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Changes in the required credit loss allowance, including the impact of movements between Stage 1 (12 month expect-
               ed credit losses) and Stage 2 (lifetime expected credit losses), will be recorded in profit or loss. Because of the impact of
               moving between 12 month and lifetime expected credit losses and the application of forward looking information, provi-
               sions are expected to be more volatile under IFRS 9 than IAS 39.

               Measurement
               “The measurement of expected credit losses will primarily be based on the product of the instrument’s probability of de-
               fault (PD), loss given default (LGD), and exposure at default (EAD), discounted to the reporting date. The main difference
               between Stage 1 and Stage 2 expected credit losses is the respective PD horizon. Stage 1 estimates will use a maximum
               of a 12-month PD while Stage 2 estimates will use a lifetime PD.
               Stage 3 estimates will continue to leverage existing processes for estimating losses on impaired loans, however, these
               processes will be updated to reflect the requirements of IFRS 9, including the requirement to consider multiple for-
               ward-looking scenarios. The Group will combine the regulatory prudential guidelines with other relevant qualitative factors
               in the “”definition of default

               An expected credit loss estimate will be produced for each individual exposure, including amounts which are subject to
               a more simplified model for estimating expected credit losses; however the relevant parameters will be modeled on a
               collective basis using largely the same underlying data pool supporting our stress testing and regulatory capital expected
               loss processes. Models have been developed, primarily leveraging our existing models for enterprise-wide stress testing.
               For the small percentage of our portfolios that lack detailed historical information and/or loss experience, we will ap-
               ply simplified measurement approaches that may differ from what is described above. These approaches have been
               designed to maximize the available information that is reliable and supportable for each portfolio and may be collective in
               nature.

               Expected credit losses must be discounted to the reporting period using the effective interest rate.

               Significant increase in credit risk (SICr)
               The Group considers a financial instrument to have experienced a significant increase in credit risk when one or more of
               the following quantitative, qualitative or backstop criteria have been met:

               quantitative criteria:
               The remaining Lifetime PD at the reporting date has increased, compared to the residual Lifetime PD expected at the
               reporting date when the exposure was first recognised.

               Deterioration in the credit rating of an obligor either based on the Bank’s internal rating system or an international credit
               rating. However the downgrade considers movement from a grade band to another e.g. Investment grade to Standard.

               The Bank also considers accounts that meet the criteria to be put on the watchlist bucket to have significantly increased in
               credit risk.

               qualitative criteria:
               •   For Retail loans, if the borrower meets one or more of the following criteria:
               •   In short-term forbearance
               •   Direct debit cancellation
               •   Extension to the terms granted
               •   Previous arrears within the last [12] months

               For Corporate portfolio, if the borrower is on the Watchlist and/or the instrument meets one or more of the following
               criteria:
               •   Significant increase in credit spread
               •   Significant adverse changes in business, financial and/or economic conditions in which the borrower operates
               •   Actual or expected forbearance or restructuring
               •   Actual or expected significant adverse change in operating results of the borrower
               •   Significant change in collateral value (secured facilities only) which is expected to increase risk of default
               •   Early signs of cashflow/liquidity problems such as delay in servicing of trade creditors/loans







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