INCOME RECOGNITION, ASSET CLASSIFICATION, AND PROVISIONING S Dwivedi ACA-TM-37 (v2.2-20-Nov-10) ALL BANKS IRRESPECTIVE OF SIZE OF BRANCH “ONE SIZE FITS ALL” PRINCIPLE NORMS ARE WITH 90 DAYS DELINQUENCY 3/18/2016 10:16 AM 2 ACA-TM-37 (v2.2-20-Nov-10) IRAC NORMS & PROVISIONING WHY? In line with international best practices. As per Narsimham committee recommendations. In a phased manner Greater consistency and transparency in published books of accounts of banks. To improve intrinsic health of banks 3/18/2016 10:16 AM 3 ACA-TM-37 (v2.2-20-Nov-10) DEFINATION OF NON PERFORMING ASSET [ NPA ] and IMPORTANT TERMINOLOGIES NPA : An Asset becomes Non Performing when it ceases to generate income OVERDUE : due Any amount due under any credit facility if not paid by the date fixed by the bank becomes overdue OUT OF ORDER : An account should be treated as Out of Order if the outstanding balance remains continuously in excess of the sanctioned limit/ drawing power or if there are no credits for specified number of days or credits are not enough to cover the 3/18/2016 10:16during the same period 4 interest debited AM ACA-TM-37 (v2.2-20-Nov-10) NPA : ADVANCES Term Loans Interest and or installment of principal remain overdue for more than 90 days Overdraft / Cash Credit The account remains Out of Order for a period of more than 90 days Bank Guarantee In case Bank Guarantee is invoked and the amount remains unpaid for 90 days Letter of Credit In case Letter of Credit is devolved and the amount remains unpaid for more than 90 days Bills The bill remains overdue for a period of more than 90 days Agriculture Advance Short duration loans - Installment or interest remains overdue for two crop seasons Long duration loans – Installment or interest remains overdue for one crop season Gold Loans, Loans against Deposits, KVPs, NSCs, IVPs. Interest and or installment of principal remain overdue for 90 days Any Other Amount Any other amount to be received remains overdue for a period of more than 90 days 5 3/18/2016 10:16 AM ACA-TM-37 (v2.2-20-Nov-10) NPA : TERM LOAN ACCOUNTS Account Status NPA IF Interest or Instalment is overdue for 90 days Term Loan Account of XYZ Date Particulars Debit Credit Balance 2010 Dec. 1 To Loan 5000.00 5000.00 Dec. 31 To Interest 50.00 5050.00 Dec. 31 By 1st Installment 2010 Jan. 31 To Interest 46.00 4596.00 2010 Feb. 28 To Interest 46.00 4642.00 2010 Mar. 31 To Interest 46.00 4688.00 500.00 4550.00 In the above example Borrower has not paid the interest which was charged on Dec. 31 2010 amounting to Rs. 50.00 and the same was overdue for 90 days hence this account shall be categorised as NPA as on 31st March 2011. Thus all accounts disbursed after 1st Jan of the financial year can never be NPA. 3/18/2016 10:16 6 AM ACA-TM-37 (v2.2-20-Nov-10 ) AGRICULTURAL ADVANCES SHORT DURATION LONG DURATION NPA IF NPA IF Installment or Interest remains overdue for two crop seasons Installment or Interest remains overdue for one crop seasons Where natural calamity has impaired the repaying capacity and the crop loan is converted into Term Loan or Term Loan is rescheduled, Term Loan or fresh short term loan may be treated as current dues and need not be classified as NPA. 3/18/2016 10:16 AM 7 ACA-TM-37 (v2.2-20-Nov-10) WHAT IS SHORT TERM CROP AND LONG DURATION CROP? • “LONG DURATION CROP MEANS CROP WITH CROP SEASON LONGER THAN ONE YEAR AND CROPS WHICH ARE NOT LONG DURATION CROPS WOULD BE TREATED AS SHORT DURATION CROP”. 3/18/2016 10:16 AM 8 ACA-TM-37 (v2.2-20-Nov-10) AGRICULTURAL REVISED NORMS…. • REVISED NORMS ARE APPLICABLE TO DIRECT AGRICULTURAL ADVANCES AND NOT ALLIED AGRI. ACTIVITIES LIKE DAIRY, POULTRY, FISHERY, PIGGERY, ETC. 3/18/2016 10:16 AM 9 ACA-TM-37 (v2.2-20-Nov-10) AGRI ADVANCE- NPA STATUS CROP LOAN GRANTED IN JUNE 2008 REPAYMENT DUE DATE 31Mar 2009 AMOUNT NOT PAID ON DUE DATE STATUS OF A/C ON 31 MAR. 09: STANDARD STATUS OF A/C ON 31 MAR. 10: STANDARD STATUS OF A/C ON 31 MAR .11 SUB-STND DATE OF NPA WILL BE 31 JAN 2011 3/18/2016 10:16 AM 10 ACA-TM-37 (v2.2-20-Nov-10) Illustration :NPA Agri. 3/18/2016 10:16 AM 11 ACA-TM-37 (v2.2-20-Nov-10) Illustration :NPA Agri… 3/18/2016 