Impairment assessment
The references below show where the Company's impairment assessment and measurement approach is set out in these notes.
Definition of default
The Company considers a financial instrument as defaulted and considers it as Stage 3 (credit-impaired) for expected credit loss (ECL) calculations, when the assets become more than 90 days past due on its contractual payments and these assets continue to be classified as Stage 3 till the entire overdues are received, in accordance with the RBI guidelines and the ECL Policy.
Exposure at default
The exposure at default (EAD) represents the gross carrying amount of the financial instruments 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 12 months ECL. For Stage 2 financial assets, the exposure at default is considered for events over the lifetime of the instruments.
Probability of default
Probability of default (PD) represents the likelihood of default over a defined time horizon.
Loss given default
Loss given default (LGD) has been calculated by taking into account the recovery experience across the Company's loan accounts post default. The recoveries netted off by expenses incurred for recovery, are tracked and discounted to the date of default using the interest rate.
Significant increase in credit risk
The Company continuously monitors all assets subject to ECL. In order to determine whether an instrument or a portfolio of instruments is subject to 12 months ECL or Lifetime ECL, 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 and/ or when the accounts have been restructured under the RBI 'Resolution Framework - 2.0: Resolution of COVID-19 related stress of Individuals and Small Businesses' Guidelines.
When estimating ECLs 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.
Grouping financial assets measured on a collective basis
As explained above, the Company calculates ECL on a collective basis on the following broad asset classes:
- Home loans
- Loan against property
- Commercial loan
- Construction finance 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.
The Company considers qualitative factors and creates additional provisions in relation to specific borrowers
over and above the ECL model based on the evaluation of the expected cash flows.
Collateral
The Company holds collateral to mitigate credit risk associated with financial assets that are measured at amortised cost. The main types of collateral include residential and commercial properties.
Assets possessed under Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002
Loan Portfolio includes gross loans amounting to ' 261.33 million (31 March 2023: ' 169.18 million), out of which ' 21.00 million (31 March 2023: ' 27.57 million) pertains to retained portion of loans from the assigned portfolio, against which the Company has taken possession of the properties under Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 and held such properties for disposal. The value of assets possessed against these loans is ' 411.38 million (31 March 2023: ' 312.56 million). Value of repossessed assets for loans written off is ' 52.16 million (31 March 2023: ' 35.12 million).
* The notional amounts are not indicative of either the market risk or credit risk. Notional amounts of the respective currencies have been converted using exchange rates as at the balance sheet date.
Hedging activities and derivatives
The Company is exposed to currency risk on its outstanding foreign currency borrowing amounting to ' 4,442.95 million (31 March 2023: Nil) which is primarily mitigated using derivative financial instruments. Refer note 14 (v) and note 33 for foreign currency risk disclosures.
The management has identified enterprises which qualify under the definition of micro enterprises and small enterprises, as defined under Micro, Small and Medium Enterprises Development (MSMED) Act, 2006. Accordingly, the disclosure in respect of amount payable to such enterprises as mentioned below is based on information received and available with the Company and relied upon by the statutory auditors.
The Company has outstanding 2,800 debentures (31 March 2023: 2,800 debentures) at a face value of '1.00 million which are unlisted and 700 debentures as at 31 March 2023 at a face value of ' 1.00 million which were listed on wholesale debt segment of BSE; and secured against the first pari-passu charge (along with banks, financial institutions and other lenders which provide credit facilities to the issuer) by way of hypothecation on the Company's present and future receivables and book debts, cash and cash equivalents and investments, as may be identified by the Company on a time to time basis.
( i ) All borrowings are secured against the loan assets, investments, cash and cash equivalents and bank balances
other than cash and cash equivalents of the Company to the extent of required asset cover as per sanctioned terms.
(ii) The repayment of the borrowing is done in monthly, quarterly and half - yearly instalment as per the sanctioned terms.
(iii) The Company has not made any default in repayment of instalments due over the reporting year.
