SBN HOLDINGS LIMITED Annual Report 2022
KEY MANAGEMENT ASSUMPTIONS continued
68
KEY MANAGEMENT ASSUMPTIONS
SBN HOLDINGS LIMITED
69
Annual report 2022
In preparing the group and company annual financial statements,
estimates and assumptions are made that could materially
affect the reported amounts of assets and liabilities within the
next financial year. Estimates and judgements are continually
evaluated and are based on factors such as historical experience
and current best estimates of future events. While models have
been enhanced, no material changes to assumptions have
occurred during the current year. The following represents the
most material key management assumptions applied in preparing
these financial statements. The key management assumptions
below apply to group and company, unless otherwise stated.
Expected credit loss (ECL)
During the current reporting period models have been enhanced,
but no material changes to assumptions have occurred. Covid-19
placed considerable strain on our operations over the past two
years, specifically retail, business and corporate clients, however,
the group's risk appetite remained unchanged. As such the below
significant increase in credit risk (SICR) and default assumptions,
thresholds and/or triggers were not amended.
-
IFRS 9 drivers
ECL on financial assets
For the purpose of determining the ECL:
■■The BCB and CHNW portfolios are based on the product
categories or subsets of the product categories, with tailored
ECL models per portfolio. The impairment provision calculation
excludes post-write-off recoveries (PWOR) from the loss given
default (LGD) in calculating the ECL. These LGD parameters
are aligned to market practice.
■CIB client exposures are calculated separately based on rating
models for each of the asset classes.
ECL measurement period
■The ECL measurement period for stage 1 exposures is
12-months (or the remaining tenor of the financial asset for
CIB client exposures if the remaining lifetime is less than
12-months).
■A loss allowance over the full lifetime of the financial asset
is required if the credit risk of that financial instrument has
increased significantly since initial recognition (stage 2).
■ A lifetime measurement period is applied to all credit impaired
(stage 3) exposures.
■The measurement periods for unutilised loan commitments
use the same approach as on-balance sheet exposures.
SICR and low credit risk
Home services, vehicle and asset finance, card,
personal, business and other lending products
All exposures are assessed to determine whether there has
been SICR at the reporting date, in which case an impairment
provision equivalent to the lifetime expected loss is recognised.
SICR thresholds, which are based on behaviour scores, are
derived for each portfolio vintage of exposures with similar credit
risk and are calibrated over time to determine which exposures
reflect deterioration relative to the originated population and
consequently reflect an increase in credit risk.
Behaviour scorecards are based on a combination of factors
which include the information relating to customers, transactions
and delinquency behavioural (including the backstop when
contractual payments are more than 30 days past due (DPD) to
provide a quantitative assessment (score), and more specifically,
a ranking of customer creditworthiness. The creditworthiness
of a customer is summarised by a score, with high scores
corresponding to low-risk customers, and conversely, low scores
corresponding to high-risk customers. These scores are often
taken into account in determining the probability of default (PD)
including relative changes in PD.
The group and company determine the SICR threshold by
utilising an appropriate transfer rate of exposures that are less
than 30 days DPD to stage 2. This transfer rate is such that the
proportion of the 0 - 29 DPD book transferred into stage 2 is no
less than the observed 12-month roll rate of 0-29 days accounts
into 30 or more days in arrears. The SICR thresholds are reviewed
regularly to ensure that they are appropriately calibrated to
identify SICR by portfolio vintage and to consequently facilitate
appropriate impairment coverage.
Where behaviour scores are not available, historical levels of
delinquency are applied in determining whether there has been
SICR. For all exposures, the rebuttable presumption of 30 days
past due as well as exposures classified as either debt review or
as 'watch-list' are used to classify exposures within stage 2.
In accordance with BoN's policy directives in response to
economic and financial stability challenges, following the fallout
of the Covid-19 pandemic where a restructure is considered
due to Covid-19 related factors, the group determines whether
the exposure is expected to remain in a not overdue status
subsequent to the relief period. These restructured exposures are
classified as Covid-19 related restructures and the determination
of temporary or permanent distress is assessed on a regular
basis. Temporary distressed accounts are classified as stage 1
or stage 2 based on the risk profile and permanently distressed
accounts are classified as stage 3.
Corporate, sovereign and bank lending products
(including certain business banking exposures)
The group uses a 25-point master rating scale to quantify the
credit risk for each exposure. On origination, each client is
assigned a credit risk grade within the group's 25-point master
rating scale. Ratings are mapped to PDs by means of calibration.
formulae that use historical default rates and other data for the
applicable portfolio. These credit ratings are evaluated at least
annually or more frequently as appropriate.
CIB exposures are evaluated for SICR by comparing the credit
risk grade at the reporting date to the origination credit risk
grade. Where the relative change in the credit risk grade exceeds
certain pre-defined ratings' migration thresholds or, when a
contractual payment becomes more than 30 days overdue
(IFRS 9's rebuttable presumption), the exposure is classified
within stage 2. These pre-defined ratings' migration thresholds
have been determined based on historic default experience which
indicate that higher rated risk exposures are more sensitive to
SICR than lower risk exposures. Based on an analysis of historic
default experience, exposures that are classified by the group's
master rating scale as investment grade (within credit risk
grade 1 - 12 of the group's 25-point master rating scale) are
assessed for SICR at each reporting date but are considered to be
a low credit risk customer. To determine whether a client's credit
risk has increased significantly since origination, the group and
company would need to determine the extent of the change in
credit risk using the table below.
