Annual Financial Statements 2020
18
ANNUAL FINANCIAL STATEMENTS REPORT OF THE INDEPENDENT AUDITOR CONTINUED
STANDARD BANK NAMIBIA LIMITED
Annual financial statements 2020
19
Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial
statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in
forming our opinion thereon, and we do not provide a separate opinion on these matters.
Key audit matter
Expected credit losses on Corporate and Investment Banking
(CIB) loans and advances
Refer to Expected Credit Loss (ECL) on financial assets - IFRS 9
drivers, included within the Key management assumptions note, note
6 (loans and advances), note 31 (credit impairment charges), the
credit risk section of annexure C- Risk and Capital Management, and
the impairment section in the detailed accounting policies in the
financial statements, for the related disclosures.
The ECL assessment for CIB loans and advances is material to the
financial statements in terms of their magnitude, the level of
subjective judgement applied by management and the effect that the
ECL has on the Company's credit risk management processes and
operations. This resulted in this matter being considered a matter of
most significance to the audit of the financial statements.
The ECL on CIB loans and advances was calculated by applying
International Financial Reporting Standard (IFRS) 9 - Financial
Instruments (IFRS 9), as described in the notes to the financial
statements.
ECLS on CIB exposures are calculated separately based on rating
models for per customer. In calculating the ECL on CIB loans and
advances, the key areas of significant management judgement and
estimation included:
•
Evaluation of Significant Increase in Credit Risk ("SICR") taking
into account the estimated impact of COVID-19;
⚫ Incorporation of macro-economic inputs and forward looking
information into SICR assessment and ECL measurement;
•
•
Input assumptions applied to estimate the probability of default
("PD"), exposure at default ("EAD") and loss given default ("LGD")
within the ECL measurement; and
Incorporation of the estimated impact of COVID-19 on the key
inputs into the ECL pertaining to forward-looking information.
Evaluation of SICR taking into account the impact of COVID-19
For CIB exposures, SICR is largely driven through the movement in
credit ratings assigned to counterparties on origination and reporting
date, based on the Company's 25-point master rating scale to
quantify credit risk for each exposure.
With regard to COVID-19 related qualifying exposures the credit risk
grade is assessed at the time of relief and subsequent monthly
reviews are performed.
Incorporation of macro-economic inputs and forward-looking
information into SICR assessment and ECL measurement
Macroeconomic expectations are incorporated in CIB's client ratings
to reflect the Company's expectation of future economic and business
conditions.
Input assumptions applied to estimate the PD, EAD and LGD
within the ECL measurement
Input assumptions applied to estimate the PD, EAD and LGD as inputs
into the ECL measurement are subject to management judgement
and are determined at an exposure level.
How our audit addressed the key audit matter
Our audit procedures addressed the key areas of significant
judgement and estimation in determining the ECL on CIB loans and
advances as follows:
We assessed the accounting policies applied to the CIB segment
against the requirements of IFRS noting no material inconsistencies.
Making use of our actuarial expertise, we assessed the Company's
ECL methodology applied in determining the ECL recognised on CIB
loans and advances against the requirements of IFRS 9, and noted no
material inconsistencies.
Making use of our actuarial expertise, we also independently
recalculated the ECL on CIB loans and advances by independently
calculating parameters and comparing the results against the ECL
calculated by the Company and noted no material differences in this
regard.
Evaluation of SICR taking into account the impact of COVID-19
Through inquiry of management and inspection of underlying
documentation we obtained an understanding of and tested relevant
controls relating to the approval of credit facilities, subsequent
monitoring and remediation of exposures, key system reconciliations
and collateral management.
We selected a sample of counterparties and assessed the
appropriateness of their assigned credit rating by:
•
Testing the inputs into the credit rating system against the financial
information relating to the exposure and the Company's 25-point
rating scale noting no material exceptions; and
Making use of our actuarial expertise, we assessed the
reasonableness of management's assumptions made during the
credit risk rating process, by performing the following procedures:
Through inquiry of management we obtained an understanding
of the process for assigning credit ratings based on the exposure
type and industry factors; and
Performing an independent assessment of the credit risk rating
assigned to the exposure by assessing the quantitative and
qualitative factors, including the impact of COVID-19 pandemic,
assigned by management against our independent expectation.
