ECL movement as on 31st March 2023 and 31st March 2024
a) The loan assets in stage 2 were 2.87% as on 31st March 2024 as against 3.61% as on 31st March 2023. The Company has applied qualitative SICR criteria owing to which stage 1 assets of H469.34 crore has moved to stage 2 assets. Pre SICR, the stage 2 loan assets as on 31st March 2024 would be 2.13% against 2.56% as on 31st March 2023.
b) ECL % POS has increased by 1.14% as on 31st March 2024 in stage 2.
c) Overall ECL % POS have decreased by 42 bps on accounts improvement in Asset quality.
ECL movement as on 31st March 2022 and 31st March 2023
a) The loan assets in stage 2 were 3.61% as on 31st March 2023 as against 3.88% as on 31st March 2022. The Company has
applied qualitative SICR criteria owing to which stage 1 assets of H584.70 crore has moved to stage 2 assets. Pre SICR,
the stage 2 loan assets as on 31st March 2023 would be 2.56% against 2.25% as on 31st March 2022.
b) ECL % POS has increased by 2.63% as on 31st March 2023 in stage 2.
c) Overall ECL % POS have decreased by 25 bps on accounts improvement in assets quality.
ECL movement as on 31st March 2023 and 31st March 2024
a) Stage 1 ECL % of POS increased from 9.47% to 16.42%.
b) The loan assets in stage 2 were increased to 6.16% as on 31st March 2024 from 0.00% as on 31st March 2023 majorly due to shift of stage 1 asset to stage 2.
c) The Company's stage 3 asset ratio has decreased from 22.25% as on 31st March 2023 to 3.31% as on 31st March 2024.
ECL movement as on 31st March 2022 and 31st March 2023
a) Stage 1 ECL % of POS increased from 6.50% to 9.47%.
b) The loan assets in stage 2 were decreased to nil as on 31st March 2023 from 0.29% as on 31st March 2022 majorly due to decreasing corporate portfolio.
c) The Company's stage 3 asset ratio has decreased from 37.13% as on 31st March 2022 to 22.25% as on 31st March 2023 owing to this ECL has also decreased.
AThe restructuring was done for Stage 1 accounts, total restructured assets were H696.38 crore (previous year H967 crore),against which provision of H94 crore (Previous year H102 crore) is held.
#Refer Note 2.21, 2.22, 2.23 and 46.1.
Note 6.4: Loans due from borrowers are secured wholly or partly by any one or all of the below as applicable:
Tangible securities
i) Equitable / Simple / English Mortgage of immovable property;
ii) Mortgage of Development Rights / FSI / any other benefit flowing from the immovable property;
iii) Hypothecation of rent receivables, cash flow of the project, debt service reserve account, fixed deposit, current and escrow accounts;
Intangible securities
i) Demand Promissory Note;
ii) Post dated cheques towards the repayment of the debt;
iii) Personal / Corporate Guarantees;
iv) Undertaking to create a security;
v) Letter of Continuity.
Note 8.1: During the year ended 31st March 2024, the Company had not sold any loans and advances measured at amortised cost. However during the year ended 31st March 2023, the Company has sold some loans and advances measured at amortised cost under co-lending deals through assignment mode. As per the terms of deal, the de-recognition criteria as per IND AS 109, including transfer of substantially all the risks and rewards relating to assets being transferred to the buyer is met and the assets have been derecognised.
Since the Company transferred the above financial asset in a transfer that qualified for derecognition in its entirety therefore the whole of the interest spread and net servicing fees (over the expected life of the assets) is recognised at present value on the date of derecognition as interest-only strip / net servicing fees receivable ("Receivables on assignment of loan") and correspondingly recognised as profit on derecognition of financial assets.
Note 8.2: Includes receivable from related party H1.92 crore (previous year H0.44 crore.)
Note 8.3: Disclosure pursuant to RBI Notification dated 24th September 2021 on "Transfer of Loan Exposures" are given below:
(a) The Company has not acquired any stressed loans or loans not in default during the year ended 31st March 2024 and 31st March 2023.
Note 18.1: Refinance from National Housing Bank (NHB):
a) Nature of Security
(i) All the present and outstanding refinancing from NHB are secured by hypothecation of specific loans/ book debts to the extent of 1.0 to 1.20 times of outstanding amount.
(ii) During FY 24, the Company has availed H3,000.00 crore (previous year H Nil) under "Liberalised Refinance Scheme" H2,250.00 crore and Affordable Housing Finance H750.00 crore to provide refinance assistance in respect of eligible individual Housing loans.
Note 18.2: Term Loan from Banks and Financial Institutions:
a) Nature of Security
i) Term loan from Punjab National Bank (related party) are secured by hypothecation by way of exclusive charge on specific standard book debts of the Company with minimum asset cover of 1.10 times to be maintained at all times.
ii) Term loans from banks other than Punjab National Bank and financial institution are secured by hypothecation of specific book debts to the extent of 1.0 to 1.12 times of outstanding amount.