(iv) Bank guarantees of ' 340.00 million and ' 10.00 million for term loans from NHB is provided by Axis Bank Limited and Central Bank of India (31 March 2023: ' 340.00 million and ' 10.00 million) respectively on behalf of the Company to NHB. Total outstanding balance as at 31 March 2024 for such term loans is ' 2,468.75 million (31 March 2023: ' 3,406.65 million).
(v) Borrowings in India includes outstanding foreign currency borrowings amounting to ' 4,442.95 million (31 March 2023: Nil) for which the Company has entered in to forward contracts to hedge the foreign currency risk.
iii. Terms, rights, preferences and restrictions attached to shares
Equity shares:
The Company has only one class of equity share having face value of ' 2 per share. Each holder of equity share is entitled to one vote per share. The dividend proposed, if any, by the board of directors is subject to the approval of shareholders in the ensuing general meeting. In the event of liquidation of the Company, the holder of equity shares will be entitled to receive any of the remaining assets of the Company.
iv. Issue of bonus shares or buyback of shares
The Company has not issued / allotted any shares pursuant to contracts without payment being received in cash, nor issued any bonus shares nor there has been any buyback of shares during five years immediately preceding 31 March 2024.
v. For details of shares reserved for issue under the employee stock option plan (ESOP) of the Company and shares exercised under ESOP, refer note 37.
19.2 Statutory reserve
As per Section 29C of National Housing Bank Act (NHB), 1987, the Company is required to transfer at least 20% of its net profits every year to a reserve before any dividend is declared. For this purpose, any Special Reserve created by the Company under Section 36(1)(viii) of the Income Tax Act, 1961 is considered to be an eligible transfer. Thus, during the year ended 31 March 2024 and 31 March 2023, the Company has transferred to Statutory Reserve, an amount arrived in accordance with Section 29C of the NHB Act, 1987.
19.3 Securities premium
Securities premium is credited when shares are issued at premium. It can be used to issue bonus
shares, to provide for premium on redemption of shares or debentures, share issue related expenses like underwriting costs etc. in accordance with Section 52 of the Companies Act, 2013.
19.4 Stock options outstanding account
Share options outstanding account is created as required by Ind AS 102 'Share Based Payments' on the Employee stock option schemes operated by the Company for its employees.
19.5 Retained earnings
Retained earnings represents the amount of accumulated earnings of the Company.
19.6 Other Comprehensive Income
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31 Capital management
The Company's capital management strategy is to effectively determine, raise and deploy capital to cover risk inherent in business and meeting the capital adequacy requirements of the Reserve Bank of India (RBI). The same is done through a combination of equity and/ or short term/ long term debt as may be appropriate. The Company determines the amount of capital required on the basis of operations and capital expenditure. The adequacy of the Company's capital is
monitored using, among other measures, the regulations issued by the RBI.
The capital structure is monitored on the basis of net debt to equity and maturity profile of overall debt portfolio. The Company's policy is in line with Master Direction - Non-Banking Financial Company - Housing Finance Company (Reserve Bank) Directions, 2021 which currently permits HFCs to borrow up to 12 times of their net owned funds ("NOF"). Refer note 48 for Capital to risk-weighted assets ratio (CRAR).
Loan covenants
In order to achieve the overall objective, the Company's capital management, amongst other things, aims to ensure that it meets the financial covenants attached to the interest-bearing loans and borrowings that
define capital structure requirements. Breach in meeting these financial covenants would permit the bank to immediately call loans and borrowings. There have been no breaches in the financial covenants of any borrowing in the reporting year.
32.2 Fair value hierarchy
The fair values of the financial assets and liabilities are included at the amount that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.
This section explains the judgements and estimates made in determining the fair values of the financial instruments that are (a) recognised and measured at fair value and (b) measured at amortised cost and for which fair values are disclosed in the financial statements. To provide an indication about the reliability of the inputs used in determining fair value, the Company has classified its financial instruments into the three levels prescribed under the Indian Accounting standard.
Level 1: Level 1 hierarchy includes financial instruments measured using quoted prices. This includes listed equity instruments, units of mutual funds (open ended) and traded bonds that have quoted price. Open-ended mutual funds are valued at Net Asset Value (NAV) declared by respective fund house and are classified under Level 1.
