SBN HOLDINGS LIMITED Annual Report 2022
ACCOUNTING POLICY ELECTIONS AND RESTATEMENTS continued
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SBN HOLDINGS LIMITED
Annual report 2022
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future participation in changes in investment values over the
remaining life of the contract. An optional simplified premium
allocation approach (PAA) is available for contracts that have
a coverage period of 12 months or less, or if it is reasonably
expected that the PAA would produce a measurement of the
liability for remaining coverage (LRC) that would not materially
differ from the one produced applying the GMM. The PAA
is similar to the current unearned premium reserve profile
recognised over time.
Quantitative impact: Management has developed a better
understanding of the transition statement of financial position
to be presented as at 1 January 2022, although this is still
a work in progress and subject to certain assumptions and
estimates being finalised. The impact of IFRS 17 can only be
reliably determined on the date of transition of IFRS 17. This
impact is primarily dependent on the finalisation of the group's
methodologies, assumptions and estimates, conclusion of
audit procedures by the group's external auditors as well as the
group's internal reviews and validations.
Transition approaches: The standard requires retrospective
application of IFRS 17 prior to the transition date, which
is 1 January 2022, unless it is impracticable to do so. If it
is impracticable, an entity can choose either between the
modified retrospective or a fair value approach to measure
the initial IFRS 17 balances on the transition date. The group
intends to use a combination of all three transition approaches
(namely, full retrospective, modified retrospective, and fair
value) depending on the historical data (including assumptions,
methodologies and particularly, availability of risk adjustment
data for certain years prior to the adoption of IFRS 17) that is
available per the IFRS 17 defined groups.
IFRS 9 Financial Instruments: The group applied IFRS 9 for
years commencing 1 January 2018. At this stage, there is
no expected change to previously applied classification and
designation of financial assets that back policyholder liabilities
as a result of IFRS 17.
Tax implications: Within Namibia, no specific tax legislation has
been announced or introduced relating to the introduction of
the IFRS 17 accounting statement. Current tax principles will
apply.
Regulatory capital/capital implications: At this stage, IFRS
17 should not impact any aspect of the regulatory capital
assessment.
■IAS 1 Presentation of Financial Statements (amendments)
Effective date: 1 January 2023
Background: The amendment clarifies how to classify debt
and other liabilities as current or non-current. The objective of
the amendment is aimed to promote consistency in applying
the requirements by helping entities determine whether, debt
and other liabilities with an uncertain settlement date should
be classified as current (due or potentially due to be settled
within one year) or non-current. The amendment also includes
clarifying the classification requirements for debt an entity
might settle by converting it into equity. These are clarifications,
not changes, to the existing requirements, and so are not
expected to affect entities' financial statements significantly.
However, these clarifications could result in reclassification of
some liabilities from current to non-current, and vice versa.
The amendment will be applied retrospectively. Pending the
finalisation of the exposure draft on ED/2021/9 - Non-Current
Liabilities with Covenants: Proposed Amendments to IAS 1,
the effective date of all IAS 1 amendments will be deferred to 1
January 2024. The impact on the annual financial statements
has not yet been fully determined, however not expected to
have a significant impact on the company.
■IFRS 16 Leases (narrow scope amendments)
Effective date: 1 January 2024
Background: The amendments add to requirements explaining
how a company accounts for a sale and leaseback after the
date of the transaction. IFRS 16 had not previously specified
how to measure the transaction when reporting after that date.
The amendments add to the sale and leaseback requirements
in IFRS 16, thereby supporting the consistent application of the
standard. These amendments will not change the accounting
for leases other than those arising in a sale and leaseback
transaction. The amendments will be applied retrospectively
and are not expected to have a material impact on the
company's financial statements.
Refer to Annexure D - detailed
accounting policies.
Interest rate benchmarks and reference
interest rate reform
The Financial Stability Board has initiated a fundamental review
and reform of the major interest rate benchmarks used globally
by financial market participants. This review seeks to replace
existing interbank offered rates (IBORS) with alternative risk-free
rates (ARRS) to improve market efficiency and mitigate systemic
risk across financial markets. The IBOR rates which the bank
is exposed to will be replaced by Secured Overnight Financing
Rate (SOFR), Sterling Overnight Index Average (SONIA), Euro
Short Term Rate (ESTR), Tokyo Overnight Average (TONA) and
Swiss Average Rate Overnight (SARON). In certain instances,
other suitable rates may be used, such as Central Bank Policy
Rates. While there are plans to replace JIBAR, there is currently
no indication of when the designated successor rate will be made
available.