Note 18.3: External Commercial Borrowing:
a) Nature of Security
i) The ECB borrowings are secured against eligible housing loans/book debts and are hedged through currency swaps, interest rate swaps and forward contracts as per the applicable RBI guidelines.
ii) The derivative contracts are initially recognised at fair value on the date of the transaction and all outstanding derivative transactions, on the date of balance sheet, are subsequently measured at fair value on that date. Where cash flow hedge accounting is used, fair value changes of the derivative contracts are recognised through the cash flow hedge reserve (through other comprehensive income) which is reclassified to profit and loss account as the hedged item effects profit and loss. Premium paid / discount received in advance (if any) on the derivative contracts, which are not intended for trading or speculation purposes, are amortised over the period of the contracts, if such contracts relate to monetary items as at the balance sheet date.
iii) As at 31st March 2024, the Company has outstanding ECB of USD 175.00 million (equivalent to H1,459.04 crore) (31st March 2023 USD 670.00 million (equivalent to H5,508.53 crore)). The Company has undertaken cross currency swaps and principal only swaps to hedge the foreign currency risk of the ECB principal. Whereas the Company has entered floating to fixed coupon only swaps to hedge the floating interest and foreign currency risk of the coupon payments. However during the previous year the Company has also entered into interest rate swaps along with forward contracts to hedge the floating interest and foreign currency risk of the coupon payments respectively. All the derivative instruments are purely for hedging the underlying ECB transactions as per applicable RBI guidelines and not for any speculative purpose.
Note 24.4: Terms / Rights Attached to Equity Shares
The Company has only one class of shares referred to as equity shares having a par value of H10/ - per share. Each holder of equity shares is entitled to one vote per share. The Company declares and pays dividend in H. Dividend distribution is for all equity shareholders who are eligible for dividend as on record date. The dividend proposed by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General meeting. In the event of liquidation of the Company, the holders of equity shares will be entitled to receive remaining assets of the Company, after distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares held by the shareholders.
Note 24.5: The Company has not allotted any share pursuant to contracts without payment being received in cash nor it has issued any bonus shares or bought back any shares, during the period of five years immediately preceding the reporting date.
Note 24.6: The Company has not:
i. Issued any securities convertible into equity / preference shares.
ii. Issued any shares where calls are unpaid.
iii. Forfeited any shares.
Note 24.7: Capital Management:
The Company maintains an actively managed capital base to cover risks inherent in the business and is meeting the capital adequacy requirements as per the directives of the regulator. The adequacy of the Company capital is monitored using, among other measures, the regulations issued by NHB & RBI from time to time.
Company has complied in full with all its externally imposed capital requirements.
The primary objectives of the Company capital management policy are to ensure that it complies with externally imposed capital requirements and maintains strong credit ratings and healthy capital ratios in order to support its business and to maximise shareholder's value.
The Company manages its capital structure after taking in to consideration the inherent business risk and the changes in economic conditions. In order to maintain or adjust the capital structure, the Company may adjust the amount of dividend payment to shareholders, return of capital to shareholders or issue capital securities.
No changes have been made to the objectives, policies and processes from the previous years and they are reviewed by the Board of Director's at regular intervals.
Regulatory capital consists of Tier I capital, which includes owned funds comprising share capital, share premium, retained earnings including current year profit and free reserves less cash flow hedge reserve, deferred revenue expenditure and intangible assets. The book value of investment in shares of other non-banking financial companies including housing finance companies and in shares, debentures, bonds, outstanding loans and advances including hire purchase and lease finance made to and deposits with subsidiaries and companies in the same group exceeding, in aggregate 10% of owned funds will be reduced while arriving at the Tier I capital.
The other component of regulatory capital is Tier II Capital Instruments, which includes non convertible preference shares, revaluation reserve, general provision and loss reserves to the extent of one and one fourth percent of risk weighted asset, hybrid capital instruments and subordinated debts.(Refer Note 36.1)
Note 25: Other Equity (Nature and Purpose of Reserves)
Share Application Money
Share application money pending allotment whereby the amount has been received on the application, of which allotment is not yet made.
Securities Premium
Securities premium includes:
- amount of premium received on issue of equity shares and;
- fair value of the stock options which are treated as expense, if any, in respect of shares allotted pursuant to Employee Stock Options Scheme.
The securities premium can be utilised only for limited purposes such as issuance of bonus shares, issue expenses of securities which qualify as equity instruments in accordance with the provisions of the Companies Act, 2013.
Special Reserve and Statutory Reserve
In accordance with Section 29C(i) of the National Housing Bank Act, 1987, the Company is required to transfer at least 20% of its net profit every year to a reserve fund (statutory reserve) before any dividend is declared.
The Company has created a special reserve in terms of clause (viii) of sub-section (1) of section 36 of the Income-tax Act, 1961 and the same is considered to be an eligible transfer for the purposes of section 29C (i).
Share Option Outstanding Account
The cost of equity settled transactions is determined by the fair value at the date when the grant is made using the Black-Scholes Model. The cumulative expense recognised for equity settled transaction is credited to share option outstanding account in equity.
Retained Earnings
Retained earnings are profits earned by the Company after transfer to general reserve and payment of dividend to shareholders.
