries Development Bank of India (SIDBI) of H4,990.19 lakh (P.Y. Nil) carrying rate of interest at the rate of 8.20% p.a. which are secured by hypothecation of receivables. Secured loans from financial institutions include auto loans of H Nil (P.Y. H7.52 lakh) carrying rate of interest in the range of 8.75 % p.a. which are secured by hypothecation of Company's vehicles.
13(d) Secured term loan from Insurance Company carry rate of interest of 9.25% p.a. The loan is having tenure of 8 years from the date of disbursement and is repayable in half yearly instalments. The loan is secured by hypothecation (exclusive charge) of the loans given by the Company.
13(e) Cash credit borrowings from bank are repayable on demand and carry interest rates ranging from 8.70% to 10.90%
13(f) Other borrowings includes associated liabilities to securitized asset that has been re-recognised due to non fulfillment of derecognition criteria as per Ind AS.
As per records of the Company, including its register of shareholders/ members and other declarations received from shareholders regarding beneficial interest, the above shareholding represents both legal and beneficial ownerships of shares.
20(c) Rights, preferences and restrictions attached to shares Equity shares:
The Company has one class of equity shares having a par value of H10 per share. Each shareholder is eligible for one vote per share held. The dividend as and when proposed by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in case of interim dividend. In the event of liquidation, the equity shareholders are eligible to receive the remaining assets of the Company after distribution of all preferential amounts, in proportion to their shareholding.
21(a) Nature and purpose of reserve
Securities premium
Securities premium is used to record the premium on issue of shares. The reserve is utilised in accordance with provisions of the Companies Act, 2013.
Special reserve
Section 29C (i) of the National Housing Bank Act, 1987 defines that every housing finance institution which is a Company shall create a reserve fund and transfer therein a sum not less than twenty percent of its net profit every year as disclosed in the statement of profit and loss before any dividend is declared. For this purpose any special reserve created by the Company under Section 36(1) (viii) of Income tax Act 1961, is considered to be an eligible transfer. During the year ended March 31, 2024, The Company has transferred an amount of H8,903.57 lakh (P.Y. H7,311.11 lakh) to special reserve in terms of Section 36(1) (viii) of the Income Tax Act 1961 considered eligible for special reserve u/s 29C of NHB Act 1987 and also transferred an amount of H 913.34 lakh (P.Y. Rs. 1,254.46 lakh) to the Reserve in terms of Section 29C of the National Housing Bank (“NHB”) Act, 1987.
Share Based Payments Reserve
This Reserve relates to stock options granted by the Company to employees under various ESOP Schemes. This Reserve is transferred to Securities Premium Account on exercise of vested options.
Defined Contribution plan
The Company operates defined contribution plan (Provident fund) for all qualifying employees of the Company. The employees of the Company are members of a retirement contribution plan operated by the government. The Company is required to contribute a specified percentage of payroll cost to the retirement contribution scheme to fund the benefits. The only obligation of the Company with respect to the plan is to make the specified contributions. T he Company’s contribution to provident fund aggregating HI,278.66 lakhs (P.Y. HI,172.08 lakhs) has been recognised in the statement of profit and loss under the head employee benefits expense.
Gratuity and other post-employment benefit plans
The Company has a defined benefit gratuity plan. Every employee who has completed five years or more of service is eligible for gratuity on cessation of employment and it is computed at 15 days salary (last drawn salary) for each completed year of service subject to such limit as prescribed by the Payment of Gratuity Act, 1972 as.
The following tables summarize the components of net benefits expense recognized in the statement of profit and loss and the funded status and amounts recognized in the balance sheet for the respective plans.
The sensitivity analysis have been determined based on reasonably possible changes of the respective 'assumptions occurring at the end of the reporting period, while holding all other assumptions constant.
Funding Arrangement and Policy
The contribution by the Corporation to fund the liabilities of the plan has to be invested. The trustees of the 'plan are required to invest the funds as per the prescribed pattern of investments laid out in the income tax 'rules for such approved schemes. Due to the restrictions in the type of investments that can be held by the 'fund, it is not possible to explicitly follow an asset-liability matching strategy to manage risk actively.
Other Benefits
The Company has provided for compensatory leaves which can be availed and not encashed as per policy of the Company as present value obligation of the benefit at related current service cost measured using the Projected Unit Credit Method on the basis of an actuarial valuation.
