M. Provisions, contingent liabilities and contingent assets
In accordance with AS 29, Provision, Contingent liabilities and Contingent Assets, the provision is recognised when the Bank has a present obligation as a result of past event, where it is probable that an outflow of resources embodying economic benefits will be required to settle the obligation, in respect of which a reliable estimate can be made. Provisions are not discounted to its present value and are determined based on best estimate required to settle the obligation at the Balance Sheet date. These are reviewed at each Balance Sheet date and adjusted to reflect the current best estimates.
A disclosure of contingent liability is made when there is:
• a possible obligation arising from a past event, the existence of which will be confirmed by occurrence or non-occurrence of one or more uncertain future events not within the control of the Bank; or
• a present obligation arising from a past event which is not recognised as it is not probable that an outflow of resources will be required to settle the obligation or a reliable estimate of the amount of the obligation cannot be made.
When there is a possible obligation or a present obligation in respect of which the likelihood of outflow of resources is remote, no provision or disclosure is made.
Contingent assets are not recognised in the financial statements.
N. Cash and cash equivalents
Cash and cash equivalents include cash in hand, balances with RBI, balances with other banks and money at call and short notice. Cash and Cash Equivalents for the purpose of Cash Flow Statement comprises Cash at Bank and in hand and short term Investments with an original maturity of less than three months and without any charge.
O. Borrowing cost
Borrowing cost includes arranger fees, processing fees, stamp duty on issuance of debenture certificates and other associated transaction cost related to borrowing from banks and other financial institutions. Borrowing costs are recognised upfront.
P. Retirement and other employee benefits
Employee benefits include Provident Fund, Employee state insurance schemes, Gratuity and Compensated Absences.
(i) Defined Contribution Plans
Retirement benefits in the form of provident fund and employee state insurance schemes are defined contribution schemes and the contributions are charged to the Profit and Loss Account for the year when the contributions to the respective funds are due. There are no other obligations other than the contribution payable to the respective funds.
(ii) Defined Benefit Plan Gratuity:
The Bank operates a defined benefit scheme for its employees, viz., gratuity scheme. The costs of providing benefits under this plan is determined on the basis of actuarial valuation at each year-end.
Separate actuarial valuation is carried out for each plan using the projected unit credit method. In accordance with the gratuity fund’s rules, actuarial valuation of gratuity liabilities is calculated based on certain assumptions regarding rate of interest, salary growth, mortality and staff alteration as per projected unit credit method.
Actuarial gains/losses are immediately taken to profit and loss account and are not deferred.
Other Employee Benefits
Compensated Absences:
The Bank accrues the liability for compensated absences based on the actuarial valuation as on the Balance Sheet date conducted by an independent actuary which includes assumptions about demographics, early retirement, salary increases, interest rates and leave utilisation. The net present value of the Banks’ obligation is determined using the Projected Unit Credit Method as on the Balance Sheet date. Actuarial gains / losses are recognised in the Profit and Loss Account in the period in which they arise.
Q. Employee Stock Compensation Cost
Employees (including senior executives) of the Bank receive remuneration in the form of share-based payment transactions, whereby employees render services as consideration for equity instruments (equity-settled transactions).
In accordance with the Guidance Note on Accounting for Employee Share-based Payments, issued by the ICAI, the cost of equity-settled transaction is measured using the fair value method and recognized, together with a corresponding increase in the "Employees Stock options outstanding account” in reserves. The cumulative expense recognized for equity-settled transactions at each reporting date until the vesting date reflects the extent to which the vesting period has expired and the Bank’s best estimate of the number of equity instruments that will ultimately vest. The expense or credit recognized in the Profit and Loss Account for a period represents the movement in cumulative expense recognized as at the beginning and end of that period and is recognized in employee benefits expense.
R. Share issue expenses
Share issue expenses are adjusted from Share Premium Account in terms of Section 52 of the Companies Act, 2013 and RBI approval in accordance with RBI/2006- 07/132 DBOD.BP. BC No. 31 / 21.04.018/ 2006-07.
S. Segment information
In accordance with guidelines issued by RBI vide DBOD. No.BRBC.81 /21.01.018/2006-07 dated April 18, 2007 and Accounting Standard 17 (AS-17) on "Segment Reporting”, the Banks’ business has been segregated into Treasury, Retail Banking and Corporate/ Wholesale Segments.
