Impact of IFRS on Housing Finance Companies 29th CEO’S Meeting of HFCs Presentation By Mr Keki Mistry March 17, 2010 1 Contents • Fundamental difference between IFRS and Indian Accounts • Proposed Convergence Path • Regulatory Alignment • Significant Impacts for HFCs 2 Fundamental Difference between IFRS and Indian Accounts • Indian Accounts are prepared on the basis of historical cost and prudence • IFRS reports certain item of Assets and Liabilities at Fair Value and not at Original Cost 3 Proposed Convergence Path • Commencement date 1st April 2011 reiterated by MCA • Phases suggested by MCA for convergence • Phase 1: Nifty 50 and Sensex 30 companies, Companies listed outside India, Companies with over Rs 1000 crore networth • Phase 2: All companies (listed and unlisted) with networth between Rs 500 crores and Rs 1000 crores • Phase 3: All listed companies with networth below Rs 500 crores • Changes proposed in Companies Act sent to MCA • 2 set of Accounting Standards suggested • 1st set that converge with IFRS • 2nd set that carries the existing standards 4 Regulatory Alignment • Income Tax Act – Treatment of Fair Value gains and losses – Impact of Fair Value changes for Asset Based Taxation • NHB Regulations – Guidelines on provisioning and income recognition • Companies Act – Amendments suggested for Schedule VI and XIV – Certain Sections are also being amended • Accounting Standards – Most significant change in the standard on Financial Instruments • Derivatives • Investments – Fixed Income and Equity 5 Changes in the Companies Act - 1 • Dividend (Section 205) – Allows Dividends out of PROFITs for the year – Under IFRS certain PROFITs may go to Reserves • Legal confirmation for certain transactions – Amalgamation and Reconstruction require ratification by the courts/ tribunals (Sections 391 to 394) before they can be incorporated into the accounts – Under IFRS, date of acquiring the control is the trigger point 6 Changes in the Companies Act - 2 • Funding growth thru debt (Section 78) – Premium on Redemption of Debentures is allowed to be debited to Share Premium – Under IFRS this has to be debited to P&L • Treasury Stock – Buyback of its own stock leads to reduction in the capital of the company (Section 100) – Under IFRS this is permitted to be held as Treasury Stock 7 Changes in the Companies Act - 3 • Other Comprehensive Income – This concept does not exists in Indian Accounting – Under IFRS, certain Income and Expenses are recognised directly in Shareholder’s equity under the head Other Comprehensive Income e.g. Fair value changes in equity/ derivatives 8 Changes in Schedules (under Companies Act) • Depreciation (Schedule XIV) – Useful life is limited by the Act, higher life not allowed – Under IFRS, useful life is a management estimate • Presentation of Income Statement (Schedule VI) – Currently as per specified format – Under IFRS no format is prescribed • Presentation of Balance Sheet (Schedule VI) – Formats specified. Specific formats for Banks and Insurance – Under IFRS, items are classified into Current and Non Current 9 Accounting for Derivatives • Derivatives have to be Fair Valued (FV) • MTM Gains and Losses recognised in PL unless proved as hedge • Hedge is proved if [Change in FV of Underlying ÷ Change in FV of derivative] lies between 0.80 and 1.25 • Mathematical proving may be difficult even though economically valid • If effectiveness proved: • Net difference between FV of Underlying and Derivatives is taken to PL • If not proved : • MTM effect of Derivatives taken to PL, Underlying remain at Amortised Cost • This can cause huge unwarranted volatility • Intention to hold the derivative till maturity does not have an impact 10 Example of Forward Contract • A company borrows USD 100 mio @ Rs 48/ USD (Rs 480 crores) for a 5 year period • Loan hedged on same day through a forward contract at Rs 53.00 (Forward premia Rs 5) • Currently Rs 5 is amortised over the life of the loan @ Rs 10 crores per year • Under IFRS this would happen: • As on next reporting date : – USD/INR spot rate : 45.50 – Forward Rate for balance to maturity period : 49.00 – Gain on Loan Revaluation (100 mio * 2.50) : Rs 25 crores – Mark to Market Loss on Forward Contract (100 mio * 4.00): Rs 40 crores • Mathematical ratio 0.625 (25 ÷ 40) does not prove effectiveness on the reporting date • Net Ineffectiveness : Rs 15.00 crores debit to Profit and Loss Account in this method • The total debit to PL will be Rs 50 crores over 5 years under both methods – The periodic allocation under current accounting is smooth – While the periodic allocation under IFRS is volatile 11 Amortisation and Impairment • Amortisation of loans to be done based on effective rate – Loan Fees and Costs (e.g. DSA commission) would get deferred • Impairment – General impairment based on Statistical models of Default Probability and Expected Loss – Specific impairment for significant items based on present value of expected Cash Flow – Impairment amounts likely to be lower than current regulatory guidelines 12 Investments and Capital Requirement • Investments in Equity Shares – Other than Subsidiaries and Associates • These would be Fair Valued • Fair Value differences can be either through PL or into Reserves • If routed into Reserves, the final gain/ loss would also go into Reserves – Investment in Subsidiaries and Associates • Either the above method can be used or these can be valued at cost • Capital Requirements – Volatility due to changes in Fair Valuation – Credits to Reserves – are these Tier 1 capital ? 13 Staff Loans • These would get Fair Valued using the market rates • This would adversely impact the 1st year PL Loan Term (in months) Rate EMI Market Rate Present Value of EMIs (PV of 5059 * 240 months) 1st Year Debit to PL (10,00,000 – 5,24,237) 10,00,000 240 2.00% 5,059 10.00% 5,24,237 4,75,763 14 ESOPs and Interest Free Deposits • ESOPS – The option would get Fair Valued and charged as a Cost – Option of Intrinsic value is not available • Interest Free Deposits (for Rent etc.) – Similar to Staff Loans – would get fair valued with initial loss 15 Thank You 16