Effective Portion of Cash Flow Hedges
The Company uses hedging instruments as part of its management of foreign currency risk and interest rate risk associated on borrowings. For hedging foreign currency and interest rate risk, the Company uses foreign currency forward contracts, cross currency swaps and interest rate swaps. To the extent these hedges are effective, the change in fair value of the hedging instrument is recognised in the cash flow hedging reserve. Amounts recognised in the cash flow hedging reserve is reclassified to the statement of profit or loss when the hedged item affects profit or loss (e.g. interest payments).
ii) The basic earnings per share has been computed by dividing the net profit after tax attributable to equity share holders of the Company by the weighted average number of equity shares outstanding during the year. The diluted earnings per share has been computed by dividing the net profit after tax attributable to equity share holders of the Company by the weighted average number of equity shares considered for deriving basic earning per equity share and also the weighted average number of equity shares that could have been issued upon conversion of all dilutive potential equity shares. The dilutive potential equity shares are adjusted for the proceeds receivable had the equity shares been actually issued at fair value (i.e. the average market value of the outstanding equity shares). Diluted potential equity shares are deemed converted as of the beginning of the period unless issued at a later date. Diluted potential equity shares are determined independently for each period presented. Diluted earnings per share does not include conversion or exercise of potential ordinary shares that would have an antidilutive effect on earnings per share.
The company being an HFC raises funds from multiple sources viz., bank borrowings, deposits, National Housing Bank (NHB), External Commercial Borrowings (ECBs), debt markets, etc. In the last few years with rising interest rates, the borrowing from the debt market was costlier than the other long-term sources. Therefore, the Company's actual borrowing through debt securities was lower primarily due to higher cost of borrowing.
As per SEBI circular SEBI/HO/DDHS/DDHS-RACPOD1/P/CIR/2023/172 dated October 19, 2023, which is effective from April 01, 2024, the framework for funds raising by issuance of debt securities by large corporates has been revised from Financial Year 2024-25 onwards. As per the new framework, the requirement of mandatory qualified borrowing by an LC in a FY (not less than 25% of the qualified borrowings) shall be met over a contiguous block of three years i.e., by March 31, 2027.
Given that various rating agencies have upgraded Company's credit rating from AA with "Negative" outlook in Finacial Year 2022-23 to AA with "Stable" outlook in Financial Year 2023-24, The Company shall raise funds through debt securities and meet the mandatory requirement of raising funds through debt securities.
Note 36: Disclosure as per regulatory guidelines
The Company has been classified as Upper Layer entity under Scale Based Regulations issued by Reserve Bank of India.
The following additional disclosures have been given in compliance with:
(i) Master Direction - Non-Banking Financial Company-Housing Finance Company (Reserve Bank) Directions, 2021 "('RBI directions") issued by RBI vide notification number RBI/2020-21/73/D0R.FIN.HFC.CC.No.120/03.10.136/2020-21 dated 17th February 2021; and
(ii) Master Direction - Reserve Bank of India (Non-Banking Financial Company - Scale Based Regulation) Directions, 2023 ("RBI directions") issued by RBI vide notification number RBI/DoR/2023-24/106/DoR.FIN.REC.No.45/03.10.119/2023-24 dated 19th October 2023.
During the previous year, the Company has sold some loans and advances measured at amortised cost under co-lending deals through assignment mode, the details of which has been given in note 8.3 (b).
iv) During the year, the Company has not purchased any non-performing financial assets (Previous year H Nil).
v) During the current and previous year, the Company has sold non-performing financial assets details of which are given in note 8.3 (c).
Note 36.6: Asset Liability Management
The residual maturity profile of Assets and Liabilities is carried out based on the current estimates and assumptions regarding behavioural pattern of pre-payments/maturities and renewals. Maturity pattern of certain items of assets and liabilities are as follows:
iii) As on 31st March 2024, the Company does not have any exposure to Capital Market (Previous year H Nil).
iv) As on 31st March 2024, the Company has not financed any product of the parent company (Previous year H Nil).
v) As on 31st March 2024, the Company has not exceeded the prudential exposure limit for single borrower or group
borrower (Previous year H Nil).
vi) As on 31st March 2024, the Company has not given any unsecured advances (Previous year H Nil).
vii) As on 31st March 2024, all advances of the Company are secured against tangible assets and there are no advances against intangible assets (Previous year H Nil).
viii) As on 31st March 2024, the Company has no exposures to group companies engaged in the real estate business (Previous year H Nil).
ix) As on 31st March 2024, the Company has no Intra-group exposures with in the group companies as defined by RBI (Previous year H Nil).
x) Unhedged foreign currency exposure Refer Note 36.4.
Note 36.8: Registration obtained from financial sector regulators
NHB : vide registration number 01.0018.01
Ministry of Corporate Affairs : L65922DL1988PLC033856
Insurance Regulatory and Development Authority of India : CA0862
Note 36.9: Disclosure of Penalties imposed by NHB/RBI and other regulators:
During the financial year ended 31st March 2024, there is no penalty imposed by Regulators. However, during the financial year ended 31st March 2023, Regulators have imposed a penalty of H 0.08 crore for delay in appointment of Independent directors on Board pursuant to Regulation 17 (1) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
Note 36.13: Remuneration of Directors: Details of Remuneration of Directors are disclosed in Form No. MGT - 7.