Level 2: The fair value of financial instruments that are not traded in an active market is determined using valuation techniques which maximise the use of observable market data and rely as little as possible on entity-specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in level 2, this level of hierarchy includes financial assets, measured using inputs other than quoted prices included within Level 1 that are observable for the asset, either directly (i.e. as prices) or indirectly (i.e. derived from prices).
Level 3: This level of hierarchy includes financial instruments measured using inputs that are not based on observable market data (unobservable inputs). Fair values are determined in whole or in part, using a valuation model based on assumptions that are neither supported by prices from observable current market transactions in the same instrument nor are they based on available market data.
There have been no transfers amongst the levels of hierarchy during the year ended 31 March 2024 and 31 March 2023.
32.4 Financial assets and liabilities measured at amortised cost at each reporting date
The carrying value of loans given, excess interest strip receivable, bank deposits and borrowings represents its fair value. Further, the carrying value of cash and cash equivalents, investments in government securities, other financial assets, trade payables and other financial liabilities are considered to be approximately equal to the fair value due to their short term maturities.
The above mentioned financial assets and liabilities are classified under level 1 of the fair valuation hierarchy, refer note 32.1.
32.5 Valuation techniques
The fair value of the financial assets and liabilities is the amount at which the instrument could be exchanged in a current transaction between willing parties, other than in a forced or liquidation sale. The following methods and assumptions were used to estimate the fair values:
Loans - The fair value of floating rate loans are deemed to be equivalent to the carrying value.
Borrowings (including debt securities) - The fair value of fixed rate borrowings is determined by discounting expected future contractual cash flows using current market interest rates charged for similar new loans and the carrying value approximates the fair value. The fair value of floating rate borrowings are deemed to be equivalent to the carrying value.
33 Financial risk management
The Company is exposed to certain financial risks namely credit risk, liquidity risk and market risk i.e.
interest risk, foreign currency risk and price risk. The Company's primary focus is to achieve better predictability of financial markets and minimise potential adverse effects on its financial performance by effectively managing the risks on its financial assets and liabilities.
The principal objective in Company's risk management processes is to measure and monitor the various risks associated with the Company and to follow policies and procedures to address such risks. The Company's risk management framework is driven by its Board and its subcommittees including the Audit Committee, the Asset Liability Management Committee and the Risk Management Committee. The 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, valuation of collateral, technical and legal verifications, conservative loan to value, and required term cover for insurance.
A Liquidity risk
Liquidity risk is defined as the risk that the Company will not be able to settle or meet its obligations on time or at a reasonable price. For the Company, liquidity risk arises from obligations on account of financial liabilities - borrowing, trade payables and other financial liabilities. The Company manages liquidity risk by maintaining adequate cash reserves by continuously monitoring forecast and actual cash flows, and by matching the maturity profiles of financial assets and liabilities.
Notes:
(I) Debt securities and borrowings (other than debt securities) carry adjustment of unamortised processing fee (EIR).
(ii) Other financial liabilities exclude liability pertaining to lease liabilities covered under Indian accounting standard 116 (31 March 2024: ' 169.00 million; 31 March 2023: ' 147.73 million).
B Market risk ( i ) 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 primarily towards principal and interest payments at a future date on the foreign currency borrowings taken from banks and certain vendors in trade payables.
In order to minimise any adverse impact on the financial performance of the Company, the Company enters in to forward contracts to hedge the foreign currency risk in such a manner that it results in fixed determinate outflows in the functional currency and as such there would be no significant impact of movement in foreign currency rates on the Company's profit before tax. .....
(ii) Interest rate risk
The Company is subject to interest rate risk, since the rates of loans and borrowings might fluctuate over the tenure of instrument. 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 seeks to optimise borrowing profile between short-term and long-term loans. The liabilities are categorised 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.
34 Credit risk management Credit quality of assets
Credit risk is the risk that the Company will incur a loss because the counterparty might fail to discharge their contractual obligations. The Company has a comprehensive framework for monitoring credit quality of its retail and other loans primarily based on number of days past due.