Based on the results of our work performed, we accepted
management's assumptions.
For a sample of stage 1 and stage 2 exposures we assessed whether
the stage classification of these exposures was appropriate in terms
of the Company's accounting policy for SICR based on the change in
credit risk at reporting date since the origination date of these
exposures. Our procedures included the inspection of the credit risk
ratings at reporting date relative to origination date to assess whether
the Company's SICR policy has been applied consistently. No material
exceptions were noted.
Incorporation of macro-economic inputs and forward looking
information into SICR assessment and ECL measurement
We selected a sample of exposures and assessed the reasonableness
of the forward-looking information incorporated into their assigned
credit risk ratings. Through inquiry with management, we obtained an
understanding of the forward-looking information that was
incorporated into the assigned credit rating for the exposure and
evaluated the reasonableness of the forward-looking information
against management's expectations and other industry factors for the
SICR assessment and ECL measurement. Based on our work
performed, we accepted the forward-looking information incorporated
into the model.
Input assumptions applied to estimate the PD, EAD and LGD
within the ECL measurement
Making use of our internal actuarial expertise, we assessed the
reasonableness of the input assumptions applied within the PD, EAD
and LGD models for compliance with the requirements of IFRS 9 by
performing an independent recalculation of PD, EAD and LGD. In
addition, our procedures included assessing the appropriateness of
the statistical models by way of reperformance and validation
procedures. We did not note any material variances.
Key audit matter
Expected credit losses Personal and Business Banking (PBB) loans
and advances
Refer to Expected Credit Loss (ECL) on financial assets - IFRS 9 drivers,
included within the Key management assumptions note, note 6 (loans
and advances), note 31 (credit impairment charges), the credit risk
section of annexure C - Risk and Capital Management, and the
impairment section in the detailed accounting policies in the financial
statements, for the related disclosures.
The ECL assessment for PBB loans and advances is material to the
financial statements in terms of their magnitude, the level of subjective
judgement applied by management and the effect that the ECL has on the
Company's credit risk management processes and operations. This
resulted in this matter being considered a matter of most significance in
the audit of the financial statements.
ECLS on PBB loans and advances are based on the product categories or
subsets of the product categories, with tailored ECL models per portfolio.
The key areas of significant management judgement within the ECL
calculation include:
• Evaluation of SICR taking into account the estimated impact of
COVID-19;
•
•
•
Incorporation of macro-economic inputs and forward looking
information into SICR assessment and ECL measurement;
Application of out-of-model adjustments into the ECL measurement;
Assessment of ECL raised for individual exposures;
Input assumptions applied to estimate the PD, EAD and LGD within the
ECL measurement; and
Incorporation of the estimated impact of COVID-19 on the key inputs
into the ECL pertaining to forward-looking information.
Evaluation of SICR taking into account the impact of COVID-19
The Company determines the SICR threshold by utilising an appropriate
transfer rate of exposures that are less than 30 days past due (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 day 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.
As a result of Bank of Namibia's response to the economic and financial
stability challenges posed by the COVID-19 pandemic, where a restructure
is considered by the counterparty as a result of COVID-19, the Company
applies judgement in determining the following:
•
determining whether the exposure is expected to remain in 'an not
overdue status' subsequent to the relief period, and
assessing whether the restructure can be classified as a temporary or
permanent distress.
Incorporation of macro-economic inputs and forward looking
information into SICR assessment and ECL measurement
Forward-looking expectations are included in the ECL for PBB loans and
advances based on the Company's macro-economic outlook, using
models that correlate these parameters with macro-economic variables.
Where modelled correlations are not viable or predictive, adjustments are
based on judgement to predict the outcome based on the Company's
macro-economic outlook expectations.
In the determination of the forward-looking impact, the Company applied
judgement in assessing the impact of the COVID-19 pandemic on
forward-looking information.
