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Income Recognition,
Asset Classification and
Provisioning (2010-2011)
         (UCB)

      NPA 2010-11


Compiled by CA. Sudhir Vaidya
Compiled by Spandane                             2                               NPA 2010-11


        Income Recognition, Asset Classification and Provisioning (2010-2011) (UCB)

 Classification of          Date of NPA                 Age of NPA           Provision required
   Assets as on
    31-03-2011

Standard                N.A.                     N.A.                     0.40 % of outstanding
                                                                          Also refer page 7 & 8
Sub-standard            Between 01-04-2010       Not more      than    12 10% of outstanding
                        To 31-03-2011            months

i) Doubtful             Between 01-04-2009       Between 13 to 24          100% of shortfall + 20%
                        To 31-03-2010            months                    of realizable security
ii) Doubtful            Between 01-04-2007       Between 25 to 48          100% of shortfall + 30%
                        To 31-03-2009            months                    of realizable security
iii) Doubtful           Prior to 31-03-2003      More than 48 months       100% of shortfall + 100%
                                                 As on 31-03-2007          of realizable security
                        Doubtful > 3 years as
                        on 31-03-2007

iv) Doubtful            Advances classified      Between 01-04-2003 To 100% of shortfall + 100%
                        as 'doubtful more        31-03-2007            of realizable security.
                        than three years' on                           i.e. 100% of O/S
                        or after April 1, 2007

Loss Assets             No criteria of date      No criteria of date       100% of outstanding


 Note      Dates of Circulars issued by RBI to All Primary (Urban) Co-operative Banks have
           been mentioned below. However the various issues discussed below are equally
           applicable to all banks. RBI issues separate circulars to commercial banks.



  1.0      Classification of Assets as Non-Performing:
                  An asset becomes non-performing when it ceases to generate
                  income for the bank.



  2.0      Asset Classification:
                  Standard Assets is one, which does not disclose any problems
                  and which does not carry more than normal risk attached to the
                                                                                         11-09-2002
                  business. Such an asset should not be an NPA.

                                       www.spandane.com
Compiled by Spandane                         3                               NPA 2010-11

               Sub-standard Asset is one which has remained as NPA for a           11-09-2002
               period not exceeding 18 months. (12 months from 31-03-2005)
               Doubtful Asset is one, which has remained in the sub-standard
               category for 18 months. (12 months from 31-03-2005)



 3.0    Income Recognition Policy:
               Income from non-performing assets (NPA) is not recognized on
               accrual basis but is booked as income only when it is actually
               received.
               Interest on advances against term deposits, NSCs, IVPs, KVPs &
               LIC policies may be taken to income account on the due date,
               provided adequate margin is available in the account.
               If any loan a/c becomes NPA as at the close of the year, interest
               accrued and credited to income account in the corresponding
               previous year, should be reversed or provided for if the same is
               not realized.



 4.1    The difference between the original advance and minimum balance
        indicates the repayment received towards the principal.
        Repayment towards principal = Original advance – Minimum balance.



 4.2    The difference between the present balance and minimum balance
        indicates the arrears of interest and charges i.e. interest and charges
        debited to the loan but not paid by the borrower.
        Interest arrears = Present balance – Minimum balance – Advance
        payments if any.



 5.0    As on 31-03-2011: In case of loans repayable in equated monthly            05-10-2001
        installments (EMI) where a part of the interest is included in the
        installment, NPA shall be determined on the basis of non-payment of
        EMI. In other words, credit summations in the borrowal account up to
                                   www.spandane.com
Compiled by Spandane                          4                                NPA 2010-11

        31-03-2011 should be divided by EMI to arrive at number of EMI
        received. If EMI due up to 31-12-2010 is received by 31-03-2011, the
        account will be classified as PA.