34 Segment information
The Company has only one reportable business segment, i.e. lending to borrowers within India, which have similar nature of products and services, type/class of customers and the nature of the regulatory environment (which is banking), risks and returns for the purpose of Ind AS 108 on 'Segment Reporting'. Accordingly, the amounts appearing in the financial statements relate to the Company’s single business segment. No revenue from transactions with a single external customer aggregates to 10% or more of the Company's total revenue during the year ended March 31, 2024 and March 31, 2023.
35 The Company has been granted Certificate of Registration (No. 08.0095.11) to commence/carry on the business as a housing finance company without accepting public deposits by National Housing Bank on August 04, 2011 and got a revised Certificate of Registration (02.0104.13) after conversion of Company from a private limited company to a public limited company on February 08, 2013. Further, the name of our company was changed to AAVAS FINANCIERS LIMITED, pursuant to a Shareholders resolution passed at the EOGM held on February 23, 2017. A fresh certificate of incorporation consequent to such change of name was issued on March 29, 2017 by the Registrar of companies, Jaipur and subsequently the revised certificate of Registration (No.04.0151.17) was issued on April 19, 2017 by National Housing Bank.
37 The Company’s pending litigations comprise of claims against the Company primarily by the customers. The Company has reviewed all its pending litigations and proceedings and has adequately provided for where provisions are required and disclosed the contingent liabilities where applicable, in its financial statements. The Company does not expect the outcome of these proceedings to have a material adverse effect on its financial statements of the Company as at March 31, 2024.
38 Commitments and Contingencies
a Capital and other commitments:
|
|
|
|
(H in lakh)
|
Particulars
|
|
As at March 31, 2024
|
|
|
Estimated Project cost
|
Paid during the year
|
Balance Payable
|
Property, plant and equipment
|
227.36
|
49.93
|
177.43
|
Other intangible assets
|
2,474.29
|
1,089.12
|
1,385.17
|
(H in lakh)
|
Particulars
|
As at March 31, 2023
|
|
Estimated Project cost
|
Paid during the year
|
Balance Payable
|
Property, plant and equipment
|
222.47
|
83.25
|
139.22
|
Other intangible assets
|
3,501.75
|
2,036.69
|
1,465.06
|
Refer note 4(iii) for undisbursed commitment relating to loans.
b There are no Contingent Liabilities as on March 31, 2024 and March 31, 2023 39 Expenditure in Foreign currency
|
|
|
(H in lakh)
|
Particulars
|
Year ended March 31, 2024
|
Year ended March 31, 2023
|
Interest paid*
|
3,563.24
|
3,995.25
|
Other Expenses**
|
809.38
|
799.29
|
*Interest expenses does not includes provision for interest on Rupee Denominated Bond (RDB) issued on March 10, 2022 payable to CDC Group amounting
to Rs 220.95 lakh (PY H190.50 lakh).
**Other expenses does not includes provision for royalty payable to Intralinks Inc. amounting to H Nil (PY H10.00 lakh).
|
40 CSR Expenses
Operating expenses include H904.79 lakh for the year ended March 31, 2024 (P.Y. H740.13 lakh) towards Corporate Social Responsibility (CSR), in accordance with Companies Act, 2013. Gross amount (including excess spending/ Deficit of previous year) required to be spent by the Company during the year is H904.79 lakh. (P.Y. H788.56 lakh). The Board of Directors of the Company has approved an amount of CSR of H904.79 lakh.
During the year ended March 31, 2024, the Company has spent excess amount of CSR amounting to H31.34 lakh. The said pre-spent shall be carried forward in next financial year in accordance with the provisions of Companies Act, 2013.
f. Reason of shortfall at the end of year
No short fall during the FY 2023-24.
g. Nature of CSR activities
1. Plantation, Renewable Energy and Traditional Energy Sources e.g. Solar Energy, Bio Gas, and Promoting Green Home Practices.
2. Aavas Udaan: Skill Development: focusing on industry specific and new age courses.
3. Aavas Gurukul: School Infrastructure, Resources and Scholarship.
4. Khelodaya: Sports Training, Scholarship, Sponsorship.
5. Road Safety and other Awareness programs.
6. Vishwakarma: Construction Worker Development- Focus on Construction Workers and their Families, Skill Building, Health and Safety, Social Security, Decent Work Environment.