Group master rating
scale-band
SB 1-12
SB 13-20
SB 21-25
SICR trigger
(from origination)
Low credit risk
3 rating or more
1 rating or more
From a Namibian perspective, for Covid-19 related qualifying
exposures the SICR methodology remains unchanged
(comparing the credit risk grading) to determine whether these
exposures are classified within stage 1 or stage 2. The credit
risk grade is assessed at the time of the relief, and subsequent
monthly reviews of the status of the request and client's
performance are conducted.
Incorporation of forward-looking
information (FLI) in ECL measurement
The group determines the macroeconomic outlook, over a
planning horizon of at least three years based on the group's
global outlook and its global view of commodities.
For home services, vehicle and asset finance, card, personal,
business and other lending products these forward-looking
economic expectations are included in the ECL where
adjustments are made based on the group's macroeconomic
outlook, using models that correlate these parameters with
macroeconomic variables. Where modelled correlations are not
viable or predictive, adjustments are based on expert judgement
to predict the outcomes based on the group's macroeconomic
outlook expectations. In addition to forward-looking
macroeconomic information, other types of FLI, such as specific
event risks and industry data, have been taken into account in
ECL estimates when required, through the application of out-of-
model adjustments. These out-of-model adjustments are subject
to group credit risk management committee oversight.
The group's macroeconomic outlook is incorporated in corporate,
sovereign and bank products' client rating and include specific
forward-looking economic considerations for the individual client.
The client rating thus reflects the expected client risk for the
group's expectation of future economic and business conditions.
Further adjustments, based on point-in-time market data, are
made to the PDs assigned to each risk grade to produce PDs and
ECL representative of existing market conditions.
Default
The definition of default, which triggers the credit impaired
classification (stage 3), is based on the group and company's
internal credit risk management approach and definitions. While
the specific determination of default varies according to the
nature of the product, it is compliant to the Basel definition of
default, and generally determined as occurring at the earlier of:
■where, in the group and company's view, the counterparty is
considered to be unlikely to pay amounts due on the due date
or shortly thereafter without recourse to actions such as the
realisation of security; or
■when the counterparty is past due for more than 90 days (or, in
the case of overdraft facilities in excess of the current limit).
The group and company have not rebutted the 90 DPD rebuttable
presumption.
Write-off policy
An impaired loan is written off once all reasonable attempts at
collection have been made and there is no material economic
benefit expected from attempting to recover the balance
outstanding (i.e. no reasonable expectation of recovery).
This assessment considers both qualitative and quantitative
information, such as past performance, behaviour and recoveries.
The group assesses whether there is a reasonable expectation of
recovery at an exposure level. As such, once the below criteria are
met at an exposure level, the exposure is written off.
The following criteria must be met before a financial asset can be
written off:
■the financial asset has been in default for the period defined for
the specific product (i.e. vehicle and asset finance, mortgage
loans, etc.) which is deemed sufficient to determine whether
the group is able to receive any further economic benefit from
the impaired loan. The period defined for unsecured BCB and
CHNW products are determined with reference to post-default
payment behaviour such as cumulative delinquency, as well
as an analysis of post write-off recoveries which includes an
assessment of the factors resulting in post write-off recoveries.
Factors that are within the group's control are assessed and
considered in the determination of the period defined for each
product. The post-default payment period is generally once the
rehabilitation probability (repayment of arrear instalments) is
considered low to zero, and a period between 180 and 360 days
post default with no payments; and
■at the point of write-off, the financial asset is fully impaired
(i.e. 100% ECL allowance) with no reasonable expectation of
recovery of the asset, or a portion thereof.
As an exception to the above requirements:
■where the exposure is secured (or for collateralised structures),
the impaired exposure can only be written off once the
collateral has been realised. Post-realisation of the collateral,
the shortfall amount can be written off if it meets the second
requirement listed above.
■■CIB products, write-off are assessed on a case-by-case basis
and approved by the CIB client credit governance committee
based on the individual facts and circumstances. For unsecured
exposures, post write-off collection and enforcement activities
include outsourcing to external debt collection agents as well
as, collection/settlement arrangements to assist clients to
settle their outstanding debt. The group continuously monitors
and reviews when exposures are written off, the levels of post
write-off recoveries as well as the key factors causing post
write-off recoveries. which ensure that the group's point of
write-off remains appropriate and that post write-off recoveries
are within acceptable levels after time.
Curing
Continuous assessment is required to determine whether the
conditions that led to a financial asset being considered to be
credit impaired (i.e. stage 3) still exist. Distressed restructured
financial assets that no longer qualify as credit impaired remain
within stage 3 for a minimum period of six months (i.e. six full
consecutive monthly payments per the terms and conditions).
In the case of financial assets with quarterly or longer dated
repayment terms, the classification of a financial asset out
of stage 3 may be made subsequent to an evaluation by the
group's CIB, BCB and CHNW credit governance committee (as
appropriate), such evaluation will take into account qualitative
factors in addition to compliance with payment terms and
conditions of the agreement. Qualitative factors include
compliance with covenants and with existing financial asset terms
and conditions.
Where it has been determined that a financial asset no longer
meets the criteria for SICR, the financial asset will be moved
from stage 2 (lifetime ECL model) back to stage 1 (12-month ECL
model) prospectively.View entire presentation