 6.0    The Term loan will be treated as NPA when interest and / or installment       05-10-2001
                                                                                      04-09-2004
        of principal remain overdue for a period of more than 90 days.
                                (As on 31-03-2011)
           If interest due for the quarter ended 31-12-2010 is not paid, it becomes
           NPA on 31-03-2011. (i.e. overdue for more than 90 days).
           If installment towards principal due on 31-12-2010 is not paid, it
           becomes NPA as on 31-03-2011 (i.e. overdue for more than 90 days)



 7.0    The date of existing NPA accounts will remain same as mentioned last
        year unless it was wrongly calculated last year. If account is NPA as on
        31-03-2011, then confirm whether account was classified as NPA during
        earlier years. If yes, then continue old NPA date.



 8.0    Interest receivable on all NPA accounts up to 31-03-2011 should be            28-02-1995
        reversed / Overdue provision should be made.
        Interest accrued in respect of non-performing advances should not be
        debited to borrowal accounts but shown separately under ‘Interest
        receivable account’ and corresponding amount shown under ‘Overdue
        interest reserve account’



 9.0    In respect of borrowal accounts, which are treated as performing assets,      30-03-2005
        accrued interest may be debited to the borrowal account and credited to
        interest account and taken to income account. (Instruction to create OIR
        in respect of such interest has been omitted from new paragraph
        substituted in earlier circular dated 28-02-1995)




                                    www.spandane.com
Compiled by Spandane                             5                             NPA 2010-11


 10.1   Valuation of Security in case of NPAs with balance of Rs.10 Lacs and          06-10-2001
        above:
        Stock Audit at annual intervals by external agency should be carried out.
        The Board may finalize the cut off limit and the names of the external
        agencies.
        Collaterals such as immovable properties charged in favor of the bank
        should be got valued once in 3 years by valuers appointed as per the
        guidelines approved by the Board of Directors.



 10.2   Wherever valuation report in respect of securities is not available or
        valuation could not got done in the case of doubtful debts on account of
        non co-operation of borrowers or any other justifiable reasons, then
        depreciated value of securities shall be taken into account for the purpose
        of computation of secured and unsecured portion of advance.
        Depreciated value shall be calculated on straight-line method on the
        movable assets at the following rates.
        (The said rates are suggested /based on average life of the Asset.
        Bank can provide higher rate.)
             Plant & Machinery                       15 %
             Furniture & Fixture                     15 %
             Consumer durable                        20 %
             Computers                               30 %
             Vehicle                                 20 %
        Shop, Gala, Flat, Building etc. can be valued as per prevailing property
        rates available in Govt. gazette, property magazines etc.
        Approximate value can also be found out by use of cost inflation index
        published by Govt. for purpose of calculation of capital gains. Table of
        CII is printed on cover Page-134 of V. G. Mehta’s I.T. Reckoner for
        A.Y.2010-11.
        Bank should evolve the policy for obtaining valuation of property
        charged in favour of the bank.

                                    www.spandane.com
Compiled by Spandane                            6                                 NPA 2010-11


 10.3   Significant credit impairment: Erosion in the value of of security can be       06-10-2001
        reckoned as significant when the realizable value of the security is less
        than 50 % of the value assessed by the bank or accepted by RBI at the
        time of last inspection as the case may be. Such NPAs may be
        straightaway classified under doubtful category and provisioning should
        be made as applicable to doubtful assets.



 10.4   Treatment of Loss assets: If realizable value of the security, as assessed      06-10-2001
        by the bank / approved valuer’s / RBI is less than 10 % of the O/S in the
        borrowal accounts, the existence of security should be ignored and the
        asset should be straightaway classified as Loss Asset.



 10.5   Availability of security or net worth of borrower / guarantor should not        09-02-1993
        be taken into account for the purpose of treating an advance as non-
        performing asset or other wise as income recognition is based on record
        of recovery.



 11.1   Cash Credit: CC a/c will be classified as NPA if it is out of order for more    05-10-2001
        than 90 days.                                              (As on 31-03-2011)
        i) O/S continuously > Limit / DP between
               31-12-2010 to 31-03-2011                                         NPA
        ii) If O/S < Limit and there are no credits during
              01-01-2011 to 31-03-2011                                          NPA
        iii) If there are credits, then credits should be sufficient
            to cover Interest debited during the same period.
            Otherwise cc a/c will be                                            NPA
        CC Limits sanctioned against the security of Premises, Gold etc. should
        also be classified as NPA on above criteria. CC Limits sanctioned against
        the security of LIC, NSC, TDR should be classified as NPA as per
        guidelines stated in para-12.1 stated below.


