Daily Loan Interest Calculation Standardisation 33-41 LOW ER MOUNT STREE T DUBLIN 2 Standard for Daily Loan Interest Calculation Requirements Specification Issued: May 2007 Updated: February 2008 Page 1 of 13 v4 Daily Loan Interest Calculation Standardisation Contents CONTENTS ..................................................................................................... 2 INTRODUCTION ............................................................................................... 3 DAILY LOAN INTEREST CALCULATION .............................................................. 4 PROCESSING REQUIREMENTS .......................................................................... 5 FURTHER INFORMATION ................................................................................ 11 APPENDIX 1 - WEEKLY VS DAILY INTEREST CALCULATION ............................... 12 APPENDIX 2 – DAILY LOAN INTEREST CALCULATION - WORKED EXAMPLE ........ 13 Page 2 of 13 v4 Daily Loan Interest Calculation Standardisation Introduction Currently there is no standardisation across the credit union movement in respect of loan interest calculations. Historically, going back to the days of manual interest calculations by staff and volunteers, a simple weekly interest calculation was adopted for loans. Despite significant improvements in systems and technology over the past two decades, weekly loan interest calculations are still used in many credit unions today. This weekly loan interest calculation basis does not conform to financial industry norms and is less desirable from a consumer point of view. Current best practice in lending suggests that loan interest is calculated on a daily basis which is generally considered to be the fairest calculation method. This specification provides IT supplier personnel with the information and business rules necessary to develop and implement standard daily loan interest calculations. The Irish League of Credit Unions proposed a motion to BDM 2007 to require all credit unions to adopt and implement these new standards by 1/10/2007 and bring credit unions more in line with industry norm interest calculations today. This motion was passed overwhelmingly by the movement. Page 3 of 13 v4 Daily Loan Interest Calculation Standardisation Daily Loan Interest Calculation How it works? The proposed standard suggests that interest due, or more correctly called interest accrued, is calculated and accumulated on a daily basis in accordance with the following formula:- [Int. Accr’d=(Current Loan Bal. x No. Days x Int. Rate)/(No. Int. Days in Yr x 100)] The resulting interest accrued is rounded in accordance with normal rounding rules ie if the decimal part is greater than or equal to 0.xx5 round up to the nearest cent/pence otherwise round down. By performing the full calculation in a single formula calculation and rounding at the end this minimises rounding errors eg. with an interest rate of 10% and a loan balance =£/€981.10. 4 days interest =(981.10 x 4 x 10.0)/(365 x 100)= 1.07517808219. This is rounded up to €1.08 / £1.08. Note:- It is not proposed that loan interest calculated is capitalised ie interest is not charged on unpaid interest due. Where interest accrued remains unpaid following a transaction on a members account, this unpaid interest is added to the members Interest Arrears balance. Total interest due for a member is calculated as follows: [ Total Interest Due = Interest Accrued + Interest Arrears ] Note: The remainder of this report refers only to the calculation of Interest Accrued, however Total Interest Due is obtained from the above formula. Page 4 of 13 v4 Daily Loan Interest Calculation Standardisation Processing Requirements Interest due is calculated and updated to the members account on a daily basis. The interest period for the purpose of the loan amortization and cost of credit calculation is the loan repayment period ie weekly, monthly etc. Disregard previous interest rate tables and calculators issued or made available utilising alternative calculations/formulae. If you are unsure as to the validity of previous documentation received or are unclear as to League recommendations in regard to already available interest calculation tools please contact the League for clarity. Req 1.0 Daily Interest Loan Calculation The system must calculate Interest on a daily basis using the following formula: [Int. Accr’d=(Current Loan Bal. x No. Days x Int. Rate)/(No. Int. Days in Yr x 100)] Req 1.1 Interest Loan Calculation Rounding The system must perform rounding on the interest calculation as follows: If the interest calculation is greater than or equal to 0.xx5, then round up the nearest cent/pence. If the interest calculation is less than 0.xx5, then the value must be rounded down the nearest cent/pence. Req 1.2 