Note 36.14: Management: Management Discussion and Analysis report shall be referred for the relevant disclosures.
Note 36.15: D uring the year, no transaction was accounted which was related to prior period (Previous year H Nil).
Note 36.16: During the year, no item of revenue recognition has been postponed except as disclosed in accounting policy for revenue recognition (Refer Note 2.3).
Note 36.17: Consolidated Financial Statements (CFS): Consolidated Financial Statements shall be referred for the relevant disclosures.
Note 36.19: Break-up of Loan & Advances and Provisions thereon:
The Company has complied with the norms prescribed by the regulator for recognising Non-Performing Assets (NPA) in preparation of accounts. As per the norms, NPAs are recognised on the basis of more than 90 days overdue. NPAs are to be treated as Bad & Doubtful, if they remain outstanding for more than 15 months. The Company has made adequate provisions on Non-Performing Assets and Standard Assets in respect of Housing and Non-Housing Loans as prescribed under directions issued by the regulator.
Note 36.30: As on 31st March 2024, the Company has not granted any loans and has no outstanding loans (Nil % of total assets) against collateral gold jewellery (Previous year H Nil).
Note 36.31: Deposit includes Public Deposits as defined in Paragraph 4.1.30 of RBI Directions, are secured by floating charge on the Statutory Liquid Assets maintained in terms of sub-sections (1) & (2) of Section 29B of the National Housing Bank Act, 1987. As on March 31, 2024, the public deposits (including accrued interest) outstanding amounts to H15,721.35 crore (excluding effective interest rate H15,822.00 crore) [Previous year H15,545.96 crore (excluding effective interest rate H15,654.74 crore)].
The Company is carrying Statutory Liquid Assets amounting to H2,388.95 crore (Previous year H2,276.42 crore).
Note 36.32: As on 31st March 2024, the Company operates within India and does not have any joint venture or overseas subsidiary.
(vi) Institutional set-up for liquidity risk management
The Board of Directors of the Company has constituted the Asset Liability Management Committee (ALCO) and the Risk Management Committee. The Board has the overall responsibility for management of liquidity risk. The Board decides the strategy, policies and procedures to manage liquidity risk in accordance with the liquidity risk tolerance/limits approved by it. The Risk Management Committee (RMC), which is a committee of the Board, is responsible for evaluating and monitoring the integrated risk management system of the Company including liquidity risk. The ALCO is responsible for ensuring adherence to the liquidity risk tolerance/limits set out in the Board approved Asset Liability Management (ALM) policy. The role of the ALCO with respect to liquidity risk includes, inter alia, decision on desired maturity profile for assets & liabilities, responsibilities and controls for managing liquidity risk and overseeing the liquidity position of the Company. The ALM Policy is reviewed periodically to realign the same pursuant to any regulatory changes or business needs and approved by the RMC and the Board.
Management regularly reviews the position of cash and cash equivalents by aligning the same with the projected maturity of financial assets and financial liabilities, economic environment, liquidity position in the financial market, anticipated pipeline of future borrowing & future liabilities and threshold of minimum liquidity defined in the ALM policy with additional liquidity buffers as management overlay.
(b) Disclosure pertaining to Liquidity Risk Management Framework for Housing Finance Companies A. Qualitative Disclosure
All deposit taking HFCs irrespective of their asset size, shall maintain a liquidity buffer in terms of Liquidity Coverage Ratio (LCR) which will promote resilience of HFCs to potential liquidity disruptions by ensuring that they have sufficient High Quality Liquid Asset (HQLA) to survive any acute liquidity stress scenario lasting for 30 days. The timeline on adhering to LCR guidelines are tabulated below.
*As per Master Direction - Reserve Bank of India (Non-Banking Financial Company - Scale Based Regulation) Directions, 2023 as on 1st December 2022 and 1st December 2023 Minimum LCR required is 70% and 85% respectively.
The objective of the LCR is to promote an environment wherein balance sheet carry a strong liquidity for short term cash flow requirements. To ensure strong liquidity NBFCs are required to maintain adequate pool of unencumbered HQLA which can be easily converted into cash to meet their stressed liquidity needs for 30 calendar days. 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 of the Company is managed by the ALCO under the governance of Board approved Liquidity Risk Framework comprising of Asset Liability Management policy, Contingency Funding Policy, Funding Strategy and Resource Mobilization Policy, and Market Risk Management Policy. The LCR levels for the balance sheet date is derived by arriving the stressed expected cash inflow and outflow for the next calendar month. To compute stressed cash outflow, all expected and contracted cash outflows are considered by applying a stress of 15%. Similarly, inflows for the Company is arrived at by considering all expected and contracted inflows by applying a haircut of 25%.
The main drivers of LCR are:
Outflows comprises of:
a) All the contractual debt repayments and interest payments
b) Expected operating expense based on FY 2022-23
c) Committed credit facilities contracted with customers for both sanctioned but partly disbursed cases and sanctioned but undisbursed cases based on historical experience and other expected or contracted cash outflows like expected payouts under contracted direct assignment deals.
The potential debt which may be recalled by the lenders on account of covenant breach has not been considered since the Company has not experienced such debt recall by any lender so far despite having breached covenants in the past.