                                     www.spandane.com
Compiled by Spandane                          7                                NPA 2010-11



 11.2   Non-submission of stock statements: The o/s in the account based on           05-10-2001
        drawing power calculated from stock statements older than 3 months,
        would be deemed as irregular. A working capital borrowal account will
        become an NPA if such irregular drawings are permitted in the account
        for a continuous period of 90 days even though the unit may be working
        or the borrower’s financial position is satisfactory. Stock statement as on
        31-12-2010 should be obtained failing which the same will have to be
        classified as NPA as on 31-03-2011.



 11.3   As on 31-03-2011: Un renewed CC accounts: An account where the                05-10-2001
        regular / adhoc credit limits have not been reviewed or have not been
        renewed within 90 days from the due date / date of adhoc sanction will
        be treated as NPA.
        CC accounts having due date 31-12-2010 or prior should be renewed by
        31-03-2011, failing which the same will have to be classified as NPA as on
        31-03-2011.



 11.4   As on 31-03-2011: Bills remaining overdue for a period of more than           05-10-2001
        90 days in case of bills purchased and discounted will be classified as
        NPA. Bills having due date 31-12-2010 or prior and remaining O/S as on
        31-03-2011 will be classified as NPA as on 31-03-2011.



 11.5   Any amount to be received remaining overdue for a period of more than         05-10-2001
        90 days in respect of other accounts will be classified as NPA.



 12.1   Advances against term deposits, NSCs eligible for surrender, IVPs, KVPs
        and Life policies need not be treated as NPAs although interest thereon
        may not have been paid for more than 90 days provided adequate
        margin is available in the accounts. In other words, Advances against


                                    www.spandane.com
Compiled by Spandane                            8                               NPA 2010-11

        above security should be classified as standard, if (O/S + interest) is less
        than value of above security as on 31-03-2011.



 12.2   Gold Loan: Primary (urban) co-operative banks should fix monthly               17-06-1993
        /quarterly installments for repayment of gold loans for non-agricultural
        purposes taking into account the pattern of income generation and
        repayment capacity of the borrowers and such gold loan accounts may be
        treated as NPAs if installments of principal and/ or interest thereon are
        overdue for more than 90 days. If loan account secured by gold becomes
        NPA, it should be classified into the different categories of assets as
        indicated in table given above.



 12.3   Gold Loan-Bullet scheme:                                                       26-11-2007
           i)      The amount of gold loan sanctioned should not exceed Rs 1.00
                   lakh at any point of time.
           ii)     The period of the loan shall not exceed 12 months from the
                   date of sanction.
           iii)    Interest will be charged to the account at monthly rests but
                   will become due for payment along with principal only at the
                   end of 12 months from the date of sanction.
           iv)     Such loans shall be governed by the extant income
                   recognition, asset classification and provisioning norms which
                   shall be applicable once the principal and interest become
                   overdue.
           v)      The account would also be classified as NPA ( sub standard
                   category) even before the due date of repayment, if the
                   prescribed margin is not maintained.



 13.1   As per RBI guidelines a provision of 0.25% has to be made on Performing        23-04-1999
                                                                                       24-05-2000
        Standard Assets from the year 31-03-2000 and should be shown
        separately as Contingent provision against standard assets under ‘Other

                                       www.spandane.com
Compiled by Spandane                           9                                NPA 2010-11

        Funds and Reserves’ in the Balance Sheet.



 13.2   Provision on Performing assets has been enhanced to 0.40 %                    24-11-2005
        wef 31-03-2006.



 13.3   It has now been decided to increase the general provisioning requirement      15-06-2006
        on standard advances in specific sectors, i.e., Personal loans, loans and
        advances qualifying as capital market exposures and commercial real
        estate loans from the present level of 0.40 per cent to 1.0 per cent.
        As hitherto, these provisions would be eligible for inclusion in Tier II
        capital for capital adequacy purposes to the permitted extent.