7. Aavas Aahar Program, Health Care and Wellness, improving Health Infrastructure in Rural and Peri-Urban Areas, Health Camps.
8. Gram Siddhi- Enterprise Development, E-Commerce & Digital Marketing, Refresher Training to existing Gram Siddhis.
9. Association with Academic Institutions for R&D in the field of Green Housing; Environment Friendly Material, Designs and Construction Waste Management.
h. Details of related party transactions
The Company has paid H429.10 lakh for CSR expenditure to Aavas Foundation, public trust registered under section 12A and 80G of Income Tax Act 1961, established by the Company singly for the purpose of CSR.
41 Fair value measurement
41(a) Valuation Principles
Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction in the principal (or most advantageous) market at the measurement date under current market conditions (i.e., an exit price), regardless of whether that price is directly/ indirectly observable or estimated using a valuation technique. In order to show how fair values have been derived, financial instruments are classified based on a hierarchy of valuation techniques.
41(b) Fair Value of financial instruments which are not measured at Fair Value
The carrying amounts and fair value of the Company's financial instruments are reasonable approximations of fair values at financial statement level.
Valuation methodologies of financial instruments not measured at fair value Loans
Most of the loans are repriced frequently, with interest rate of loans reflecting current market pricing. Hence carrying value of loans is deemed to be equivalent of fair value.
Borrowings
The Company’s most of the borrowings are at floating rate which approximates the fair value.
Debt securities and subordinate liabilities are fixed rate borrowings and fair value of these fixed rate borrowings is determined by discounting expected future contractual cash flows using current market interest rates charged for similar new loans and carrying value approximates the fair value for fixed rate borrowing at financial statement level.
Short Term and Other Financial Assets and Liabilities
The management assessed that cash and cash equivalents, investments, other financial assets, trade payables and other financial liabilities approximate their carrying amounts largely due to the short-term maturities of these instruments.
Assets held for sale
Real estate properties are valued based on a well progressed sale process with price quotes.
42 Transfer of Financial assets
Transfers of financial assets that are not derecognised in their entirety
Securitisation:
The Company uses securitisations as a source of finance. Such transactions generally result in the transfer of contractual cash flows from portfolios of financial assets to holders of issued debt securities. Securitisation has resulted in the continued recognition of the securitised assets.
Assignment Deal:
During the year ended March 31, 2024, the Company has sold some loans and advances measured at amortised cost as per assignment deals, as a source of finance. As per the terms of these deals, since substantial risk and rewards related to these assets were transferred to the buyer, the assets have been derecognised from the Company’s balance sheet.
The management has evaluated the impact of assignment transactions done during the year for its business model. Based on the future business plan , the company business model remains to hold the assets for collecting contractual cash flows.
The table below summarises the carrying amount of the derecognised financial assets measured at amortised cost and the gain on derecognition.
Co-lending Deal:
During the year ended March 31, 2024, the Company has transfered a pool of loans amounting to H433.00 lakh (P.Y. Nil) by way of a Co-lending transaction during the year. These loan assets have been de-recognised from the loan portfolio of the Company as the sale of loan assets is an absolute assignment and transfer on a ‘no-recourse’ basis. The Company continues to act as a servicer to the Co-lending transaction on behalf of lender.
43 Capital management:
For the purpose of the Company’s capital management, capital includes issued equity capital, Securities premium and all other equity reserves attributable to the equity holders of the Company net of intangible assets. The primary objective of the Company’s capital management is safety and security of share capital and maximize the shareholder value.
The Company manages its capital structure in light of changes in economic conditions and the requirements of the financial covenants. The Company monitors capital using a gearing ratio, which is total debt divided by net worth. The Company’s policy is to keep the gearing ratio at reasonable level of 6-8 times in imminent year while the Master Direction - Non-Banking Financial Company - Housing Finance Company (Reserve Bank) Directions, 2021 currently permits HFCs to borrow up to 12 times of their net owned funds (“NOF”). The Company includes with in debt, its all interest bearing loans and borrowings.
In order to achieve this overall objective, the Company’s capital management, amongst other things, aims to ensure that it meets financial covenants attached to the interest-bearing loans and borrowings that define capital structure requirements. Breaches in meeting the financial covenants would permit the bank to immediately call loans and borrowings. There have been no breaches in the financial covenants of any interest-bearing loans and borrowing in the current year.