Inflows comprises of:
a) Expected receipt (scheduled EMIs) from all performing loans
b) Liquid investment either in the form of short tenure Fixed Deposits with banks or in units of Debt Mutual Fund Schemes (like Overnight Liquid and Money Market Schemes) which are unencumbered and have not been considered as part
of HQLA
c) Sanctioned and undrawn lines of credit from banks.
For the purpose of HQLA the Company considers unencumbered government securities and cash/bank balances with nil haircuts.
The unencumbered government securities held as part of HQLA are identified separately from the government securities which are lien marked in favour of Trustee for public deposits accepted by the Company. The LCR is computed by dividing the stock of HQLA by its total net cash outflows over one-month stress period.
LCR guidelines are effective from 1st December 2021. LCR has been calculated and monitored as per methodology prescribed in the RBI circular. LCR has been calculated as a simple average of the total number of days in a quarter on daily basis. The Company is compliant with maintenance of stipulated LCR. Further, the Company has been monitoring the LCR at monthly intervals for the period of April 2023 to March 2024. The maximum and minimum daily required HQLA for regulatory compliance has been H299.51 crore and H1,591.42 crore respectively for the period of April'23 to March'24. The Company has maintained the daily average LCR of 105% for Financial Year 2023-2024.
The Company maintains diversified sources of funding comprising short/long term loans from banks, Non-Convertible Debentures (NCDs), External Commercial Borrowings (ECBs), Deposits, Refinance from National Housing Bank (NHB) and Commercial Papers (CPs). The funding pattern is reviewed on monthly basis by the management and on quarterly basis by the ALM Committee and Risk Management Committee.
Derivative exposures and potential collateral calls: To hedge ECBs and mitigate the Interest rate risk on NCDs, the Company enters into derivative transactions. All the derivatives of the Company are for hedging purpose and not for any speculative or trading purpose. As on 31st March 2024, the notional amount of outstanding derivatives is H3,275.44 crore (Previous year H10,065.79 crore) with net positive MTM of H135.01 crore (Previous year H 682.37 crore). Further, the Company has executed bilateral Credit Support Agreement with one of its derivative counterparty. As on 31st March 2024 there is no outstanding margin but there could be potential future margin calls based on the MTM movements H Nil (Previous year H22.33 crore).
Currency mismatch in LCR: There is no mismatch required to be reported in LCR as on 31st March 2024 and 31st March 2023 since all the Foreign Currency liabilities are reinstated to H as per the corresponding derivative/ forward deals and closing RBI reference / FBIL exchange rates.
The Company uses derivative financial instruments such as forwards and swaps to hedge its risks associated with foreign exchange fluctuation, price risk and interest rate movements. The fair values of all such derivative financial instruments are recognized as assets or liabilities at the balance sheet date.
Company's main business is to provide loans against/for purchase, construction, repairs & renovations of Houses/ Flats/ Commercial Properties etc. All other activities of the Company revolve around the main business. As such, there are no separate reportable segment, as per the Operating Segments (Ind AS 108), notified by the Companies (Accounting Standard) Rules, 2015. The Company operates within India and does not have operations in economic environments with different risks and returns, hence it is considered operating in single geographical segment.
The Company is not reliant on revenues from transactions with any single external customer and does not receive 10% or more of its revenues from transactions with any single external customer.
Note 40: Contingent Liabilities and Commitments
i) Contingent liabilities in respect of Income-tax of H56.01 crore (Previous year H56.01 crore) is disputed and are under appeals. This includes contingent liability of H1.96 crore (Previous year H1.96 crore) with respect to Income-tax which have been decided by the ITAT in Company's favour. However, Income-tax Department has filed appeal with Delhi High Court. The Company expects the demands to be set aside by the Delhi High Court and appellate authority, hence no additional provision is considered necessary.
ii) Contingent liabilities in respect of Goods and Service Tax of H0.47 crore (Previous year H Nil) is disputed and appeals has been filed for H0.33 crore. Further the Company in the process of filing of appeal H0.14 crore. The Company expects the demands to be set aside by the appellate authority, hence no additional provision is considered necessary.
iii) Estimated amount of contracts remaining to be executed on capital account and not provided for (net of advances) is H20.23 crore (Previous year H21.51 crore).
iv) Claims against the Company not acknowledged as debt is H1.20 crore (Previous year H0.43 crore)
v) Company had issued corporate financial guarantee amounting to H22.19 crore (Previous year H0.25 crore) to "National Stock Exchange of India Ltd" and "UNIQUE IDENTIFICATION AUTHORITY OF INDIA (UIDAI)’’ in relation to Rights Issue of the Company and Aadhar Authentication Services respectively.
Note 41: Disclosure in respect of Employee Benefits:
In accordance with Indian Accounting Standards on "Employee Benefits" (Ind AS 19), the following disclosure have been made: Defined Contribution Plans:
Note 41.1: The Company makes contributions towards provident fund to a defined contribution retirement benefit plan for qualifying employees. Under the plan, the Company is required to contribute a specified percentage of payroll cost to the retirement benefit plan to fund the benefits. The contribution has been recognised in the Statement of Profit and Loss which are included under "Contribution to Provident Fund and Other Funds" in Note 31.