 13.4   It has now been decided to increase the general provisioning requirement      19-02-2007
        on standard advances in specific sectors, i.e., Personal loans, loans and
        advances qualifying as capital market exposures and commercial real
        estate loans from the present level of 1.0 per cent to 2.0 per cent.
        As hitherto, these provisions would be eligible for inclusion in Tier II
        capital for capital adequacy purposes to the permitted extent.



 13.5   The provisioning requirements in case of Tier II UCBs for all types of        01-12-2008
        standard assets stand reduced to a uniform level of 0.40 per cent except
        in the case of direct advances to agricultural and SME sectors, which
        shall continue to attract a provisioning of 0.25 per cent, as hitherto. The
        revised norms would be effective prospectively but the provisions held at
        present should not be reversed.



 13.6   In view of large increase in credit to the Commercial Real Estate (CRE)       08-12-2009
        sector over the last one year and the extent of restructured advances in
        this sector, it would be prudent to build cushion against likely non-
        performing assets (NPAs). Accordingly, it has now been decided to


                                     www.spandane.com
Compiled by Spandane                              10                               NPA 2010-11

          increase the provisioning requirement for advances to the CRE sector
          classified as 'standard assets' to 1.00 per cent.
 13.6     The standard asset provisioning requirements for all categories, after the    08-12-2009
          above change, are summarized below:



                       Category of Advance                      Tier II        Tier I   08-12-2009
 a      Direct advances to Agriculture and SME sectors          0.25 %         0.25 %
 b      Commercial Real Estate sector                           1.00 %         1.00 %
 c      All other loans & advances not included in a & b        0.40 %         0.25 %
        above



 14.0     Treatment of NPA borrower wise: All the facilities granted to a               09-02-1993
          borrower will have to be treated as non-performing assets and not the
          particular facility or part thereof which has become irregular.



 15.0     Asset classification of accounts under consortium should be based on          20-03-1997
                                                                                        06-10-2001
          the record of recovery of the individual member banks and other aspects
          having a bearing on the recoverability of the advance.



 16.0     Regularization of the account around the date of balance sheet: The           06-10-2001
          asset classification of borrowal accounts where a solitary or a few credits
          are recorded before the balance sheet date should be handled with care
          and without scope for subjectivity. Where the account indicates inherent
          weakness on the basis of the data available, the account should be
          deemed as NPA.



 17.0     Appropriation of Recoveries: In the absence of a clear agreement              06-10-2001
          between the bank and the borrower for the purpose, banks should adopt
          an accounting principle and exercise the right of appropriation of
          recoveries in a uniform and consistent manner.

                                        www.spandane.com
Compiled by Spandane                           11                                NPA 2010-11


 18.0     NPAs should be identified on going basis and required provision for            01-06-2004
          NPAs should be made at quarterly intervals in accounts.



19.0    Additional Provisions for NPAs at higher than prescribed rates                  16-12-2009
        As per the extant instructions, provisions made for NPAs as per                 Also refer
                                                                                        29-09-2009
        prudential norms are deducted from the amount of Gross NPAs to arrive
        at the amount of Net NPAs. In cases where banks make specific provision
        for NPAs in excess of what is prescribed under the prudential norms, the
        total specific provision may be deducted from the amount of Gross NPAs
        while reporting the amount of Net NPAs. The additional specific
        provision made by the bank will not be reckoned as Tier II capital.




No              Significant Changes made by RBI in respect of NPA.                        Circular
1.1     With effect from 31-03-2005, an asset would be classified as doubtful if it      11-09-2002
                                                                                         Amended
        remained in the sub-standard category for 12 months.
                                                                                          on 27-09-
        Banks are, however, permitted to phase the consequent additional                    2004
        provisioning over a four-year period commencing from the year ending 31-
        03-2005, with a minimum of 20 % each year.
1.2     Additional provision to be phased over 5 years with minimum of 10 % for          27-09-2004
        first 2 years, namely 31-03-2005 & 31-03-2006


2.0     NPAs should be identified on going basis and required provision for NPAs         01-06-2004
        should be made at quarterly intervals in accounts.