Segment revenues consist of earnings from external customers and inter-segment revenues based on a transfer pricing mechanism. Segment expenses consist of interest expenses including allocated operating expenses and provisions. Segment results are net of segment revenues and segment expenses.
Segment assets include assets related to segments and exclude tax related assets. Segment liabilities include liabilities related to the segment excluding net worth and dividend liability, if any.
Since the business operations of the Bank are primarily concentrated in India, the Bank is considered to operate only in the domestic segment.
T. Corporate Social Responsibility (CSR)
Expenditure towards CSR, in accordance with Companies Act, 2013, is recognised in the Profit and Loss Account.
U. Proposed Dividend
Proposed dividend / declared after the balance sheet date is accrued in the books of the Bank in the year in which the dividend is declared.
b) Draw Down from Reserves Share Premium
There has been no draw down from share premium during the year ended March 31,2025 (March 31, 2024: H Nil).
c) Appropriation to Reserves
i) Statutory Reserve
The Bank has made an appropriation of H 28.74 crores (March 31, 2024: H 53.99 crores) out of profits for the year ended March 31, 2025 to Statutory Reserve pursuant to the requirements of section 17(1) and section 11(2)(b)(ii) of Banking Regulation Act, 1949 and RBI guidelines dated September 23, 2000.
ii) Capital Reserve
During the year ended March 31, 2025, the Bank has been required to appropriate (net of taxes and statutory reserves) H 4.24 crores (March 31,2024: H Nil) from profit and loss account to capital reserves being the profit from sale of investments under HTM category as per the RBI guidelines.
iii) Investment Fluctuation Reserve
During the year ended March 31, 2025, the Bank has transferred H 7.05 crores (March 31, 2024: H 4.56 crores) from Investment Fluctuation Reserve to Profit & Loss Account as per RBI guidelines.
d) Proposed dividend
The Board of Directors of the Bank has not proposed any dividend for the year ended March 31, 2025 (March 31,2024: H Nil).
ii) Qualitative information on Liquidity Coverage Ratio (LCR) is given below:
The objective of LCR is to ensure that the Bank maintains an adequate stock of unencumbered High Quality Liquid Assets (HQLA) that can be converted into cash to meet its liquidity needs for a 30-day period under a significantly severe liquidity stress scenario. At a minimum, the stock of liquid assets should enable the Bank to survive until day 30 of the stress scenario, by which time it is assumed that appropriate corrective actions can be taken.
The LCR is calculated by dividing the amount of High Quality Liquid unencumbered Assets (HQLA) by the expected net cash outflows over a stressed 30 day period as per the RBI Guidelines. Minimum LCR requirement for small finance banks is 100%.
HQLA comprises of cash in hand, excess CRR, excess SLR/Non SLR securities, maximum liquidity facility allowed by RBI under marginal standing facility (MSF) and Facility to Avail Liquidity for Liquidity Coverage Ratio (FALLCR).
The Asset Liability Committee (ALCO) governs the Liquidity Risk management of the Bank. The liquidity profile of the Bank is monitored and measured by the Risk Management Department, which reviews liquidity under different business conditions and places the same before the ALCO.
The net cash outflows are calculated by applying RBI prescribed outflow factors to the various categories of liabilities (deposits, borrowings), as well as to undrawn commitments and other miscellaneous liabilities, partially offset by expected inflows from assets maturing within 30 days.
The average LCR for the quarter ended March 31, 2025 was at 141.20% as against 144.89% for the quarter ended March 31, 2024, and well above the present prescribed minimum requirement of 100%. The average HQLA for the quarter ended March 31, 2025 was H 2,793.35 crores, as against was H 1,735.93 crores for the quarter ended March 31, 2024.
C) Net stable funding Ratio (NSFR)
As per the RBI guideline vide circular RBI circular RBI/2017-18/178 DBR.BRBC.No.106/21.04.098/2017-18 dated May 17,2018 , RBI/2020-21/95 DOR.No.LRG.BC.40/21.04.098/2020-21 dated February 06,2021 and RBI/2020-21 DOR.BRBC No.16/21.04.098/2020-21 dated Septemebr 06, 2021 is required to maintain the NSFR on an ongoing basis. The objective of NSFR is to ensure that banks maintain a stable funding profile in relation to the composition of their assets and off-balance sheet activities. A sustainable funding structure is intended to reduce the probability of erosion of a bank’s liquidity position due to disruptions in a bank’s regular sources of funding that would increase the risk of its failure and potentially lead to broader systemic stress. The NSFR limits overreliance on short-term wholesale funding, encourages better assessment of funding risk across all on- and off-balance sheet items, and promotes funding stability.