The Company managers credit risks by using a set of credit procedures and guidelines, laid down in the credit risk policy, to ensure effective credit risk management and health of the portfolio. The adherence to the policy and various processes is monitored and appraised in the credit committee meetings on a quarterly basis. The policy is amended periodically to ensure compliance with the guidelines of the RBI as well as other regulatory bodies.
We have implemented a structured credit approval process, including multi-step customer verification and comprehensive credit risk assessment, which encompasses analysis of relevant quantitative and qualitative information to ascertain the credit worthiness of a potential customer. As part of our multi-step customer verification, we have established a process by which separate set of verifications are conducted by a customer relationship manager and customer service officer to ensure the quality of customers acquired as well as eliminate misuse of borrowing practices.
Portfolio quality, credit limits, collateral quality and credit exposure limits are regularly monitored at various levels.
The Company considers a financial instrument as defaulted and considers it as Stage 3 (credit-impaired) for expected credit loss (ECL) calculations, when the assets become more than 90 days past due on its contractual payments and these assets continue to be classifed as Stage 3 till the entire overdues are received, in accordance with the RBI guidelines and Board approved ECL Policy.
The following table sets out information about credit quality of loans measured at amortised cost based on days past due information. The amount represents gross carrying amount. (Refer note 4 - Loans for detailed disclosure on gross carrying value and ECL amount on loans).
35 Transfers of assets Assignment deal:
The Company has sold some loans measured at amortised cost as per assignment deals during the year. 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's 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, per type of asset.
b. The Company has not acquired any loan not in default during the year ended 31 March 2024 and 31 March 2023.
c. The Company has not transferred or acquired any stressed loan during the year ended 31 March 2024 and 31 March 2023.
36 Employee benefits
(A) Defined benefit obligation
The Company has an unfunded defined benefit plan i.e.,
Gratuity, for its employees. Under the gratuity plan every employee who has completed at least five years of service gets a gratuity on departure at 15 days of salary for each year of service.
Contribution to gratuity fund (unfunded scheme)
In accordance with Indian Accounting Standard 19 'Employee benefits', actuarial valuation was done in respect of the aforesaid defined benefit plan of gratuity based on the following assumptions:
Interest rate risk: The risk of government security yields falling due to which the corresponding discount rate used for valuing liabilities falls. Such a fall in discount rate will result in a larger value placed on the future benefit cash flows whilst computing the liability and thereby requiring higher accounting provisioning.
Longevity risk: Longevity risks arises when the quantum of benefits payable under the plan is based on how long the employee lives post cessation of service with the company. The gratuity plan provides
the benefit in a lump sum form and since the benefit is not payable as an annuity for the rest of the lives of the employees, there is no longevity risk.
Salary risk: The gratuity benefits under the plan are related to the employee's last drawn salary. Consequently, any unusual rise in future salary of the employee raises the quantum of benefit payable by the company, which results in a higher liability for the company and is therefore a plan risk for the company.
Code on Social Security, 2020
The Indian Parliament has approved the Code on Social Security, 2020 which would impact the contributions by the Company towards Provident Fund and Gratuity. The Ministry of Labour and Employment had released draft rules thereunder on 13 November 2020. The Company will assess the impact and its evaluation once the subject rules are notified. The Company will give appropriate impact in its financial statements in the period in which the Code becomes effective and the related rules to determine the financial impact are published.
(B) Defined contribution plan
The Company contributes towards provident fund for employees which is the defined contribution plan for qualifying employees. Under this Scheme, the Company is required to contribute specified percentage of the payroll cost to fund the benefits. The Company recognised ' 40.37 million (31 March 2023: ' 33.16 million) for provident fund contributions in the statement of profit and loss.
The Company has recognised ' 2.29 million (31 March 2023: ' 1.77 million) for National Pension Scheme contributions in the statment of profit and loss.
(C) Compensated absence expenses
The Company has accounted for provision for compensated absences from 01 April 2019. An employee is eligible to carry
forward 30 to 90 days of leaves basis their work location to the next period from the balance leaves pending utilisation; however these leaves are non-encashable. Provision for compensated absence for current year is ' 2.50 million (31 March 2023: ' 2.25 million).