3.1     All advances classified as ‘doubtful more than three years’ on or after April    30-06-2004
        1, 2004, the provisioning requirement would be 100 %.
3.2     The said date was extended to 01-04-2006.                                        27-09-2004
3.3     The said date was extended to 01-04-2007.                                        30-04-2007


                                      www.spandane.com
Compiled by Spandane                           12                                NPA 2010-11

3.3   Provision of Doubtful > 3 years as on 31-03-2007 will be as under:              30-04-2007
      As on 31-03-2007: 100% of shortfall + 50% of realizable security
      As on 31-03-2008: 100% of shortfall + 60% of realizable security
      As on 31-03-2009:100% of shortfall + 75% of realizable security
      As on 31-03-2010: 100% of shortfall + 100% of realizable security.


4.1   90 days loan impairment norms will now be applicable to Gold loan &             04-08-2004
      small loans up to Rs. 1 lac from year ending 31-03-2005.
      Exemption of 180 days loan impairment norms to these loans up to 31-03-
      2004 has been withdrawn by the said notification.
4.2   Circular dated 04-08-2004 was reconsidered by RBI in view of requests           04-09-2004
      made by Banks / Federation/Association of UCBs. 90 days loan
      impairment norms will now be applicable to Gold loan & small loans up to
      Rs. 1 Lac from year ending 31-03-2007.


5.0   OIR in respect of unrealized interest on Performing Assets need not be          30-03-2005
      created.


6.1   Provision on Standard Assets has been enhanced from 0.25 % to         0.40 %    24-11-2005
6.2   It has now been decided to increase the general provisioning requirement        15-06-2006
      on standard advances in specific sectors, i.e., personal loans, loans and
      advances qualifying as capital market exposures and commercial real estate
      loans from the present level of 0.40 % to 1.0 %
6.3   It has now been decided to increase the general provisioning requirement        19-02-2007
      on standard advances in specific sectors, i.e., personal loans, loans and
      advances qualifying as capital market exposures and commercial real estate
      loans from the present level of 1.00 % to 2.0 %
6.4   The provisioning requirements in case of Tier II UCBs for all types             01-12-2008
      of standard assets stand reduced to a uniform level of 0.40 per cent except
      in the case of direct advances to agricultural and SME sectors, which shall
      continue to attract a provisioning of 0.25 per cent, as hitherto. The revised
      norms would be effective prospectively but the provisions held at present
      should not be reversed.

                                    www.spandane.com
Compiled by Spandane                           13                                NPA 2010-11

6.5    In view of large increase in credit to the Commercial Real Estate (CRE)         08-12-2009
       sector over the last one year and the extent of restructured advances in this
       sector, it would be prudent to build cushion against likely non-performing
       assets (NPAs). Accordingly, it has now been decided to increase the
       provisioning requirement for advances to the CRE sector classified as
       'standard assets' to 1.00 per cent.
6.6    The standard asset provisioning requirements for all categories, after the      08-12-2009
       above change, are summarized below:



                      Category of Advance                      Tier II       Tier I    08-12-2009
 a     Direct advances to Agriculture and SME sectors          0.25 %       0.25 %
 b     Commercial Real Estate sector                           1.00 %       1.00 %
 c     All other loans & advances not included in a & b        0.40 %       0.25 %
       above


 6.7   Additional Provisions for NPAs at higher than prescribed rates                  16-12-2009
       As per the extant instructions, provisions made for NPAs as per prudential      Also refer
       norms are deducted from the amount of Gross NPAs to arrive at the               29-09-2009
       amount of Net NPAs. In cases where banks make specific provision for
       NPAs in excess of what is prescribed under the prudential norms, the total
       specific provision may be deducted from the amount of Gross NPAs while
       reporting the amount of Net NPAs. The additional specific provision made
       by the bank will not be reckoned as Tier II capital.




                                       www.spandane.com
Compiled by Spandane                              14                           NPA 2010-11



        Action Plan -- NPA / Recovery Management for the year ended 31-03-2011.