Note 41.2: Defined Benefit Plans
The Company has a defined benefit gratuity plan. Every employee is entitled to gratuity as per the provisions of the Payment of Gratuity Act, 1972. The scheme is funded and the same is managed by Life Insurance Corporation of India. The liability of Gratuity is recognised on the basis of actuarial valuation.
The most recent actuarial valuation of plan assets and the present value of the defined benefit obligation for gratuity were carried out as at 31st March 2024. The present value of the defined benefit obligations and the related current service cost and past service cost, were measured using the Projected Unit Credit Method.
Risks associated with defined benefit plan
Interest rate risk: A fall in the discount rate, which is linked to the Government Securities rate, will increases the present value of the liability requiring higher provision. A fall in the discount rate generally increases the mark to market value of the assets depending on the duration of asset.
Salary Risk: The present value of the defined benefit plan liability is calculated by reference to the future salary of members. As such, an increase in the salary of the members more than assumed level may increase the plan's liability.
Mortality risk: Since the benefits under the plan is not payable for life time and payable till retirement age only, plan does not have any longevity risk.
Note 44.3: Quarterly returns/statements of current assets filed with banks or financial institutions against the underlying borrowings are in agreement with the books of accounts (principal outstanding).
Note 45: Maturity analysis of assets and liabilities
The table below shows an analysis of assets and liabilities analysed according to when they are expected to be recovered or settled. However, with regard to loans and advances to customers and investments, the Company has used the contractual maturities for recovery/settlement. Borrowings (including debt securities and deposits) are reflected basis the contractual maturities.
The Company has formulated a comprehensive enterprise risk management policy to take care of major risks, such as credit risk, market risk, liquidity risk. The Company has an integrated risk management policy (IRM) in place, which communicates the risk management strategy, framework, and risk processes across the organisation, and has been approved by the Board. The risk management framework broadly includes governance, risk appetite approach, risk-specific guidelines, risk measurement, mitigation, monitoring reporting, and key risk indicators (KRIs). The Company has developed a clearly articulated risk appetite statement, functional policies, and KRIs to explicitly define the level and nature of risk that an organisation willing to take in order to pursue the articulated mission on behalf of various stakeholders. The Board has delegated the responsibility of risk management to its risk management committee (RMC), which reviews the efficacy of our risk management framework, provides important oversight, and assesses whether it is consistent with the risk tolerance levels laid down. The RMC gives directions to executive risk management committee (ERMC), comprising senior management.
Note 46.1: Credit Risk
The Company's asset base comprises of retail loans and corporate loans.
Retail loans mainly focusses on financing of acquisition or construction of houses that includes repair, upgradation, and development of plot of land. In retail loans category, the Company also provides loan against properties and loans for purchase & construction of non-residential premises.
Corporate finance loans are given mainly to developers for financing the construction of residential / commercial properties, i.e. construction finance loans, and for general corporate purpose loans. i.e. corporate term loans and lease rental discounting loans.
Being in the lending domain, credit risk is one of the major risks in the business model of the Company. Credit risk stems from outright default due to inability or unwillingness of a customer or counterparty to meet the contractual commitments.
The essence of credit risk management in the Company pivots around the early assessment of stress, both at a portfolio and account level, and taking appropriate measures.
Credit Risk Management
Credit risk of the Company is managed through a robust Credit Risk Management set-up at various levels. Given the pervasiveness of credit risk in the Company's line of business, the Board and the senior management consider credit risk management to be an integral part of the organisational strategy. The Board has constituted a Risk Management Committee (RMC) that owns the risk management framework. The RMC oversees the Risk Management practices and gives direction to the Executive Risk Management Committee (ERMC), comprising of the MD and CEO along with functional heads, in implementing the risk management framework and policy. The policies and procedures have been drafted in close consultation with process owners, ERMC and RMC.
The risk management function is led by the Chief Risk Officer who is independent and has direct access to the RMC.
The Company's Risk Framework for credit risk management is mentioned below:
1) Established an appropriate credit risk environment
The Company has developed credit risk strategy which reflects its risk tolerance and level of profitability it expects to achieve. The execution of strategy is done through policies, guidelines and processes supervised by team of experienced professionals in the mortgage business.
2) Ensure sound credit approval process
The Company's Target Operating Model (TOM) primarily comprises of Hub and Spoc structure, advanced technology platform, experienced and specialized professionals and mark to market policies and products. The Company's TOM allows to manage various type of risks in a better manner which in turn helps building a robust portfolio.
The Company has clear segregation of duties between transaction originators in the business function and approvers in the credit risk function. Spoc or branch act as the primary point of sale, undertake loan originations, collection, deposit sourcing and customer service. Hubs perform functions, such as loan processing, credit appraisal and monitoring through subject matter experts comprising team of underwriters, fraud control unit, legal counsels, and technical evaluators.
The credit sanction is done through a well-defined delegation matrix under four eye principle. All functions are subject to audit, undertaken by an independent team directly reporting to the Board.
Hubs and Spocs are supported by Central Support Office (CSO), Centralised Operations (COPS) and Central Processing Centre (CPC).