Application of out-of-model adjustments into the ECL measurement
Management may identify that due to modelling complexity, certain
aspects of the ECL may not be fully reflected by the underlying model and
an out-of-model adjustment is required.
Assessment of ECL raised for individual exposures
A lifetime ECL is calculated on stage 3 exposures that are assessed to be
credit impaired due to evidence of default, significant financial difficulty of
the borrower and/or modification, probability of bankruptcy or financial
reorganisation or disappearance of an active market due to financial
difficulties. This assessment relates primarily to business lending
accounts and incorporates judgement in determining the foreclosure
value of the underlying collateral.
Input assumptions applied to estimate the PD, EAD and LGD within
the ECL measurement
The ECL is calculated using statistical models which incorporate
observable data, assumptions and estimates relating to historical default
experience, timing and amount of forecasted cash flows and the value
of collateral.
How our audit addressed the key audit matter
Our audit procedures addressed the key areas of significant judgement
and estimation in determining the ECL on PBB loans and advances as
follows:
We assessed the accounting policies applied to the PBB segment
against the requirements of IFRS 9 noting no material inconsistencies.
Making use of our actuarial expertise, we assessed the Company's ECL
methodology applied in determining the ECL recognised on PBB loans
and advances against the requirements of IFRS 9, and noted no
material inconsistencies.
Making use of our actuarial expertise, we also independently
recalculated the ECL on PBB loans and advances by independently
calculating parameters and comparing the results against the ECL
calculated by the Company and noted no material differences.
Evaluation of SICR taking into account the impact of COVID-19
Making use of our actuarial expertise,we reperformed the calculation
of the significant deterioration roll rates per product category and
compared these rates per product category to those used by
management and noted no material differences.
For a sample of exposures which were manually transferred by
management we assessed if these transfers were appropriate through
discussions with management and inspection of underlying
documentation. No material exceptions were noted.
For a sample of stage 1, 2 and 3 exposures, we evaluated if the
exposures are appropriately classified by recalculating the days in
arrears. For exposures that were more than 30 days past due, we
confirmed that these were appropriately classified. No material
exceptions were noted.
For a sample of exposures classified as COVID-19 related restructures
we assessed the reasonableness of the staging and classification
assigned to these exposures by assessing the payment history before
and after the relief term. We found no material exceptions in the
staging and classification of these exposures.
Incorporation of macro-economic inputs and forward looking
information into SICR assessment and ECL measurement
Making use of our actuarial expertise, we evaluated the
appropriateness of forward-looking economic expectations included in
the ECL model which included the impact of COVID-19 by comparing
the forward-looking expectations to independently sourced industry
data and noted no material inconsistencies.
Application of out-of-model adjustments into the ECL
measurement
For a sample of out-of-model adjustments we evaluated the
reasonableness of the adjustments by assessing key assumptions,
inspecting the calculation methodology and tracing a sample of
out-of-model adjustments back to source data.
Assessment of ECL raised for individual exposures
For a sample of stage 3 exposures, we independently recalculated the
impairment losses based on our assessment of the expected cash
flows and the recoverability of collateral at an individual exposure level.
No material differences were noted.
For collateral held in respect of the sample of stage 3 exposures
referred to above, we inspected legal agreements and other
documentation to assess the existence and legal right to collateral. No
material exceptions were noted.
We assessed the collateral valuation techniques applied by
management against the Company's valuation guidelines. Making use
of our valuation expertise we performed an independent reasonability
test on the valuation of collateral. Although our independent internal
reasonability tests differed from external valuations in some instances,
no material adjustments to the ECLS on PBB loans and advances were
considered necessary.
Input assumptions applied to estimate the PD, EAD and LGD
within the ECL measurement
Making use of our actuarial expertise, we assessed the assumptions
relating to historical default experience, estimated timing and amount
of forecasted cash flows and the value of collateral applied within the
PD, EAD and LGD models for compliance with the requirements of
IFRS 9. In addition, our procedures included assessing the
appropriateness of the statistical models by way of reperformance
and validation procedures. We did not note any material differences
on the assumptions applied in the calculation of the ECL at year end.View entire presentation