The NSFR is defined as the amount of available stable funding relative to the amount of required stable funding. "Available stable funding” (ASF) is defined as the portion of capital and liabilities expected to be reliable over the time horizon considered by the NSFR, which extends to one year. The amount of stable funding required (""Required stable funding"") (RSF) of a specific institution is a function of the liquidity characteristics and residual maturities of the various assets held by that institution as well as those of its off-balance sheet (OBS) exposures. The above ratio should be equal to at least 100% on an ongoing basis. The NSFR as on March 31,2025 was at 159.15% (March 31, 2024: 151.70%).
e) Divergence in asset classification and provisioning
RBI vide its circular DBR.BP.BC.No.63/21.04.018/2016-17 dated April 18, 2017 and Notification dated April 1,2019, has directed banks shall make suitable disclosures, if either or both of the following conditions are satisfied:
(a) the additional provisioning for non-performing assets (NPAs) assessed by the RBI exceeds 5% of the reported profit before provisions and contingencies for the reference period, and/ or
(b) the additional Gross NPAs identified by the RBI exceed 5% of the reported incremental Gross NPAs for the reference period.
There has been no divergence observed by the RBI for the Financial year 2024-25 in respect of the Bank’s asset classification and provisioning as per the extant prudential norms on income recognition asset classification and provisioning (IRACP) which require such disclosures.
f) Disclosure of transfer of loan exposures
Details of loans transferred/acquired during the year ended March 31,2025 under the RBI Master Direction on Transfer of Loan Exposures dated September 24, 2021 are given below:
e) Factoring exposures
The factoring exposure of the Bank as at March 31, 2025 is H 259.37 Crores (March 31, 2024 : H Nil)
f) Intra Group Exposure
The Bank does not have any intra group exposure as at March 31, 2025 (March 31,2024 : H Nil).
g) Unhedged Foreign Currency Exposure
In accordance with the RBI guidelines on Banks’ exposures to entities with Unhedged Foreign Currency Exposure ('UFCE’), the Bank has put in place a mechanism to seek information from its borrowers and to evaluate the currency induced credit risk. In the case of listed entities, the Bank obtains information relating to unhedged positions based on the latest available audited / reviewed financial statements; whilst in the case of unlisted / private companies, the Bank obtains the aforesaid information based on the latest available audited financial statements (not exceeding a financial year) so as to estimate the extent of likely loss and to provide for incremental capital or to recognise incremental provision in accordance with the aforesaid guidelines. Further, as per the above-mentioned guidelines, the Bank obtains audited and certified UFCE information from the statutory auditors of the borrowers, wherever feasible, on an annual basis. In the case of smaller entities i.e. entities with exposure to banking industry up to H 50 crore, the Bank recognises an incremental provision at 10 basis points on all such exposures.
In accordance with RBI guidelines, as at March 31,2025 the Bank holds UFCE provisions of H 4.21 crores (March 31,2024: H 2.14 crores) maintains capital of H 85.32 crore (March 31,2024: H 39.53 crore) in respect of the unhedged foreign currency exposure of its customers
12. Disclosure of penalties imposed by the Reserve Bank of India
During the year ended March 31,2025, no penalties were imposed on Suryoday Small Finance Bank Limited by the Reserve Bank of India. (March 31,2024: H 0.001 crore).
13. Disclosures on remuneration A) Qualitative Disclosures
(a) Information relating to the composition and mandate of the Nomination and Remuneration Committee:
The Nomination and Remuneration Committee of the Board ("NRC”) is the main body overseeing remuneration of the Directors, Key Managerial Personnel ("KMPs”), and Senior Management Personnel ("SMPs”) of the Bank. As on March 31, 2025, the NRC had four (4) members of which three (3) are Independent Directors. The functions of the Committee include formulating criteria to determine independence of Directors, identifying persons for appointment as Directors on the Board of the Bank, devising a Policy on Board Diversity, formulating criteria for evaluation of the performance of the Board, its Committees and individual Directors, recommending remuneration of KMPs and SMPs, administering, monitoring and formulating detailed terms and conditions of the Employees' Stock Option Scheme of the Bank, recommending to the Board Policy on Succession Planning for the Board and senior management and overseeing and reviewing the succession plans from time to time.