44 Financial risk management objectives and policies
The Company’s Principal financial liabilities comprise loans and borrowings. The main purpose of these financial liabilities is to finance the company’s operations. At the other hand company’s Principal financial assets include loans and cash and cash equivalents that derive directly from its operations.
As a lending institution, Company is exposed to various risks that are related to lending business and operating environment. The Principal Objective in Company's risk management processes is to measure and monitor the various risks that Company is subject to and to follow policies and procedures to address such risks. Company 's risk management framework is driven by Board and its subcommittees including the Audit Committee, the Asset Liability Management Committee and the Risk Management Committee. Company gives due importance to prudent lending practices and have implemented suitable measures for risk mitigation, which include verification of credit history from credit information bureaus, personal verification of a customer’s business and residence, technical and legal verifications, conservative loan to value, and required term cover for insurance. The major types of risk Company face in businesses are liquidity risk, credit risk, interest rate risk.
(A) Liquidity risk
Liquidity Risk refers to the risk that the company can not meet its financial obligations. The objective of Liquidity risk management is to maintain sufficient liquidity and ensure that funds are available for use as per requirement. The unavailability of adequate amount of funds at optimum cost and co-terminus tenure to repay the financial liabilities and further growth of business resultantly may face an Asset Liability Management (ALM) mismatch caused by a difference in the maturity profile of Company assets and liabilities. This risk may arise from the unexpected increase in the cost of funding an asset portfolio at the appropriate maturity and the risk of being unable to liquidate a position in a timely manner and at a reasonable price. The Company manages liquidity risk by maintaining adequate cash reserves and undrawn credit facilities, by continuously monitoring forecast and actual cash flows, and by matching the maturity profiles of financial assets and liabilities.
The Company has given cash collateral for the securitisation transactions and do not expect any net cash outflow and hence guarantees given for securitisation transactions have not been shown as part of below table. Further, undisbursed loan amount being cancellable in nature are not disclosed as part of below mentioned maturity profile.
The table below summarises the maturity profile of the undiscounted cash flows of the Company's financial liabilities.
(B) Credit risk
Credit Risk arises from the risk of loss that may occur from the default of Company's customers under loan agreements. Customer defaults and inadequate collateral may lead to higher credit impaired assets. Company address credit risks by using a set of credit norms and policies, which are approved by Board and backed by analytics and technology. Company has implemented a structured and standardized credit approval process, including customer selection criteria, comprehensive credit risk assessment and cash flow analysis, which encompasses analysis of relevant quantitative and qualitative information to ascertain the credit worthiness of a potential customer. Actual credit exposures, credit limits and asset quality are regularly monitored and analysed at various levels. Company has created a robust credit assessment and underwriting practice that enables to fairly price credit risks.
The Company has created more than 60 templates of customer profiles through its experience over the years, with risk assessment measures for each geography in which it operates. The Company continuously seek to develop and update such profiles in order to identify and source reliable customers and improve efficiencies. The Company also conduct an analysis of the existing cash flow of customer’s business to assess their repayment abilities. The Company has implemented a four prong system of credit assessment comprising underwriting, legal assessments, technical assessments and a risk containment unit.
Exposure to credit risk
The carrying amount of financial assets represents the maximum credit exposure. The maximum exposure to credit risk was ?14,42,255.64 lakh and H11,82,933.63 lakh as of March 31, 2024 and March 31, 2023 respectively, being the total of the carrying amount of Loan assets and EIS receivable.
(C) Analysis of risk concentration
The Company’s concentrations of risk are managed based on Loan to value (LTV) segregation as well as geographical spread. The following tables stratify credit exposures from housing and other loans to customers by range of loan-to-value (LTV) ratio .LTV is calculated as the ratio of gross amount of the loan - or the amount committed for loan commitments - to the value of the collateral. The value of the collateral for housing and other loans is based on collateral value at origination.
(D) Market Risk
Market risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market factors. Such changes in the values of financial instruments may result from changes in the interest rates, credit, liquidity and other market changes. The Company’s exposure to market risk is primarily on account of interest rate risk.
(I) Interest Rate Risk:-
The company is subject to interest rate risk, primarily since it lends to customers at rates and for maturity years that may differ from funding sources. Interest rates are highly sensitive to many factors beyond control, including the monetary policies of the Reserve Bank of India, deregulation of the financial sector in India, domestic and international economic and political conditions, inflation and other factors. In order to manage interest rate risk, the company seek to optimize borrowing profile between short-term and long-term loans. The company adopts funding strategies to ensure diversified resource-raising options to minimize cost and maximize stability of funds. Assets and liabilities are categorized into various time buckets based on their maturities and Asset Liability Management Committee supervise an interest rate sensitivity report periodically for assessment of interest rate risks.