3) Maintains an appropriate credit administration, measurement and monitoring process
Policies and procedures have been developed for identifying, measuring, monitoring and mitigating credit risk. Portfolio monitoring allows a proactive approach to identify, at an early stage, credit quality deterioration. A system of independent, periodical reviews of the Company's credit risk management process is established and the results of such reviews are communicated across the levels for corrective actions as applicable. The excpected credit loss on financial instruments has been presented in respective note.
Adequate controls are in place to ensure that the credit approval function is being properly managed and that credit exposures are within levels consistent with prudential standards and internal limits.
Note 46.2: Derivative Financial Instruments
Credit risk arising from derivative financial instruments is, at any time, limited to those with positive fair values, as recorded on the balance sheet.
Note 46.4: Market Risk
Market risk is the risk that the fair value or future cash flows of financial instruments will fluctuate due to changes in market variables such as interest rates, foreign exchange rates and equity prices. The Company monitors such changes and presents to the management on a regular basis. It undertakes scenario analysis as well as other techniques like earnings at risk to quantify the expected impact upon the change of market variables. The Board approved investment policy defines the overall exposure limits and specific limits pertaining to the exposure to a particular entity /counterparty as well as type of securities.
46.4.2 Interest rate risk
Interest rate risk arises from the possibility that changes in interest rates will affect future cash flows or the fair values of financial instruments. The Board has established limits on interest rate sensitive assets and interest rate sensitive liabilities. The Company's policy is to monitor positions on a regular basis and hedging strategies are used to ensure positions are maintained within the established limits.
46.4.3 Currency risk
Currency risk is the risk that the value of a financial instrument will fluctuate due to changes in foreign exchange rates. Foreig currency risk arises majorly on account of foreign currency borrowings which are primarily in US dolllar ($). The Company manages its foreign currency risk by entering into cross currency swaps and forward contracts. When a derivative is entered into for the purpose of being as hedge, the Company negotiates the terms of those derivatives to match with the terms of the hedge exposure.
Currently, the Company is exposed to currency risk by virtue of its ECBs. But, the Company has undertaken hedging and mitigate such risk.
The following table assesses the sensitivity of the assets and liabilities over the profit and loss and other comprehensive income with change in currency rates.
Note 46.4.4: Equity price risk :
The Company's investment in non-listed equity securities are accounted at cost in the financial statement net of impairment (if any). The expected cash flow from these entities are regularly monitored to identify impairment indicators.
Note 46.5: Liquidity risk and funding management
Liquidity risk is defined as the risk that the Company will encounter in meeting obligations associated with financial liabilities that are settled by delivering cash or another financial asset. Liquidity risk arises because of the possibility that the Company might be unable to meet its payment obligations when they fall due as a result of mismatches in the timing of the cash flows
under both normal and stress circumstances. Such scenarios could occur when funding needed for illiquid asset positions is not available to the Company on acceptable terms. To limit this risk, management has arranged for diversified funding sources and investors in addition to its core deposit base, also adopted a policy of managing assets with liquidity in mind and monitoring future cash flows and liquidity on a regular basis. The Company also keeps lines of credit and liquid investments that it can access to meet liquidity needs. The lines of credit are from various banks and institutions. The liquid investments are kept in liquid mutual funds, fixed deposits, liquid bonds, government securities etc., limits of which are defined as per investment policy based on the type of security, rating of entity and instrument. In accordance with the Company's policy, the liquidity position is assessed under a variety of scenarios. The Company follows both stock and flow approaches to monitor and asses the liquidity position. Moreover, the Compnay keeps a track of the expected funds inflows and outflows along with the avenues of raising the funds. This incorporates an assessment of expected cash flows and the availability of high grade collateral which could be used to secure additional funding if required.
The Company has a Board approved Asset and Liability Management (ALM) policy. The policy has constituted an Asset and Liability Committee (ALCO) which meets at regular intervals and review the asset liability profile both at the particular time bucket level and cumulative level as well as the interest rate profile of the Company. The policy also defines the limits on such monitored items and these are further presented to the Board for information and further action, if any. Apart from the regulatory defined tools, the Company has voluntarily instituted various liquidity parameters that are presented to the ALCO and further to the Board. Moreover, the position of liquidity is presented to the Risk Management Committee of the Board.
(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 observable or estimated using a valuation technique.
For determination of fair value, financial instruments are classified based on a hierarchy of valuation techniques, as summarised below:
Level 1: Those where the inputs used in the valuation are unadjusted quoted prices from active markets for identical assets or liabilities that the Company has access to at the measurement date. The Company considers markets as active only if there are sufficient trading activities with regards to the volume and liquidity of the identical assets or liabilities and when there are binding and exercisable price quotes available on the balance sheet date.
Level 2: Those where the inputs that are used for valuation are significant and are derived from directly or indirectly observable market data available over the entire period of the instrument's life. Such inputs include quoted prices for similar assets or liabilities in active markets, quoted prices for identical instruments in inactive markets and observable inputs other than quoted prices such as interest rates and yield curves, implied volatilities and credit spreads. In addition, adjustments may be required for the condition or location of the asset or the extent to which it relates to items that are comparable to the valued instrument.