The Composition of NRC committee as on March 31, 2025 is as follows:
1. Mr. Mrutunjay Sahoo, Independent Director (Chairman upto September 21, 2024)
2. Mrs. Swati Datye, Independent Director (member upto September 29, 2024; and thereafter Chairperson w.e.f. September 30, 2024)
3. Mr. Arun Diaz, Independent Director
4. Mr. Krishana Prasad Nair, Independent Director
5. Mr. Ranjit Shah, Investor Director
6. Mr. Jyotin Mehta, Independent Director (w.e.f. September 30, 2024 upto February 12, 2025)
External consultants whose advice has been sought, the body by which they were commissioned, and in what areas of the remuneration process
Not Applicable
Scope of the Bank's remuneration policy (e.g. by regions, business lines), including the extent to which it is applicable to foreign subsidiaries and branches
(a) The Policy on appointment and remuneration of Directors, Key Managerial personnel and senior management employees was approved by the Board on January 23, 2017 and reviewed periodically. It was modified in October 2020 to exclude the remuneration aspects in view of new Compensation Policy being formulated and approved by the Board.
(b) The Bank's new Compensation Policy (formulated in accordance with RBI Guidelines on Compensation of Whole Time Directors, Chief Executive Officers, Material Risk Takers and Risk Control & Compliance Staff), was approved by the Board in October 2020 and is annually reviewed.
(c) The Employee Policies Manual of the Bank was approved by the Board on January 23, 2017 and is reviewed periodically. It covers compensation policy for all other employees of the Bank.
Type of employees covered and number of such employees by the Compensation Policy and the Employee Policies Manual.
All permanent employees of the Bank are covered. The total number of permanent employees of the Bank at March 31, 2025 was 8,649.
(b) Information relating to the design and structure of remuneration processes of remuneration processes and the key features and objectives of remuneration policy:
Key features and objectives of Compensation policy: The Bank, under the guidance of the NRC and the Board, follows remuneration practices that are intended to drive meritocracy and performance based on a prudent risk management framework and in line with the RBI guidelines.The NRC has oversight over compensation to senior management personnel and also provides overall guidance to the compensation paid to other employees.While the Bank seeks to achieve a mix of fixed and variable (cash and non-cash) remuneration for employees covered under the new Compensation Policy, for all other employees, it has predominantly a fixed remuneration structure with no guaranteed bonuses. Also, the remuneration of employees in financial and risk control functions is not linked to business outcomes and solely depends on their performance. Further, the Bank has an Employee Stock Option Scheme for eligible employees aimed at aligning compensation to long term performance through stock options that vest over a period of time.
Effective governance of compensation: The NRC has oversight over compensation to senior management personnel and also provides overall guidance to the compensation paid to other employees.
Alignment of compensation philosophy with prudent risk taking: While the Bank seeks to achieve a mix of fixed and variable (cash and non-cash) remuneration for employees covered under the new Compensation Policy, for all other employees, it has predominantly a fixed remuneration structure with no guaranteed bonuses. Also, the remuneration of employees in financial and risk control functions is not linked to business outcomes and solely depends on their performance. Further, the Bank has an Employee Stock Option Scheme for eligible employees aimed at aligning compensation to long term performance through stock options that vest over a period of time.
Whether the remuneration committee reviewed the firm's remuneration policy during the past year, and if so, an overview of any changes that were made: Yes; the Compensation Policy was modified and approved during the period . The keys changes included roles identified for Material Risk Takers and Risk Control Staff and change in deferment period for cash variable.
Discussion of how the Bank ensures that risk and compliance employees are remunerated independently of the businesses they oversee: The remuneration of employees in control functions such as Risk and Compliance depends solely on their performance and is not linked to any business outcomes.
(c) Description of the ways in which current and future risks are taken into account in the remuneration processes including the nature and type of the key measures used to take account of these risks:
Overview of the key risks that the Bank takes into account when implementing remuneration measures: The Board approves the overall risk management policy including risk framework, limits, etc. The Bank conducts all its business
activities within this framework. The NRC while assessing the performance of the Bank and senior management, shall consider adherence to the policies and accordingly make its recommendations to the Board.The evaluation process shall incorporate both qualitative and quantitative aspects including asset quality, provisioning, increase in stable funding sources, refinement/improvement of the risk management framework, effective management of stakeholder relationships and mentoring key members of the top and senior management.In order to ensure alignment of remuneration with prudent practices, the NRC takes into account adherence to the risk framework in addition to business performance.