Due to the very nature of housing finance, the company is exposed to moderate to higher Interest Rate Risk. This risk has a major impact on the balance sheet as well as the income statement of the company. Interest Rate Risk arises due to:
i) Changes in Regulatory or Market Conditions affecting the interest rates
ii) Short term volatility
iii) Prepayment risk translating into a reinvestment risk
iv) Real interest rate risk.
In short run, change in interest rate affects Company’s earnings (measured by NII or NIM) and in long run it affects Market Value of Equity (MVE) or net worth. It is essential for the company to not only quantify the interest rate risk but also to manage it proactively. The company mitigates its interest rate risk by keeping a balanced portfolio of fixed and variable rate loans and borrowings. Further company carries out Earnings at risk analysis and maturity gap analysis at quarterly intervals to quantify the risk.
Interest Rate sensitivity
The following table demonstrates the sensitivity to a reasonably possible change in interest rates (all other v ariables being constant) of the Company’s statement of profit and loss and equity:
(II) Foreign currency risk
Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes in foreign currency rates. The Company’s exposure to the risk of changes in foreign exchange rates relates primary to the foreign currency borrowings taken from bank.
(E) Operational risk
Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and system or from external events. Operational risk is associated with human error, system failures and inadequate procedures and controls. It is the risk of loss arising from the potential that inadequate information system; technology failures, breaches in internal controls, fraud, unforeseen catastrophes, or other operational problems may result in unexpected losses or reputation problems. Operational risk exists in all products and business activities.
The Company recognizes that operational risk event types that have the potential to result in substantial losses includes Internal fraud, External fraud, employment practices and workplace safety, clients, products and business practices, business disruption and system failures, damage to physical assets, and finally execution, delivery and process management.
The Company cannot expect to eliminate all operational risks, but it endeavours to manage these risks through a control framework and by monitoring and responding to potential risks. Controls include effective segregation of duties, access, authorisation and reconciliation procedures, staff education and assessment processes, such as the use of internal audit.
45 In compliance with RBI circular number RBI/2020-21/16/DOR.No.BP.BC/3/21.04.048/2020-21 dated August 06, 2020 ,the Company has not invoked or implemented resolution plan under the “Resolution Framework for COVID-19 related Stress” for any of its borrower accounts.
46 Disclosures required by the Reserve Bank of India /National Housing Bank as per Notification no. DOR.FIN.HFC. CC.No.120/03.10.136/2020-21 dated February 17. 2021- Master Direction - Reserve Bank of India (Non-Banking Financial Company - Scale Based Regulation) Directions, 2023 dated October 19, 2023 (as amended)
46.1 Summary of Material Accounting Policies
The accounting policies regarding key areas of operations are disclosed as note 1 to the Standalone Financial Statement for the year ended March 31, 2024.
d. Details of financing of parent company products
There is no financing of parent company products.
e. Details of Single Borrower Limit (SGL) / Group Borrower Limit (GBL) exceeded by the HFC
The company has not exceeded the Single Borrower Limit and Group Borrower Limit as prescribed by NHB during the financial year.
f. Unsecured Advances
The company has not financed any unsecured advances against intangible securities such as rights, licenses, authority etc as collateral security.
g. Exposure to group companies engaged in real estate business
The company has no exposure to group companies engaged in real estate business in current and previous year.
e. Overseas Assets
The Company does not have any overseas assets.
f. Off-Balance Sheet SPVs sponsored (which are required to be consolidated as per accounting Norms)
The Company does not have any off balance sheet Special Purpose Vehicle (SPV) which are required to be consolidated as per accounting norms.
b. Disclosure of penalties imposed by NHB or RBI and any other regulator/ supervisor/ enforcement authority
During FY 2023-24, BSE Limited has imposed penalty of H10,000 excluding GST on the Company for delay in submission of the intimation of Record Date as per Regulation 60(2) of the SEBI (Listing Obligation and Disclosure requirement) Regulations, 2015. Apart from this there were no penalties imposed by NHB or RBI and any other regulator/ supervisor/ enforcement authority.