Sr. No.              Action Plan                 In                 Review Dates
                                               charge
  1.0     Cash Credit:
  1.1     To ensure that outstanding in                            31-08-10   30-11-10   28-02-11
          the CC account should be less
          than the limit / DP at least
          once in a quarter.
  1.2     To ensure that there are                                 31-08-10   30-11-10   28-02-11
          credits in every quarter in CC
          account.
  1.3     To ensure that credits in the                            31-08-10   30-11-10   28-02-11
          CC account are adequate to
          cover the interest debited
          during the said period.
  1.4     Outstanding balance in CC                     31-01-11   28-02-11   10-03-11   20-03-11
          account should be less than
          the limit / DP at least for one
          day during the period 01-01-
          2010 to 31-03-2011.
  1.5     Credit in the CC account for                  31-01-11   28-02-11   10-03-11   20-03-11
          the said period should be
          adequate to cover the interest
          debited during the period. As
          a   thumb     rule,   credits   of
          approx. 10 % of the limit
          should be received in the
          account.



                                          www.spandane.com
Compiled by Spandane                            15                          NPA 2010-11

 1.6    Stock statement should be                               31-08-10   30-11-10   28-02-11
        received at least once in a
        quarter.
 1.7    Stock statement as on 31-12-                 20-01-11   28-02-11   10-03-11   20-03-11
        2010 should be received by
        31-03-2011.
 1.8    If stock statement as on 31-12-              15-02-11   28-02-11   10-03-11   20-03-11
        2010    is    not    received     by
        20-01-2011, then branch and
        HO officials should carry
        inspection          jointly      and
        inspection report should be
        kept on record.
 1.9    An account where the regular                            28-02-11   10-03-11   20-03-11
        / adhoc credit limits have not
        been reviewed or have not
        been renewed within 90 days
        from the due date / date of
        adhoc        sanction,    will    be
        treated as NPA.
 1.10   CC accounts having due date                  01-12-10   31-01-11   28-02-11   10-03-11
        31-12-2010 or prior should be
        renewed by 31-03-2011.


 2.0    Debit balance in Deposit
        Account:
 2.1    Debit balance in deposit a/c
        should be recovered within
        90 days.




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Compiled by Spandane                          16                          NPA 2010-11

 2.2   Debit     balance      in   Current         31-01-11   28-02-11   10-03-11   20-03-11
       account      as   on    31-12-2010
       should       be   recovered     by
       31-03-2011.
 2.3   Debit     balance      in   Savings         31-01-11   28-02-11   10-03-11   20-03-11
       account      as   on    31-12-2010
       should       be   recovered     by
       31-03-2011.


 3.0   Letter of Credit Paid:
 3.1   Debit balance in LC Paid                    31-01-11   28-02-11   10-03-11   20-03-11
       account outstanding as on 31-
       12-2010 should be recovered
       by 31-03-2011.
 4.1   Term Loan:
       The Term loan will be treated                          31-08-10   30-11-10   28-02-11
       as NPA when interest and /
       or installment of principal
       remain overdue for a period
       of more than 90 days.
       Interest and Installment up to              31-01-11   28-02-11   10-03-11   20-03-11
       31-12-2010          should      be
       recovered by 31-03-2011.


 5.0   Bill Discounting:
 5.1   Bills remaining overdue for a                          31-08-10   30-11-10   28-02-11
       period of more than 90 days
       will be classified as NPA.
 5.2   Bills having due date 31-12-                31-01-11   28-02-11   10-03-11   20-03-11
       2010    or    prior    should   be
       recovered by 31-03-2011.



                                       www.spandane.com
Compiled by Spandane                            17                          NPA 2010-11

 6.0   Valuation Report:
 6.1   Valuation of security in case                 31-10-10   30-11-10   31-12-10   31-01-11
       of NPA with balance of Rs.10
       Lacs & above should be done
       at least once in 3 years as per
       RBI circular dated 06-10-2001.
 6.2   Valuation report in case of PA                           31-08-10   30-11-10   28-02-11
       may also be obtained once in
       3 years.