APR Calculation The (Actual/Actual) Day Count must be used at all times in APR calculations. The value for Actual is 365 for a normal year and 366 for a leap year Req 1.2.1 Leap Year APR Calculation In a leap year, the system must calculate interest using the formula (Actual/Actual). The “Actual” day count for a leap year is 366. Where there is a crossover interest calculation period from a leap year to a normal year or from a normal year to a leap year, the interest calculation must done for the old and new years separately. The two un-rounded interest due amounts must then be added together and rounded after the addition using normal rounding rules. Req 1.3 Interest Rate Change When the loan interest rate changes within an interest calculation period, the system must complete the interest calculation for that period at the old and new interest rates separately. The two unrounded interest due amounts for the different interest rate periods Page 5 of 13 v4 Daily Loan Interest Calculation Standardisation must then be added together and rounded using normal rounding rules at the end. Req 1.4 Loan Interest is Not Capitalised The system must not capitalise loan interest at any time over the term of a credit union loan ie interest is not charged on unpaid interest due. Where interest accrued remains unpaid following a transaction or incident on a members account, this unpaid interest is added to the members Interest Arrears balance. Req 1.5 Total Interest Due Calculation The system must calculate the Total Interest Due by a member as follows: [ Total Interest Due = Interest Accrued + Interest Arrears ] Loan Interest Rebate Many credit unions refund a portion of loan interest collected from borrowing members annually. This processing takes place at the same time as the dividend posting following financial year end. The rate of loan interest rebate must be ratified by the members at credit union AGM. A percentage of loan interest paid by the member is paid in the form of an interest rebate if applicable. Req 2.0 Accumulated Loan Interest Paid by Members The system must accumulate the loan interest paid by each member separately for the credit union financial year ending 30th September and the tax year 31st December. The system must use the loan interest paid in the credit union financial year as the basis for the calculation of the loan interest rebate for the last year ended Req 2.1 The system must calculate the Interest Rebate Calculation using the following formulae [Loan Int. Rebate = (Total Loan Interest Paid in Fin. Yr) x Rebate % ] Eg. Total loan interest paid in the last financial year is €352.22 with 20% interest rebate payable. The interest rebate calculated is €70.44. Normal rounding rules apply here also Page 6 of 13 v4 Daily Loan Interest Calculation Standardisation Req 2.2 Borrowing Members If the credit union pays an interest rebate to members, then all members loans where interest was paid during the last financial year will qualify for a rebate including members with loans that were fully repaid during the last financial year but who also paid loan interest during that financial year Req 2.3 Recording Loan Interest and Loan Interest Rebate Commencing from 1st October 2007, credit union systems must calculate and store the total loan interest paid for each loan account for each financial year (commencing 1st October) and separately for each tax year (commencing 1st January). Loan interest rebates paid to members for each loan account within each tax year must also be recorded. Req 2.4 Certificates of Interest Paid The loan interest amount shown on Certificates of Interest for qualifying loans must be calculated by the system using the total loan interest paid within the appropriate tax year less any loan interest rebate refunded to the member within the same tax year in respect of that loan. Clearing of Funds Systems and processing must be in place to manage uncleared as well as cleared funds in accordance with each individual credit union policy. Consider the situation where a member cheque is received as a loan repayment and subsequently posted against the members loan account. The funds associated with cheque received by the credit union may not be cleared by the banking system for up to 5 days. During the cheque clearing period the credit union may not be earning deposit interest from their bank in respect of these funds. The credit union may or may not want to effect the lodgement/loan repayment to the members loan balance until the funds have been cleared by the banking system. Immediate posting of uncleared funds at the credit union will result in a loss or reduction of interest income for the bank clearing period. Heretofore from a loan interest calculation point of view, most credit unions did not distinguish between