d. Ratings assigned by credit rating agencies and migration of ratings during the year:
During the year, CARE has reaffirmed long term rating of AA/Stable and short term rating of A1 to the company. ICRA has reaffirmed long term rating of AA/Stable and short term rating of A1 to the company. India Ratings has reaffirmed short term credit rating of A1 to the company during the year.
e. Intra-group exposures
There are no Intra-group exposures in the current and previous year.
f. Remuneration of Directors
Details of Remuneration of Directors are disclosed in Note no. 36 Related party transactions.
g. Net Profit or Loss for the period, prior period items and changes in accounting policies
There are no prior period items and changes in accounting policies that have impact on the current year’s profit and loss.
h. Revenue Recognition
There have been no instances in which revenue recognition has been postponed pending the resolution of significant uncertainties.
I. Consolidated Financial Statements (CFS)
Refer to the Consolidated Financial Statements for the relevant disclosures.
(vi) Institutional set-up for liquidity risk Management
The company has an Asset Liability Management Committee (ALCO) to monitor asset liability mismatches to ensure that there is no imbalances or excessive concentration on the either side of the balance sheet. The company maintains a judicious mix of borrowings in the form of Term Loans, Refinance, Capital Market Instruments, Securitization, Working Capital and continues to diversify its source of borrowings with the emphasis on longer tenor borrowings. The company has diversified mix of investors/lenders which includes Banks, National Housing Bank, Development Financial Institution, Mutual Funds, Insurance Companies etc. T he Liquidity Risk Management (LRM) of the company is governed by the LRM Policy approved by the Board. T he Asset Liability Committee (ALCO) is responsible for implementing and monitoring the liquidity risk management strategy of the company in line with its risk management objectives and ensures adherence to the risk tolerance/limits set by the Board. Refer note no. 44 of standalone financials statement
Qualitative Disclosure of LCR
RBI had issued guidelines on liquidity risk management for NBFCs/HFCs vide Circular No. RBI/2019-20/88 DOR.NBFC (PD) CC.No.102/03.10.001/2019-20 dated November 4, 2019 wherein RBI introduced Liquidity Coverage Ratio (LCR). The objective of the guidelines is to ensure that NBFCs/HFCs maintains a liquidity buffer in terms of LCR in addition to various process related aspects of liquidity risk management framework. LCR has to be maintained in the form sufficient High Quality Liquid Asset (HQLA) to survive any acute liquidity stress scenario lasting for subsequent 30 calendar days. LCR is one of the key parameters closely monitored by RBI to enable a more resilient financial sector. Further, RBI vide Circular No. RBI/2020-21/60 DOR. NBFC (HFC).CC. No.118/03.10.136/2020-21 dated October 22, 2020, provided non deposit taking HFCs with time extension for minimum LCR of 50% to be maintained by December 01, 2021 which is to be gradually increased to 100% by December 01, 2025. The LCR is expected to improve the ability of financial sector to absorb the shocks arising from financial and/or economic stress, thus reducing the risk of spill over from financial sector to real economy.
The liquidity risk management including LCR of the Company is governed by the Liquidity Risk Management (LRM) Policy approved by the board. The Asset Liability Committee (ALCO) is responsible for managing the LCR of the Company in line with the LRM Policy. Company regularly reviews the position of inflows, outflows and the liquidity buffers and ensures maintenance of sufficient quantum of High Quality Liquid Assets.
For computation of stressed cash outflow, all expected and contracted cash outflows are considered by applying a stress of 15%. Similarly, stressed cash inflows for the Company is arrived at by considering all expected and contracted inflows by applying a haircut of 25%. Finally, Net Cash Outflow is arrived by deducting the stressed cash inflows from stressed cash outflow. However, total net cash outflows will be subjected to a minimum of 25% of total stressed cash outflows. The LCR is computed by dividing the stock of HQLA by its total net stressed cash outflows over next 30 days
Cash outflow under secured wholesale funding majorly includes contractual obligations under Term loans, NHB ReFinance, NCDs, Interest payable within next 30 days. Outflow under credit and liquidity facilities, the Company considers the expected cash outflow of the committed credit facilities contracted with the customers. Outflow under other contractual funding obligations primarily includes outflow on account of expected operating expenses and other dues. In Inflows from fully performing exposures, Company considers the collection from performing advances in next 30 days. Other Cash inflows includes investments in mutual funds, FDs which can be liquidate within 30 days including interest receivable thereon. Company has no currency mismatch in LCR and Company is not expecting any cash outflow within next 30 days on account of derivative exposure and potential collateral requirement. For concentration of funding sources refer disclosure on the Liquidity Risk Management Framework as per note 46.13.