The ARR transitioning introduces a number of risks to the
company including, but not limited to:
■model risk-risk of the valuation models used within the
company not being able to cater for the changes in the
intended manner.
■legal risk-risk of being non-compliant to the agreements
previously agreed with clients.
■ operational risk-risk of the company's systems not being
able to accommodate for the changes to the interest rates as
agreed with the clients.
■financial risk - risk of not appropriately pricing the deals
which will result in a transfer of value between the company
and clients.
■compliance/regulatory risk - risk that the bank is exposed
regulatory sanctions due to failing to meet the regulatory
expectations in relation to the transition.
■reputational risk - the risk to the bank's reputation from
failing to adequately prepare for the transition.
■conduct risk-risk that arises when transitioning existing
contracts linked to IBORS as value-transfer may occur, or
clients may be transitioned to inferior rates or on unfair
contractual terms, or in circumstances where they do not
fully appreciate the impact of the transition or the alternatives
available to them.
The bank ceased booking new IBOR linked exposures from
1 October 2021, and new exposures have been booked using
the ARRs. At 31 December 2022 the company had one USD
medium term loan and four deposits linked to three months
LIBOR that extends beyond 2022. The LIBOR's administrator,
the Intercontinental Exchange Benchmark Administration
Limited announced during the 2021 financial year that it will not
publish the three month LIBOR rate after 30 June 2023.
The company's treasury and capital management (TCM) team
manages the transition to ARRs, and is working closely with
the CIB business team to establish pricing for new lending
products indexed to the ARR in impacted jurisdictions. The
TCM team have a transition plan which details the transition
process for transition of our exposures, comprised of the
following work streams: risk management and measurement,
legal, communications, accounting and systems. Pricing is being
managed centrally by TCM using the recommendations from
the main industry bodies, namely ISDA for derivatives, Loan
Markets Association for Loans and ICMA for Bonds Markets.
We are also tracking updates and incorporating best practice
recommendations emanating from official sector working
groups established to catalyse transition. By way of policy, all
new contracts or exposures referencing IBORS include robust
fallback language, and work is underway in some areas to actively
transition the legacy exposure away from LIBOR. Changes in
impacted systems are being implemented and ready to book at
new rates. Communications to clients will continue via multiple
platforms along with one-to-one conversations. The company
is also ensuring that employees attend relevant training and
received the required updates and communication.
Financial instruments impacted by the reform which are yet to transition
Total assets recognised on the balance sheet subject to IBOR reform
Loans and advances²
USD LIBOR
2022
N$'000
USD LIBOR
2021
N$'000
515 016
660 744
515 016
660 744
545 379
564 810
Total liabilities recognised on the balance sheet subject to IBOR reform
Deposits and current accounts
545 379
564 810
1 These balances represent the notional amount directly impacted by the IBOR reform.
2 Gross carrying amount excluding allowances for expected credit losses (ECL).
Restatements
Correction of prior period errors - reconciliation differences
In the current year the group enhanced the control environment surrounding its client management system (CMS) by embedding a client
contribution report tool for accrued interest. The report tool improves the process of reconciliation of interest accrued balances between
the CMS and the balance sheet accounts. As part of the reconciliation process, all transactional data for accrued interest income, accrued
interest expense and interest in suspense for the period 2012 to 2021 was analysed:
Unsubstantiated accrued interest income of N$30.5 million, interest in suspense to the value of N$8 million, accrued interest expense
to the value of N$14.0 million and credit impairments to the value of N$23 million were adjusted and restated accordingly for periods
ended up to 31 December 2020. For the 2021 financial year, a net total of N$7.4 million in interest income and expense was restated. The
N$24.2 million normal tax impact of these restatements has also been reflected in the periods ended up to 31 December 2020. For 2021
the tax impact of N$2.4 million was also adjusted for.
The above restatement had the following impact on the primary statements within these results:
GROUP
Assets
Loans and advances
Other assets
Normal tax asset
Total assets
2021
Previously
reported
N$'000
Restatement
N$'000
Restated
N$'000
165 126
25 447 708
(65 386)
25 382 322
346 814
138 521
(3949)
342 865
26 606
(42 729)
Equity attributable to ordinary shareholders
4 379 958
(56 535)
4 323 423
Liabilities
28 242 080
13 806
(42 729)
28 255 886
Equity
Deposits and current accounts
Total equity and liabilitiesView entire presentation