cleared and uncleared funds as interest calculations were typically done on a weekly basis. This calculation frequency allowed sufficient time for cheques and other funds to be cleared. With daily loan interest calculations, credit unions must decide whether or not they are willing to pass the cost of the potential loss of credit union deposit Page 7 of 13 v4 Daily Loan Interest Calculation Standardisation interest income and loan interest income on uncleared balances to the members lodging these uncleared funds. It is recognised that some credit unions will process cleared and uncleared funds in the same manner though others may not. If the policy of a credit union is to treat uncleared funds differently to cleared funds then the credit union IT processing system must be capable of managing uncleared funds in accordance with policy. Req 3.0 Cleared and Uncleared Funds Tracking IT processing systems must be enabled to identify, track and manage cleared and uncleared fund transactions. Credit unions typically offer a standing order loan repayment or lodgement option to their members in respect of lodgement of funds. In this case funds are transferred electronically from the members bank account to the credit unions bank account. Credit unions receive notice of these lodgements(cleared funds) through their Internet Business Banking package supplied by their bank or through bank statements received. Req 3.1 Standing Orders and Exceptions Posting The system must post, cleared funds lodged in respect of member payments to credit union bank accounts, to the destination member accounts no later than next day following value received by the credit union to their bank. Queries in respect of unapplied credits must be reported on and followed up the same day the query arises. Req 3.2 Funds Clearing Periods The credit union IT system must record the number of days required to clear funds in respect of the transaction types to be processed. These “number of days” values will be used by the IT system in automatically clearing member funds. Once the clearing period for funds has elapsed, un-cleared funds will be processed as cleared funds Req 3.3 Same Treatment for Cleared and Uncleard Funds If credit union policy suggests that there is no special treatment for transactions containing un-cleared funds, then the system must process such transactions as if the funds were cleared funds Page 8 of 13 v4 Daily Loan Interest Calculation Standardisation Req 3.4 No Funds Value for Clearing Period If credit union policy suggests that members will not receive value for their funds lodged for the clearing period, then the system must post uncleared funds transactions to effected member account balances next day following the completion of the specified clearing period for that transaction type. This applies to funds received by cheque and electronically Bounced Cheque and Unpaid Direct Debit Treatment Systems must be capable of efficiently processing the cancellation of bounced cheques or unpaid direct debit lodgements in accordance with credit union policy. Systems must provide for controlled and automated processing of loan interest due adjustments where applicable in respect of lodgements of uncleared funds. Req 3.5 Reversal of Bounced Cheques and Treatment of Unpaids If credit union policy suggests that funds value will be not be given to members for the clearing period in respect of bounced cheques or unpaid direct debits, the IT processing system must automatically re-adjust the loan/deposit interest value in respect of necessary transaction reversals as a result of such bounced cheques or electronic unpaid direct debits. Interest adjustment values must be calculated in accordance with this standard as follows: [Int. Adj.={(Cur Loan Bal+Cancel’d Prin Amt) x No. Days x Int. Rate}/(No. Int. Days in Yr x 100)] [ Corrected Int. Arrs= (Existing Int. Arrears + Int. Adj.) ] A worked example is shown in Appendix 2. In this example a loan and interest repayment is made on 5/10/06 by cheque. This transaction was immediately effected against the members loan balance. Subsequently the cheque bounced and a transaction reversal was effected on 10/10/06. This reversal had the effect of increasing the loan balance to£/€1,000, an increase of £/€18.90 to be applied retrospectively back to 5/10/06. Assuming a loan interest rate of 10% the additional loan interest due as a result of this reversal for the 5 day period is Interest Adjustment= {(981.10+18.90)*5*10}/(365*100)=1.36986301369. This value is rounded using normal rounding to £/€1.37. Page 9 of 13 v4 Daily Loan Interest Calculation Standardisation Corrected Total Interest Arrears is calculated by adding the interest adjustment amount to the existing interest arrears amount ie 1.37+1.10= £/€2.47. General Auditing