10:16 AM 12 ACA-TM-37 (v2.2-20-Nov-10) Illustration :NPA Agri.. 3/18/2016 10:16 AM 13 ACA-TM-37 (v2.2-20-Nov-10) Illustration :NPA Agri.. 3/18/2016 10:16 AM 14 ACA-TM-37 (v2.2-20-Nov-10) Illustration :NPA Agri.. 3/18/2016 10:16 AM 15 ACA-TM-37 (v2.2-20-Nov-10) Illustration :NPA Agri.. 3/18/2016 10:16 AM 16 ACA-TM-37 (v2.2-20-Nov-10) NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA IF Limit Sanctioned Overdrawn beyond sanctioned limit Balance between 01.01.09 to 31.03.09 Rs. 30.00 lacs 3/18/2016 10:16 AM Rs. 31.00 lacs Status Out of Order and hence NPA on the 90th day I.e. 31.03.09 / Continuously overdrawn beyond sanctioned limit from 1.1.09 to 31.3.09 i.e. 90 days 17 ACA-TM-37 (v2.2-20-Nov-10) NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA IF Overdrawn beyond Drawing Power Limit Rs. 30.00 lacs Drawing Power Rs. 27.00 lacs Balance between 01.01.09 to 31.03.09 Rs. 28.00 lacs 3/18/2016 10:16 AM Out of Order and hence NPA on the 90th day i.e. 31.03.09 / Continuously overdrawn beyond Drawing Power from 1.1.09 to 31.3.09 i.e. 90 days 18 ACA-TM-37 (v2.2-20-Nov-10) NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA IF Insufficient Credits in to the Account Limit Rs. 30.00 lac Status/Explanation Balance as on 31.12.09 Rs. 29.00 lac Well within the limit of Rs. 30.00 lacs Interest debited for Dec. Rs. 35000.00 09 Total credits between 01.01.10 and 31.03.10 3/18/2016 10:16 AM Rs. 26000.00 During the entire stretch of 90 days between 01.01.10 and 31.03.09 credits are insufficient to cover the interest debited and hence it is NPA 19 ACA-TM-37 (v2.2-20-Nov-10) NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA IF No Credits in to the Account Limit Rs. 30.00 lac Status/Explanation Balance as on 31.12.09 Rs. 29.00 lac Well within the limit of Rs. 30.00 lacs Interest debited for Dec. 09 Rs. 35000.00 During the entire stretch of 90 days between 01.01.10 and 31.03.10 there are no credits and hence it is NPA Total credits between Rs. NIL 01.01.10 and 31.03.10 3/18/2016 10:16 AM 20 ACA-TM-37 (v2.2-20-Nov-10) NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA IF Non renewal of OD/CC account for 180 days Limit Date of Agreement Date of Expiry OD should have been renewed by at least Rs. 30.00 lacs 01.10.08 30.09.09 31.03.10 OD facility was availed on 01.10.08 Secured by mortgage of Property worth Rs. 100 lacs. Limit was valid upto 30.09.09 The operations were good with no irregularity But the limit was not renewed 3/18/2016 10:16 AM The account should be treated as NPA as the limit was not renewed within180 days 21 ACA-TM-37 (v2.2-20-Nov-10) NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA IF Stock statement submitted for Drawing power is fixed on the basis of old stock statements DP for subsequent month fixed on the basis of stock statement of Drawings allowed on the basis of stock statement of March 2010 March 10 March 10 Standard Asset / within limit/DP Not Submitted for April 10 March 10 March 10 Standard Asset / within limit/DP Not Submitted for May 10 March 10 March 10 Standard Asset / within limit/DP Not Submitted for June 10 March 10 March 10 Standard Asset / within limit/DP Not Submitted for July 10 Sept. 10 March 10 March 10 Drawings allowed from 1st May on Stock statement of Mar. 10 would be treated as irregular w.e.f from 1st July. If such irregularity allowed22 for 90 days A/c. would become NPA w.e.f 30th Sept ACA-TM-37 (v2.2-20-Nov-10) Status / Explanation NPA : OVERDRAFT AND CASH CREDIT LIMITS Account Status NPA OR STANDARD ? Period OD Limit Sanctioned OD Balance BG/LC Limit Sanctioned BG/LC devolved liability Total Liability Explanation 01.01.07 to 19.01.07 30.00 21.00 20.00 10.00 31.00 OD A/c. out of order 20.01.07 to 28.02.07 30.00 23.00 20.00 20.00 43.00 OD A/c. out of order 01.03.07 to 30.03.07 30.00 26.00 20.00 10.00 36.00 OD A/c. out of order 31.03.07 30.00 29.00 20.00 10.00 39.00 OD A/c. out of order If BG/LC is devolved and Balance in OD along with balance of devolved LC is more than the sanctioned limit of Rs. 30.00 lacs 23 3/18/2016 10:16 AM ACA-TM-37 (v2.2-20-Nov-10 ) CLASSIFICATION OF ASSET Category of Assets Definitions STANDARD Asset