Overview of the nature and type of key measures used to take account of these risks, including risk difficult to measure:
The evaluation process shall incorporate both qualitative and quantitative aspects including asset quality, provisioning, increase in stable funding sources, refinement/improvement of the risk management framework, effective management of stakeholder relationships and mentoring key members of the top and senior management.
Discussion of the ways in which these measures affect remuneration: In order to ensure alignment of remuneration with prudent practices, the NRC takes into account adherence to the risk framework in addition to business performance.
Discussion of how the nature and type of these measures have changed over the past year and reasons for the changes, as well as the impact of changes on remuneration: With the introduction of the new Compensation Policy, the compensation structure of employees covered therein has undergone a change resulting in an increase in overall remuneration.
(d) Description of the ways in which the bank seeks to link performance during a performance measurement period with levels of remuneration:
Overview of main performance metrics for the Bank, top level business lines and individuals: The main performance metrics include profitability, business growth, asset quality, compliance, and customer service.The assessment of employees shall be based on their performance with respect to their result areas and shall include the metrics mentioned above.
Discussion of how amounts of individual remuneration are linked to the Bank-wide and individual performance: The
assessment of employees shall be based on their performance with respect to their result areas and shall include the metrics mentioned above.
Discussion of the measures the Bank will in general implement to adjust remuneration in the event that performance metrics are weak, including the Bank's criteria for determining ‘weak' performance metrics: In case such an event should occur, the Board/NRC shall review and provide overall guidance on the corrective measures to be taken.
(e) A discussion of the bank's policy on deferral and vesting of variable remuneration and a discussion of the bank's policy and criteria for adjusting deferred remuneration before vesting and after vesting:
Discussion of the Bank's policy on deferral and vesting of variable remuneration and, if the fraction of variable remuneration that is deferred differs across employees or groups of employees, a description of the factors that determine the fraction and their relative importance: Under the new Compensation Policy, the cash variable component will be deferred over 2-3 years and the non-cash variable component (employee stock options) will be deferred over the vesting period as per the extant ESOP Scheme. In case of other employees, where cash variable is not applicable and in case of employees being granted ESOPs, they will be deferred over the vesting period as per the extant ESOP Scheme. In the case of employees covered under the Compensation Policy, all deferred variable compensation would be subjected to malus/clawback arrangements as provided in the RBI guidelines and this would be administered by the NRC.
Discussion of the Bank's policy and criteria for adjusting deferred remuneration before vesting and (if permitted by national law) after vesting through claw back arrangements: In the case of employees covered under the Compensation Policy, all deferred variable compensation would be subjected to malus/clawback arrangements as provided in the RBI guidelines and this would be administered by the NRC.
(f) Description of the different forms of variable remuneration that the Bank utilises and the rationale for using these different forms: As per the Compensation Policy, the variable remuneration will comprise of cash and non-cash components.
Overview of the forms of variable remuneration offered. A discussion of the use of different forms of variable remuneration and, if the mix of different forms of variable remuneration differs across employees or group of employees, a description of the factors that determine the mix and their relative importance: As per the new Compensation Policy, only the employees falling under the categories of Material Risk Takers (MRTs), Risk Control & Compliance Staff (RCS) and All Other Employees (AOEs) and who donot earn performance linked incentives, are eligible for variable remuneration which could be in cash and/or non- cash forms. The Policy also determines the category-wise mix of the variable compensation payable.
f). Implementation of IFRS converged Indian Accounting Standards (Ind AS)
As per the RBI circular RBI/2015-16/315 DBR.BRBC. No.76/21.07.001/2015-16 dated February 11, 2016 Implementation of Indian Accounting Standards (Ind AS), The banks are advised to follow the Indian Accounting Standards as notified under the Companies (Indian Accounting Standards) Rules, 2015, subject to any guideline or direction issued by the the Reserve Bank in this regard. The Banks in India currently prepare their financial statements as per the guidelines issued by the RBI, the Accounting Standards notified under section 133 of the Companies Act, 2013 and generally accepted accounting principles in India (Indian GAAR). In January 2016, the Ministry of Corporate Affairs issued the roadmap for implementation of new Indian Accounting Standards (Ind AS), which were based on convergence with the International Financial Reporting Standards (IFRS), for scheduled commercial banks, insurance companies and non-banking financial companies (NBFCs). In March 2019, RBI deferred the implementation of Ind AS for banks till further notice as the recommended legislative amendments were under consideration of Government of India. The Bank had undertaken preliminary diagnostic analysis of the GAAR differences between Indian GAAR vis-a-vis Ind AS and shall proceed for ensuring the compliance as per applicable requirements and directions in this regard.