37.2 Vesting condition:
a) ESOP 2012: All options under this scheme have been fully vested.
b) ESOP II:
Management option: Vesting will be in two parts for Tranche 1, Tranche 2, Tranche 3 - 66% will be performance plus time based which will vest in 6 equal instalments; and 34% will be vested as follows:
37.3 Contractual life
ESOP 2012: The contractual life (vesting period plus exercise period) ranges from 11 to 14 years i.e. vesting period ranging from 1 to 4 years and exercise period of 10 years from the date of vesting of the option. In case of resignation/ termination of any employee, the exercise period shall be 6 months from the last working day of the employee.
ESOP II: The contractual life (vesting period plus exercise period) ranges from 11 to 16 years i.e. vesting period ranging from 1 to 6 years and exercise period of 10 years from the date of vesting of the option. In case of resignation/ termination of any employee, the
exercise period shall be 6 months from the last working day of the employee.
ESOP 2021: The contractual life (vesting period plus exercise period) ranges from 4 to 7.3 years i.e. vesting period ranging from 1 to 4.3 years and exercise period of 3 years from the date of vesting of the option. In case of resignation/ termination of any employee, the exercise period shall be 6 months from the last working day of the employee.
Method of settlement: ESOP 2012, ESOP II and ESOP 2021 is to be settled through issue of equity shares.
38 Segment information38.1 Operating segment
The Company's main business is financing by way of loans towards affordable housing segment in India. All other activities of the Company revolve around the main business. As such, there are no separate reportable segments, as per the Indian Accounting Standard (Ind AS) 108 on 'Segment Reporting'. Accordingly, the amounts appearing in the financial statements relate to the Company's single business segment.
38.2 Entity wide disclosures
No revenue from transactions with a single external customer or counterparty amounted to 10% or more of the Company's total revenue in the year ended 31 March 2024 and 31 March 2023.
The Company operates in single geography i.e. India and therefore geographical information is not required to be disclosed separately.
39 Lease disclosureWhere the Company is the lessee:
The Company has entered into agreements for taking its office premises under leave and license arrangements. These agreements are for tenures between 1 year and 9 years and majority of the agreements are renewable by mutual consent on mutually agreeable terms, lease rentals have an escalation ranging between 5% to 15%. Leases for which the lease term is less than 12 months have been accounted as short term leases.
The Company undertakes the following activities in the
nature of Corporate social responsibility (CSR):
a. Promoting education, including special education and employment enhancing vocational skills, especially among children, women, and elderly;
b. Promoting health care, including preventive health care and sanitation;
c. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources;
d. Promoting digital literacy, building importance of saving, and instilling future planning skills among students.
Notes:
1. No amount has been spent by the Company for the construction/ acquisition of any new asset during the year ended 31 March 2024 and 31 March 2023.
2. There have been no related party transactions during the year ended 31 March 2024 and 31 March 2023 in respect of CSR activities.
41 Contingent liabilities and commitments
There are no Contingent Liabilities as on 31 March 2024 (31 March 2023: Nil).
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(' in million)
|
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As at
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As at
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31 March 2024
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31 March 2023
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Commitments - Undisbursed amount of housing and other loans
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11,902.36
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10,194.53
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43 The Company does not hold any immovable property as on 31 March 2024 and 31 March 2023. All the lease agreements are duly executed in favour of the Company for properties where the Company is the lessee.
44 No proceedings have been initiated or pending against the Company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 and rules made thereunder, as at 31 March 2024 and 31 March 2023.
45 The Company is not a declared wilful defaulter by any bank or financial Institution or other lender, in accordance with the guidelines on wilful defaulters issued by the Reserve Bank of
India, during the year ended 31 March 2024 and 31 March 2023.
46 The Company does not have any transactions with the companies struck off under section 248 of Companies Act, 2013 or section 560 of Companies Act, 1956 during the year ended 31 March 2024 and 31 March 2023.
47 Registration of charges or satisfaction with Registrar of Companies (ROC)
There has been no delay in registration or satisfaction of charges with ROC beyond the statutory date during the year ended 31 March 2024 and 31 March 2023.