Tabled above the Intra-period changes as well as changes over time in the various components of the LCR, HQLA & average LCR. The Average LCR for the quarter ended March 31, 2024 was 103% which is well above present prescribed minimum requirement of 70% and the average LCR of previous periods during the year were also well above the prescribed minimum requirement of respective period.
As on March 31, 2024 most of the HQLAs of the Company are in the form of unencumbered government securities and unencumbered Cash and Bank balances and composition of unencumbered government securities in the HQLA was 94.2% for the quarter ended March 31, 2024.
46.17 Principal Business Criteria for HFCs
"Housing finance Company” shall mean a Company incorporated under the Companies Act, 2013 that fulfils the following conditions:
a) It is an NBFC whose financial assets, in the business of providing finance for housing, constitute at least 60% of its total assets (netted off by intangible assets).
b) Out of the total assets (netted off by intangible assets), not less than 50% should be by way of housing financing for individuals.
RBI vide its circular number RBI/2020-21/60/DOR.NBFC (HFC) CC.NO 118/03.10.136/2020-21 dated October 22,2020 defined the principal business criteria for HFCs. The Company meets the aforesaid principal business criteria for HFCs.
49 Additional Regulatory Information
49.1 There is no such immovable property whose title deeds are not held in the name of the Company in current year and previous year.
49.2 There are no investment property as on March 31, 2024 (P.Y. H Nil)
49.3 The Company has not revalued its Property, Plant and Equipment (including Right-of Use Assets) based on the valuation by a registered valuer as defined under rule 2 of Companies (Registered Valuers and Valuation) Rules, 2017 in current year and previous year.
49.4 The Company has not revalued its Intangible assets based on the valuation by a registered valuer as defined under rule 2 of Companies (Registered Valuers and Valuation) Rules, 2017 in current year and previous year.
49.5 Loans or Advances in the nature of loans are granted to promoters, directors, KMPs and the related parties (as defined under Companies Act, 2013,) either severally or jointly with any other person, that are:
49.6 No proceeding has been initiated or pending against the Company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) as amended and rules made thereunder in current year and previous year.
49.7 The Company has not taken borrowings from banks or financial institutions on the basis of security of current assets in current year and previous year.
49.8 The Company has not been declared wilful defaulter by any bank or financial Institution or other lender in current year and previous year.
49.9 Transactions with companies struck off under section 248 of the Companies Act, 2013 or section 560 of Companies Act, 1956
49.10 No charges or satisfaction yet to be registered with ROC beyond the statutory period.
49.11 The Company has complied with the number of layers prescribed under clause (87) of section 2 of the Act read with Companies (Restriction on number of Layers) Rules, 2017
49.12 No Scheme of Arrangements has been approved by the Competent Authority in terms of sections 230 to 237 of the Companies Act, 2013.
49.13 Utilisation of Borrowed funds and share premium
(a) The Company has not advanced or loaned or invested funds (either borrowed funds or share premium or any other sources or kind of funds) in current year and previous year to any other person(s) or entity(ies), including foreign entities (Intermediaries) with the understanding (whether recorded in writing or otherwise) that the Intermediary shall:-
(i) directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the company (Ultimate Beneficiaries) or
(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries;
(b) The Company has not received any fund in current year and previous year from any person(s) or entity(ies), including foreign entities (Funding Party) with the understanding (whether recorded in writing or otherwise) that the company shall :-
(i) directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (Ultimate Beneficiaries) or
(ii) provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries
49.14 There are no such transaction or undisclosed income that need to be disclosed in accordance with the provision of Income Tax Act, 1961 in current year and previous year.
49.15 The Company has not traded or invested in Crypto currency or Virtual Currency during current year and previous year.
50 Breach of covenants
The Company has complied with all the material covenants of borrowing facilities throughout the year ended 31 March 2024 and 31 March 2023.
51 There has been no divergence in asset classification and provisioning requirements as assessed by NHB during the year ended 31 March 2024 and 31 March 2023.
52 Previous year figures have been regrouped/ reclassified wherever applicable. The impact, if any, are not material to Financi al Statements.
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