The Expected life of the stock option is based on historical data and current expectation and is not necessarily indicative of the pattern that may occur.
The expected volatility reflects the assumption that the historical volatility of a comparable listed entity for 6 years period ended on the date of the grant is indication of future trends which may not necessarily be the actual outcome.
16. Segment Reporting
Business segments have been identified and reported taking into account, the customer profile, the nature of products and services, the differing risks and returns, the organisation structure and the guidelines prescribed by the RBI. The Bank operates in the following segments:
a) Treasury
Treasury performs liquidity management activities for various business segments. Transfer pricing is based on internally approved yield curve or at an agreed transfer rate on the funding provided by treasury to another business segment.
b) Retail banking
The retail banking segment serves retail customers through a branch network. Exposures are classified under retail banking taking into account the status of the borrower (orientation criterion), the nature of product, granularity of the exposure and the quantum thereof.
Revenues of the retail banking segment are primarily derived from interest and fees earned on retail loans, interest on deposits placed as collateral with the Bank. Expenses of this segment primarily comprise interest expense on borrowings, deposits, infrastructure and premises expenses for operating the branch network, personnel costs and other direct overheads.
c) Corporate banking
Wholesale banking includes all advances to borrowers, which are not included under Retail banking. Revenues of the wholesale banking segment consist of interest and fees on loans made to customers.
d) Other Banking Operation
Other Banking includes other items not attributable to any particular business segment. This segment includes income from para banking activities such as distribution of third party product and the associated costs.
e) Unallocated
All items which are reckoned at an enterprise level are classified under this segment. This includes other unallocable assets and liabilities such as deferred tax etc.
Geographical segments
The business operations of the Bank are concentrated in India hence the Bank is considered to operate only in domestic segment.
g) There are no such items in other assets and in other liabilities exceeding 1% of total assets to be disclosed as per Reserve Bank of India (Financial Statements - Presentation and Disclosures) Directions, 2021, updated as on February 20, 2023.
h) Micro, Small and Medium Enterprises (MSME) sector - Restructuring of Advances
The Bank has restructured accounts in accordance with RBI circular on Micro, Small and Medium enterprise (MSME) sector) - Restructuring of advances
1. Resolution Framework 2.0 - Resolution of Covid-19 related stress of Micro, Small and Medium Enterprises (MSMEs)_ RBI/2021-22/32/DOR.STR.REC.12/21.04.048/2021-22.
2. Micro, Small and Medium Enterprises (MSME) sector -Restructuring of Advances circular DOR.No.BP.BC.34/21.04.048/2019- 20 dated February 11,2020.
o) Disclosure on the scheme for sustainable structuring of stressed assets
The Bank does not have any account under the Scheme for Sustainable Structuring of Stressed Assets (S4A) as on March 31, 2025 (March 31,2024: H Nil).
p) Disclosure on flexible structuring of existing loans
The Bank does not have any account under the Scheme Flexible Structuring of Existing Loans as on March 31, 2025 (March 31,2024: H Nil).
q) Disclosure on strategic debt restructuring (SDR) scheme
The Bank does not have any account under the strategic debt restructuring (SDR) scheme as on March 31, 2025 (March 31,2024: H Nil).
r) Disclosure on change in ownership of project under implementation
The Bank does not have any account which are currently under the scheme of Change in Ownership of Projects Under Implementation as on March 31, 2025 (March 31, 2024: H Nil).
s) Disclosure on change in ownership outside SDR scheme
The Bank does not have any account which are currently under the scheme of Change in Ownership Outside SDR as on March 31,2025 (March 31, 2024: H Nil).