49 The Company has borrowings from banks and financial institutions on the basis of security of receivables and current assets and the quarterly returns filed by the Company with the banks and financial institutions are in accordance with the books of accounts of the Company for the respective quarters with no material discrepancies.
50 The Company has taken borrowings from banks and financial institutions and utilised them for the specific purpose for which they were taken as at the Balance sheet date. Unutilised funds as at 31 March 2024 and 31 March 2023 are held by the Company in the form of investments till the time the utilisation is made subsequently.
51 There have been no transactions which have not been recorded in the books of accounts, that have been surrendered or disclosed as income during the year ended 31 March 2024 and 31 March 2023, in the tax assessments under the Income Tax Act, 1961. There have been no previously unrecorded income and related assets which were to be properly recorded in the books of account during the year ended 31 March 2024 and 31 March 2023.
52 As a part of normal lending business, the Company grants loans and advances on the basis of security / guarantee provided by the borrower/ co-borrower. These transactions are conducted after exercising proper due diligence.
Other than the transactions described above,
a. No funds have been advanced or loaned or invested by the Company to or in any other
person(s) or entity(ies) including foreign entities ("Intermediaries") with the understanding that the Intermediary shall lend or invest in a party identified by or on behalf of the Company (Ultimate Beneficiaries);
b. No funds have been received by the Company from any party(s) (Funding Party) with the understanding that the Company shall whether, directly or indirectly, lend or invest in other persons or entities identified by or on behalf of the Company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.
53 The Company has not traded or invested in Crypto currency or Virtual Currency during the year ended 31 March 2024 and 31 March 2023.
54 The Company has used an accounting software for maintaining its books of account for the year ended 31 March 2024 which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software. Further, there is not any instance of the audit trail feature being tampered with.
As proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from 01 April 2023, reporting under Rule 11 (g) of the Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the statutory requirements for record retention is not applicable for the year ended 31 March 2024.
56 Disclosure on Liquidity Risk in accordance with RBI circular No. RBI/2019-20/88 DOR.NBFC (PD) CC. No.102/03.10.001/2019-20 dated 04 November 2019 on Liquidity Risk Management Framework for NonBanking Financial Companies (NBFCs) including Core Investment Companies and RBI circular No. RBI/2020-21/60 DOR.NBFC (HFC).CC.No.118/03.10.136/2020-21 dated 22 October 2020 for regulatory framework for Housing Finance Companies (HFCs)
#Significant counterparty is defined in RBI Circular RBI/2019-20/88 DOR.NBFC (PD) CC.No.102/03.10.001/ 2019-20 dated 04 November 2019 on Liquidity Risk Management Framework for Non-Banking Financial Companies and Core Investment Companies. Accordingly, the Company has considered lenders with more than 1% of total outstanding borrowing as significant counterparties.
*Borrowings amount excludes the interest accrued but not due.
**Total liabilities has been computed as sum of all liabilities (balance sheet figure) less equity share capital and other equity.
56.2 Top 20 large deposits
Not applicable. The Company is registered with National Housing Bank to carry on the business of housing finance institution without accepting public deposits.
*Significant instrument/ product is as defined in RBI Circular RBI/2019-20/88 DOR.NBFC (PD)CC.No.102/ 03.10.001/2019-20 dated 04 November 2019 on Liquidity Risk Management Framework for NonBanking Financial Companies and Core Investment Companies.
**Total liabilities has been computed as sum of all liabilities (balance sheet figure) less equity share capital and other equity.
56.6 Institutional set-up for liquidity risk management
The Company's Board of Directors monitors all the risks, including liquidity risk. Governance structure, Policies and risks limits are prescribed by the Board.
Board Constituted Asset Liability Committee (ALCO) ensures effective asset-liability management, market risk management, liquidity and interest rate risk management and also adherence to risk tolerance/ limits set up by the Board. ALCO provides guidance and directions in terms of interest rate, liquidity, funding sources, and investment of surplus funds.
The Risk Management Committee constituted by the Board of Directors is primarily responsible for the effective supervision, evaluation, monitoring and review of various aspects and types of risks, including liquidity risk, faced by the Company.
