Expert Advisory Committee
ICAI-Expert Advisory Committee
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Query No. 28

 

Subject:     

Money market instruments – treatment and presentation by an insurance company.[1]

A. Facts of the Case

 

1. An insurance company invests its funds in the following two types of short term instruments on a regular basis.

 

      (i) Front-ended instruments like commercial paper (CP), certificate of deposit (CD) and bills under rediscounting scheme (BRD).

 

      (ii) Rear-ended instruments like fixed deposits with banks and call money on notice.

 

2. The interest on rear-ended instruments is accounted for by the company on receipt basis.  In the case of  front-ended instruments such as CP, CD and BRD, the rate of interest which the instrument should fetch is agreed upon at the time of the contract and the purchase price of the instrument is determined by discounting the face value of the instrument (the realisable value on maturity) at a rate that will fetch the buyer the interest at the agreed rate.

 

3. The querist has illustrated the accounting treatment of front-ended instruments as follows:

 

Suppose, on 1.3.1999, the company invests in commercial paper @ 10.50% for 51 days.  The commercial paper matures on 21.04.1999.  In order to fetch Rs. 5 crore @ 10.50% on maturity, the amount required to be paid for the CP comes to Rs. 4,92,77,045.  As per the accounting practice of the company, the CP would be recorded as an asset at Rs. 5 crore though the consideration paid is Rs. 4,92,77,045.  The balance of Rs. 7,22,955 would be accounted for as revenue under the account head ‘interest earned’.  On the date of the balance sheet, i.e., on 31.03.1999, the company would provide for the ‘unearned portion of interest’ on a pro-rata basis by crediting Rs. 2,83,511.76 to the account head ‘interest received in advance’ with appropriate adjustment against the revenue.

 

4. As per the querist, the government auditors have made the following observation with regard to the treatment of interest on front-ended instruments:

 

“Loans under Certificate of Deposit and Commercial Papers include Rs. 5,82,09,029 being the interest accrued but not due (Rs. 3,21,92,527) and interest receivable for the year 1998-99 (Rs. 2,60,16,502) on the ‘Certificate of Deposit’ and ‘Commercial Papers’ made during the year, resulting in aggregate overstatement in the above heads to that extent.  This has also resulted in overstatement of sundry creditors by Rs. 2,60,16,502.”

 

5. The directors’ reply to the observation made by government auditors is as below:

 

“Short term money market instruments such as CP, CD and BRD are discounted at the time of contract at the agreed rates on the face value of such instruments and hence are accounted for at their face value, which represents their cost.  This is the standard practice of accounting for such instruments in the industry.”

 

6. According to the querist, the company discloses the unearned component of discount under the account head ‘Interest received in advance’ and if the asset value were to be read in conjunction with the aforesaid disclosure, the value of the asset cannot be said to have been overstated. The querist has contended that the transactions involving the acquisition of assets of the nature discussed above have two dimensions.  The first is the price of the instrument which is its face value and the other is the revenue component of the transaction.  As per the querist, the accounting method followed by the company gives due consideration to both these elements and accordingly records the face value of the asset as the acquisition cost while simultaneously recording the revenue component.

 

B. Queries

 

7. The querist has sought the opinion of the Expert Advisory Committee on the following issues:

 

(a) Valuation and disclosure in the balance sheet in respect of front-ended money market instruments such as certificate of deposits, commercial papers and bills under rediscounting scheme.

 

(b) Recognition of income arising from such assets.

 

C. Points Considered by the Committee

 

8. The Committee notes that the querist has sought its opinion only in respect of the front-ended instruments.  Therefore, it restricts itself to the queries raised and does not express opinion on other aspects covered by the query.

 

9. Accounting Standard (AS) 13, ‘Accounting for Investments’, issued by the Institute of Chartered Accountants of India, requires an enterprise to classify its investments into two categories: current investments and long term investments.  The Standard defines a current investment as “an investment that is by its nature readily realisable and is intended to be held for not more than one year from the date on which such investment is made”.  The Committee notes that the investment in CP, CD and BRD is made by the company for short term. Considering the nature of the aforesaid instruments and the intended period of holding them, the Committee is of the view that these instruments are in the nature of current investments.

 

10. The Committee notes paragraph 31 of AS 13 which states as below:

 

“31. Investments classified as current investments should be carried in the financial statements at the lower of cost and fair value determined either on an individual basis or by category of investment, but not on an overall (or global) basis.”

 

11. The Committee is of the view that the cost of the front-ended instruments like CP, CD and BRD is the amount paid by the company to acquire them.  Accordingly, the Committee is of the view that such instruments should be presented in the balance sheet at the amount paid to acquire them or their maturity value, whichever is lower.  The comparison of the amount paid to acquire such instruments and their maturity value should be made either on individual investment basis or by category of investment.

 

12. The Committee is of the view that the discount at which certificates of deposit and commercial paper have been acquired (i.e., the difference between the amount paid by the company to acquire the aforesaid instruments and their maturity value) represents interest on funds invested in those instruments.  In this regard, the Committee notes paragraph 13 of Accounting Standard (AS) 9, ‘Revenue Recognition’ issued by the Institute of Chartered Accountants of India, which states as below:

 

“13. Revenue arising from the use by others of enterprise resources yielding interest, royalties and dividends should only be recognised when no significant uncertainty as to measurability or collectability exists.  These revenues are recognised on the following bases:

 

(i) Interest: On a time proportion basis taking into account the amount outstanding and the rate applicable.....”

 

 

13. As regards the manner of disclosure of short term instruments and interest thereon, the Committee notes that the First Schedule to the Insurance Act, 1938 requires ‘Investments’ to be shown separately in the balance sheet, further classified in the manner given in the said Schedule.  The classification given in Form A does not cover short term instruments of the nature of CP, CD and BRD.  The Committee is of the view that these short terms instruments should be shown separately with an appropriate description of their nature.  The Committee also notes that ‘interest, dividends and rents accruing but not due’ are required to be shown separately in the balance sheet.  Accordingly, the Committee is of the view that interest on short term instruments accruing up to the date of the balance sheet should be shown under the aforesaid head.

 

14. The Committee further notes that AS 13 requires the disclosure, in the financial statements, of “the accounting policies for determination of carrying amount of investments” (paragraph 35).  Accordingly, the accounting policy followed for valuation of short term instruments like CP, CD and BRD should be disclosed in the financial statements.

 

D. Opinion

 

15. Based on the above, the Committee is of the following opinion on the issues raised in paragraph 7:

 

(a) Short-term instruments like commercial paper, certificate of deposit and bills under rediscounting scheme should be valued at the lower of cost and fair value.  Cost for this purpose would be the amount paid by the company for acquiring the respective instruments.  These instruments should be shown in the balance sheet as a separate category under the head ‘investments’.  The accounting policies for determination of carrying amount of such investments should be disclosed in the financial statements in accordance with AS 13.

 

(b)  The interest on the aforesaid investments should be recognized on accrual basis in accordance with AS 9, ‘Revenue Recognition’.  The interest accruing upto the balance sheet date should be shown in the balance sheet under the head ‘interest, dividends and rents accruing but not due’.

 

 

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[1]Opinion finalised by the Committee on 23.7.1999.