Requirements Req 3.6 Auditing of Adjustments The system must be controlled and fully traceable through electronic and paper audit trails for all transaction cancellations and adjustments including loan interest due adjustments. Req 3.7 Loan Interest Rates Recording The credit union IT system must be available to readily provide the loan interest rate charged on any loan currently or historically to authorised credit union personnel and audit staff without the need for making special arrangements with IT providers. Page 10 of 13 v4 Daily Loan Interest Calculation Standardisation Further Information Should you have any queries or require further information in relation to implementing the new standard interest calculation basis contact the League Name: Joe Timmons Email: jtimmons@creditunion.ie Telephone: +353 1 6146968 Page 11 of 13 v4 Daily Loan Interest Calculation Standardisation Appendix 1 - Weekly vs Daily Interest Calculation Assumptions: Weeks commence on Mondays. Loan issued for 1000 on 1/10/06 with weekly repayment of 20 (inclusive of interest). Loan interest rate of 10% applies. 1. Weekly Interest Calculation Interest Rate 10% (Apr 10.5%) Weekly Rate Factor = 0.00191650 Days Opening Wk Transaction Interest Loan No. Date Due Bal. 1 02/10/2006 7 1000.00 1 05/10/2006 0 1000.00 2 09/10/2006 7 981.91 2 12/10/2006 0 981.91 3 16/10/2006 7 963.79 4 23/10/2006 7 963.79 4 29/10/2006 0 963.79 Opening Interest 0 1.91 0.00 1.88 0.00 1.84 3.68 Total Repay Amt 0 20 0 20 0 0 0 Principal Repay Amt 0 18.09 0 18.12 0 0 0 Closing LoanBal. 1000.00 981.91 981.91 963.79 963.79 963.79 963.79 Closing Interest 1.91 0 1.88 0 1.84 3.68 3.68 Total (Level) Payments Made to 29/10/2006 = 40.00 Total Interest Charged to 23/10/2006 = 7.47 Total Interest Charged to 29/10/2006 = 7.47 Total Principal Repaid to 29/10/2006 = 36.21 Transaction Description Interest due wk1 Repayment made wk1 Interest due wk2 Repayment made wk2 Interest due wk3 Interest due wk4 Balances at end wk4 Compare the same example as shown above with daily loan interest calculation 2. Daily Interest Calculation (Standard Daily Basis) Interest Rate 10% (Apr 10.5%) I=(Rate/365x100)x Loan xDays Days Wk Transaction Interest No. Date Due 1 02/10/2006 1 day 1 05/10/2006 4 days 2 09/10/2006 4 days 2 12/10/2006 7 days 3 16/10/2006 4 days 4 23/10/2006 11 days 4 29/10/2006 17 days Opening Loan Bal. 1000.00 1000.00 981.10 981.10 962.98 962.98 962.98 Opening Interest 0 1.10 1.08 1.88 1.06 2.90 4.49 Total Repay Amount 0 20 0 20 0 0 0 Principal Repay Amount 0 18.90 0 18.12 0 0 0 Closing LoanBal 1000.00 981.10 981.10 962.98 962.98 962.98 962.98 Closing Interest 0.27 0 1.08 0 1.06 2.90 4.49 Total (Level) Payments Made to 29/10/2006 = 40.00 Total Interest Charged to 23/10/2006 = 5.88 Total Interest Charged to 29/10/2006 = 7.47 Total Principal Repaid to 29/10/2006 = 37.02 Page 12 of 13 v4 Transaction Description Interest due for 1 day Repayment made wk1 Interest due for 4days Repay wk 2 Interest due for 4days 11 days interest due Balances at end wk4 Daily Loan Interest Calculation Standardisation Appendix 2 – Daily Loan Interest Calculation - Worked Example Date (Oct Loan 2006) Balance 1 0.00 2 1,000.00 3 1,000.00 4 1,000.00 5 1,000.00 6 981.10 7 981.10 8 981.10 9 981.10 10 981.10 11 1,000.00 12 1,000.00 13 981.88 14 981.88 15 981.88 16 981.88 17 981.88 18 981.88 19 981.88 20 981.88 21 963.88 22 963.88 23 963.88 24 1,963.88 25 1,963.88 26 1,963.88 27 1,963.88 28 1,963.88 29 1,963.88 Interest No. of calculatio Days n today Interes (including t Due interest Today arrears) 0 1 0.27 2 0.55 3 0.82 4 1.10 1 0.27 2 0.54 3 0.81 4 1.08 5 1.34 1 2.74 2 3.02 1 2.09 2 2.36 3 2.63 4 2.90 5 3.17 6 3.43 7 3.70 8 3.97 1 2.23 2 2.50 3 2.76 1 3.30 2 3.84 3 4.37 1 4.85 2 5.34 3 5.82 Interest calculation yesterday (including interest arrears) 0.00 0.27 0.55 0.82 1.10 0.27 0.54 0.81 1.08 2.47 2.74 3.02 2.09 2.36 2.63 2.90 3.17 3.43 3.70 3.97 2.23 2.50 2.76 3.30 3.84 4.37 4.85 5.34 Interest Interest Arrears due for (Included today (1 in Int days Interest Calc. interest Paymen Principa Today Loan only) t Made l Repaid figure) Issued 1,000.00 Interest due for 2nd 0.27 0.28 Full chq interest payment 0.27 0.28 1.10 18.90 0.00 0.27 0.00 0.27 Reversal of txn of 0.00 0.27 5/10(after daily int.calc 0.00 0.27 done) 0.00 0.26 -1.10 -18.90 2.47 Interest 0.27 2.47 Adjustment 0.28 1.20 18.12 1.82 Calculation 0.27 1.82 0.27 1.82 0.27 1.82 Partial Interest 0.27 Payment 1.82 0.27 1.82 0.26 Partial Interest 1.82 Payment 0.27 1.82 0.27 2.00 18.00 1.97 0.26 1.97 0.27 1.97 0.26 2.76 1,000.00 Top-Up Loan 0.54 2.76 issued on 23rd 0.54 2.76 0.53 4.37 0.48 4.37 Interest Rate Change to 0.49 4.37 9% on 27th before daily 0.48 interest calc 4.37 Total Interest Due on 29th Calculations are based on an interest rate of 10% within a 365 day year) Page 13 of 13 v4