which does not disclose any problems and which does not carry more than normal risk attached to business and continues to generate income. SUB-STANDARD If an Asset remains NPA for a period of 12 months RESCHEDULED/ RENEGOTIATED A/cs. Rescheduled/Renegotiated terms of Project it remains in this category with satisfactory performance DOUBTFUL ASSET If an Asset remains NPA for more than 12 months LOSS ASSET Where loss has been identified by the bank or Internal / External Auditors or by the Cooperative Department or by RBI inspection but the amount has not been written off. 3/18/2016 10:16 AM 24 ACA-TM-37 (v2.2-20-Nov-10) EROSION IN THE VALUE OF SECURITY An NPA need not go through the various stages of classification in cases of serious credit impairment. If the realisable value of the security is <50% such NPAs may be classified as DOUBTFUL directly. If the realisable value of security is <10%, then the account should be straight way classified as LOSS ASSET. 3/18/2016 10:16 AM 25 ACA-TM-37 (v2.2-20-Nov-10) REPAYMENT WITH MORATORIUM PERIOD Where moratorium period is available for payment of interest, payment of intt. becomes ‘due’ only after the moratorium is over. So non-payment of intt.during moratorium does not make account NPA. 3/18/2016 10:16 AM 26 ACA-TM-37 (v2.2-20-Nov-10) PROVISIONING NORMS - BANKS STANDARD ASSETS Type of Bank Personal Loans & Commercial Real Estate Loans Agri. Direct Loans & SME Loans All other Standard Loans All Banks 1.00 % 0.25 % 0.40 % 3/18/2016 10:16 AM 27 ACA-TM-37 (v2.2-20-Nov-10) PROVISIONING NORMS - BANKS SUB - STANDARD ASSETS Entity All Banks 3/18/2016 10:16 AM Provision 15 % (w.e.f. FYending March 2012) on Total Outstanding without any allowance for DICGC / ECGC Guarantee cover and Securities available 28 ACA-TM-37 (v2.2-20-Nov-10) PROVISIONING NORMS - BANKS DOUBTFUL ASSETS All Entities Period for which the advance has remained in Doubtful category Secured Portion Unsecured Portion 25 Per Cent (wef FY ending March 2012) 100 Per Cent One to Three Years 40 Per Cent 100 Per Cent More than 3 years ii) Advances classified as Doubtful for more than Three years on or after April 1, 2006 100 Per Cent 100 Percent Up to One Year 3/18/2016 10:16 AM 29 ACA-TM-37 (v2.2-20-Nov-10) PROVISIONING NORMS - BANKS LOSS ASSETS Entity All Banks 3/18/2016 10:16 AM Provision 100 % on Total Outstanding 30 ACA-TM-37 (v2.2-20-Nov-10) Income Recognition • Income Recognition Policy - Based on objective criteria and on the record of recovery - Income from NPAs is not recognized on accrual basis but only when actually received - Banks should not charge and take to Income account interest on any NPA 31 ACA-TM-37 (v2.2-20-Nov-10) Income Recognition • Income Recognition Policy -Fees / Commissions earned due to renegotiations/rescheduling to be recognized on accrual basis - Interest on Govt. guaranteed advances not to be taken unless interest realized - Accrued interest on investments may be taken to P&L A/c till maturity. However, it is to be provided for fully, if interest is not realized on due date / date of maturity 32 ACA-TM-37 (v2.2-20-Nov-10) Income Recognition • Reversal of Income - If any account becomes NPA, the entire interest accrued and credited to income account in the past periods should be reversed if the same is not realised. Applies to Government guaranteed accounts also - Fees, commission and similar income that have accrued should cease to accrue and past dues if uncollected to be reversed 33 ACA-TM-37 (v2.2-20-Nov-10) Income Recognition • Appropriation of recovery in NPA - Interest realized on NPAs may be taken to income account provided credits are not out of fresh / additional credit facilities - In the absence of a clear agreement banks to exercise right of appropriation of recoveries in a uniform and consistent manner 34 ACA-TM-37 (v2.2-20-Nov-10) Income Recognition • Interest application - Reversal of interest already charged but not collected by debiting Profit and Loss A/c and stop further application of interest - Banks may continue to record accrued interest in a Memorandum Account 35 ACA-TM-37 (v2.2-20-Nov-10) 36 ACA-TM-37 (v2.2-20-Nov-10)