Further, as per guidelines issued by the RBI, HFCs are required to maintain the Liquidity Coverage Ratio (LCR), to maintain liquidity buffers to withstand potential liquidity disruptions by ensuring that it has sufficient High Quality Liquid Assets (HQLA) to survive any acute liquidity stress scenario lasting for 30 days. As per the guidelines, the weighted values of the net cash flows are calculated after the application of respective haircuts for HQLA and considering stress factors on inflows at 75% and outflows at 115%.
For all non-deposit taking HFCs with an asset size
of ' 5,000 crore and above, but less than ' 10,000 crore, there is a phased transition towards meeting the minimum LCR, with the requirement as on 01 December 2021 being 30%. Thereafter, the requirement increases from 01 December 2022 onwards in a graded manner. The Company has put in place a liquidity risk management framework so as to adhere to the said LCR guidelines and applicable timelines.
57 Disclosure on Liquidity Coverage Ratio (LCR) in accordance with RBI circular No. RBI/2020-21/73 DOR.FIN.HFC.CC.No.102/03.10.136/ 2020-21 dated 17 February 2021 and RBI circular No. RBI/DNBR/2016-17/45 Master Direction DNBR.PD.008/03.10.119/ 2016-17 dated 01 September 2016 The RBI vide Circular No. RBI/2020-21/73 DOR.FIN.HFC.CC.No.120/03.10.1 36/2020-21 dated 17 February 2021 issued guidelines on maintenance of Liquidity Coverage Ratio (LCR) for HFCs.
The objective of the LCR is to promote resilience in the liquidity risk profile of HFCs. This is done by ensuring that the Company has an adequate stock of unencumbered high-quality liquid assets (HQLA) that can be converted easily and immediately into cash to meet its liquidity needs for a 30 calendar day liquidity stress scenario. Further, the guidelines required all non-deposit taking HFCs with an asset size of ' 5,000 crore and above, but less than '10,000 crore, to maintain minimum LCR of 30% as on December 2021, to be gradually increased to 100% by December 2025. The Company's Board
approved Asset Liability Management (ALM) Policy covers its Liquidity Risk Management policies and processes, stress testing, contingency funding plan, maturity profiling, Currency Risk, Interest Rate Risk and Liquidity Risk Monitoring Tools.
The Company regularly reviews the maturity position of assets and liabilities and liquidity buffers, and ensures maintenance of sufficient quantum of High Quality Liquid Assets, most of which is in the form of government securities as at 31 March 2024 and 31 March 2023.
Note: Loan Portfolio includes gross loans amounting to ' 261.33 million (31 March 2023: ' 169.18 million), out of which '21.00 million (31 March 2023: ' 27.57 million) pertains to retained portion of loans from the assigned portfolio, against which the Company has taken possession of the properties under Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 and held such properties for disposal. The value of assets possessed against these
loans is ' 411.38 million (31 March 2023: ' 312.56 million). Value of repossessed assets for loans written off is ' 52.16 million (31 March 2023: ' 35.12 million).
**Current investment means an investment which is by its nature readily realizable and is intended to be held for not more than one year from the date on which such investment is made.
63.3 Disclosures on Risk Exposure in Derivatives
A. Qualitative Disclosure
The Company manages various risks associated with the lending business, including liquidity risk, foreign exchange risk, interest rate risk and counterparty risk.
To manage these risks, the Company has Board approved policies and framework, including the Risk Management Policy and ALCO Policy, which sets limits for exposures on currency, interest rates and other parameters. The Company manages its currency risk and enters in to derivative contracts in accordance with the guidelines prescribed therein.
Liquidity risk and Interest rate risk arising out of maturity mismatch of assets and liabilities are managed through regular monitoring of maturity profiles. The currency risk on borrowings is actively managed mainly through derivative financial instruments by entering in to forward
contracts. Counter party risk is reviewed periodically to ensure that exposure to various counter parties is well diversified and is within the limits fixed by the Risk Management Committee.
76 Breach of covenants
The Company has complied with the financial covenants under the terms of major borrowing facilities throughout the year ended 31 March 2024 and 31 March 2023.
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