Level 3: Those that include one or more unobservable input that is significant to the measurement as whole.
(b) Valuation governance
The Company's fair value methodology and the governance over its models includes a number of controls and other procedures to ensure appropriate safeguards are in place to ensure its quality and adequacy. All new product initiatives and their valuations are subject to approvals by related functions of the Company.
(c) Assets and liabilities by fair value hierarchy
The following table shows an analysis of financial instruments recorded at fair value by level of the fair value hierarchy
Valuation methodologies of financial instruments measured at fair value
Below are the methodologies and assumptions used to determine fair values for the above financial instruments which are recorded and measured at fair value in the Company's financial statements.
1. Debt securities
The Company's debt instruments are standard fixed rate securities.The Company uses market prices whenever available, or other observable inputs to estimate the corresponding fair value. These Corporate bonds are generally Level 2 instruments.
2. Derivative financial instruments Interest rate derivatives
For Interest rate derivatives Company has interest rate swaps and cross currency swaps. The valuation techniques are the mark to market positions with forward pricing on the swap models using present value calculations by estimating future cash flows and discounting them with the appropriate yield curves like the OIS yield curve. These contracts are generally Level 2 unless adjustments to yield curves or credit spreads are based on significant non-observable inputs, in which case, they are Level 3.
Foreign exchange contracts
Foreign exchange contracts include spot contracts, foreign exchange forward and swap contracts. However, the Company has not entered into any foreign exchange options. These instruments are valued by either observable foreign exchange rates, observable or calculated forward points and option valuation models. Company classifies these foreign exchange contracts as level 2.
3. Security Receipt in ACRE 122 trust
The Company has invested in security receipt whereby the valuation is based on the underlying ratings of the security.
The Company classifies these investments as Level 3.
Valuation methodologies of financial instruments not measured at fair value
Below are the methodologies and assumptions used to determine fair values for the above financial instruments which are not recorded and measured at fair value in the Company's financial statements.
1. Financial assets and liabilities (Short term)
Cash and cash equivalents, bank balances other than cash and cash equivalents, trade receivables, other financial assets, trade payables, commercial papers and other financial liabilities has been recognised at amortised cost in the financial statements.
In accordance with Ind AS 107.29(a), fair value is not required to be disclosed in relation to the financial instruments having short-term maturity (less than twelve months), where carrying amount (net of impairment) is a reasonable approximation of their fair value. Hence the fair value of cash and cash equivalents, bank balances other than cash and cash equivalents, trade receivables, other financial assets, trade payables, commercial papers and other financial liabilities has not been disclosed.
2. Financial assets
Loans and advances to customers
Substantial amount of the loans are based on floating rate of interest,carrying amount of which represents the fair value of these loans. Minuscule amount of loans are based on fixed to floating rate of interest, the fair values of these loans are computed by discounted cash flow models incorporating prevalling interest rate.The Company classifies these assets as Level 2.
Government debt securities
Government debt securities are financial instruments issued by sovereign governments and include both long- term bonds and short-term bills with fixed or floating rate interest payments. These instruments are generally liquid and traded in active markets resulting in a Level 1 classification. When active market prices are not available, the Company uses observable market inputs of similar instruments and bond prices to estimate future index levels and extrapolating yields outside the range of active market trading, in which instances the Company classifies those securities as Level 2. The Company does not have Level 3 government securities where valuation inputs would be unobservable.
3. Financial liabilities
Debt securities and Subordinated liabilities
Debt securities and subordinated liabilities are generally liquid and traded in active markets resulting in a Level 1 classification. When active market prices are not available, the Company uses observable market inputs of similar instruments and bond prices to estimate future index levels and extrapolating yields outside the range of active market trading, in which instances the Company classifies those securities as Level 2.
Deposits
The fair values of deposits are computed by discounted cash flow models that incorporates prevalling interest rate. The Company classifies these liabilities as Level 3.
Financial assets or liabilities other than those mentioned above resembles the value approximate to their fair value.
(e) There have been no transfers among Level 1, Level 2 and Level 3, during the year ended March 31, 2024, and March 31, 2023.
Note 48: Other disclosures:
(i) There is no income which is required to be recorded in the books of accounts that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961.
(ii) The Company has not been declared willful defaulter by any Banks/Financial Institutions.
(iii) The Company has not traded or invested in Crypto currency or Virtual currency during the year.
(iv) There are no proceedings which have been initiated or pending against the Company for holding any benami property under the Prohibition of Benami Properties Transactions Act, 1988 and the rules made thereunder.
(v) Disclosure in relation to Struck off Companies:
(vi) The Company has not advanced or loaned or invested funds (either borrowed funds or share premium or any other sources or kind of funds) 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:
(a) 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
(b) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries;
(vii) The Company has not received any funds from any other person(s) or entity(ies), including foreign entities (Intermediaries) with the understanding (whether recorded in writing or otherwise) that the Company shall:
(a) 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
(b) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries;
(viii) The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India and the Group has no CICs as part of the Group.
(ix) The Company has not entered into Scheme of Arrangement in terms of section 230 to 237 of the Company Act, 2013.
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