t) The Code on Social Security, 2020
The Code on Social Security, 2020 ('Code') relating to employee benefits during employment and post-employment benefits received Presidential assent in September 2020. The Code has been published in the Gazette of India. However, the date on which the Code will come into effect has not been notified and the final rules/interpretation have not yet been issued. The Company will assess the impact of the Code when it comes into effect and will record any related impact in the period the Code becomes effective.
u) No proceedings have been initiated on or are pending against the Bank for holding benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and Rules made thereunder.
v) The Bank has no transactions with the companies struck off under Companies Act, 2013 or Companies Act, 1956.
w) The Bank, as part of its normal banking business, that is conducted ensuring adherence to all regulatory requirements, grants loans and advances, makes investments and accepts deposits and borrowings from its customer, other entities and persons.
(i) Other than the transactions described above which are carried out in the normal course of business, the Bank has not advanced or loaned or invested funds to any other person(s) or entity(ies), including foreign entities (Intermediaries) with the understanding that the Intermediary shall directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Bank (Ultimate Beneficiaries) or provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries.
(ii) The Bank has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Party) with the understanding (whether recorded in writing or otherwise) that the Bank shall directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (Ultimate Beneficiaries) or provide any guarantee, security or the like on behalf of the ultimate beneficiaries.
x) There is no income surrendered or disclosed as income during the current or previous year in the tax assessments under the Income Tax Act, 1961, that has not been recorded in the books of account.
y) Disclosure on Green Deposits
During the year 2024-25, the Bank has not raised Green deposits and hence the Portfolio level information on use of funds and reporting on allocation of proceeds of Green deposits to green activities/projects as mentioned in circular RBI/2023-24/14 DOR. SFG.REC.10/30.01.021/2023-24 dated April 11, 2023 is not applicable.
z) The Bank has covered its unsecured loan portfolio under the Credit Guarantee Fund for Micro Units (CGFMU) Scheme, administered by the National Credit Guarantee Trustee Company Limited (NCGTC), since FY 2022-23. As of FY 2024-25, approximately 95% of the Bank’s unsecured loan portfolio is covered under the scheme.
Till FY 2023-24, the Bank maintained NPA, provisions on the full value of loans, including those covered under the CGFMU Scheme, in line with its internal policy. From FY 2024-25, the Bank has decided to avail the benefit in accordance with Paragraph 5.9.4 of the RBI Master Circular - "Prudential Norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances” (DOR.STR.REC.8/21.04.048/2024-25) dated April 2, 2024, applicable to loans covered under the CGFMU Scheme. Consequently, NPA provisions during FY 2024-25 were made only on the portion of such loans not guaranteed under the scheme. Accordingly, the NPA provision for the year has been adjusted by H2.57 crore in respect of loans classified as NPA as on March 2024.
Similarly, the Bank used to maintain Risk Weight as per New Capital Adequacy Framework (NCAF) guidelines issued by RBI, on all the loans including those covered under the Scheme even though the same were eligible for claim under the Scheme to the extent of the guaranteed portion. Henceforth, the Bank has decided to avail the benefit as per the provisions of the RBI Circular DOR.STR.REC.67/21.06.201/2022-23 dated September 07, 2022, titled "Review of Prudential Norms - Risk Weights for Exposures guaranteed by Credit Guarantee Schemes (CGS)”. Consequently, the Risk Weight is applied only on the portion to the extent it is not guaranteed under the CGFMU Scheme, in respect of these loans. Accordingly, the capital to risk weighted asset ratio (CRAR) as at March 31,2025 is 25.83%. Had the Bank not taken the benefit of the guarantee cover under the CGFMU Scheme both in respect of NPA provisioning and CRAR computation, the CRAR as per the NCAF guidelines would have been 22.03%.
aa) Comparatives
Figures for the previous year have been regrouped wherever necessary to conform with the current year presentation.
As per our report of even date
For Mukund M. Chitale & Co. For and on behalf of the Board of Directors
Chartered Accountants Suryoday Small Finance Bank Limited
Firm Registration No: 106655W
Nilesh RS Joshi Krishna Prasad Nair Baskar Babu Ramachandran Vivek Karve
Partner Chairperson Managing Director and Director
Membership No: 114749 DIN-02611496 Chief Executive Officer DIN - 06840707
DIN-02303132
Place: Navi Mumbai Krishna Kant Chaturvedi Kanishka Chaudhary
Date: May 08, 2025 Company Secretary Chief Financial Officer
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