 7.0   Loan against security of FDR
       / RBD / NSC / IVP / KVP /
       LIC:
 7.1   To review the Overdrawn /                                31-08-10   30-11-10   28-02-11
       Defaulters List and ascertain
       whether outstanding balance
       and     interest     receivable    is
       within the face value of the
       security + accrued interest till
       date.
 7.2   Follow up should be done for                             31-08-10   30-11-10   28-02-11
       recovery of interest / overdue
       amount.
 7.3   If TDR, NSC, KVP etc. have                               31-08-10   30-11-10   28-02-11
       matured,     then      adjust     the
       proceeds           against      loan
       balance.




                                         www.spandane.com
Compiled by Spandane                             18                          NPA 2010-11

 7.4    In case of OD / DPLN against                             31-08-10   30-11-10   28-02-11
        security of FDR, MIP etc.
        interest on FDR & MIP may
        be credited to SB / CD
        instead of to OD / DPLN.
        Review should be made of
        OD / DPLN against FDR /
        MIP and take corrective steps.
 8.0    Inspection:
 8.1    All CC & Term loan accounts                              31-08-10   30-11-10   28-02-11
        above Rs. 5 Lacs should be
        inspected by 31-03-2011.


 9.0    Obtaining Information from
        borrowers:
 9.1    Audited accounts, Accounts,                   15-10-10   15-12-10   15-01-11   15-02-11
        Audit     report,   Tax        Audit
        report,    Income   tax return
        copies, company secretarial
        compliance      certificate      etc.
        should be obtained from all
        borrowers enjoying limit of
        Rs. 3 Lacs and above.


 10.0   Multiple Limits:
 10.1   Close monitoring should be                               31-08-10   30-11-10   28-02-11
        done in case borrower is
        enjoying      Multiple         Limits
        because     overdue       in     one
        account      may      result       in
        classifying all accounts as
        NPA.

                                          www.spandane.com
Compiled by Spandane                      19                     NPA 2010-11

 11.0   Transfer from Current A/C:
 11.1   At times, borrower maintains                 31-08-10   30-11-10   28-02-11
        Current account in addition
        to Loan account and carries
        out operations in CA. Branch
        should review the operations
        in   CA   periodically   and
        transfer the funds from CA to
        CC / Loan account to avoid
        classifying these accounts as
        NPA.


 12.0   Notes:




Compiled by Spandane / Tuesday, June 22, 2010


                                  www.spandane.com
Compiled by Spandane          20          NPA 2010-11




                       www.spandane.com

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Rbi

  • 1. Income Recognition, Asset Classification and Provisioning (2010-2011) (UCB) NPA 2010-11 Compiled by CA. Sudhir Vaidya
  • 2. Compiled by Spandane 2 NPA 2010-11 Income Recognition, Asset Classification and Provisioning (2010-2011) (UCB) Classification of Date of NPA Age of NPA Provision required Assets as on 31-03-2011 Standard N.A. N.A. 0.40 % of outstanding Also refer page 7 & 8 Sub-standard Between 01-04-2010 Not more than 12 10% of outstanding To 31-03-2011 months i) Doubtful Between 01-04-2009 Between 13 to 24 100% of shortfall + 20% To 31-03-2010 months of realizable security ii) Doubtful Between 01-04-2007 Between 25 to 48 100% of shortfall + 30% To 31-03-2009 months of realizable security iii) Doubtful Prior to 31-03-2003 More than 48 months 100% of shortfall + 100% As on 31-03-2007 of realizable security Doubtful > 3 years as on 31-03-2007 iv) Doubtful Advances classified Between 01-04-2003 To 100% of shortfall + 100% as 'doubtful more 31-03-2007 of realizable security. than three years' on i.e. 100% of O/S or after April 1, 2007 Loss Assets No criteria of date No criteria of date 100% of outstanding Note Dates of Circulars issued by RBI to All Primary (Urban) Co-operative Banks have been mentioned below. However the various issues discussed below are equally applicable to all banks. RBI issues separate circulars to commercial banks. 1.0 Classification of Assets as Non-Performing: An asset becomes non-performing when it ceases to generate income for the bank. 2.0 Asset Classification: Standard Assets is one, which does not disclose any problems and which does not carry more than normal risk attached to the 11-09-2002 business. Such an asset should not be an NPA. www.spandane.com
  • 3. Compiled by Spandane 3 NPA 2010-11 Sub-standard Asset is one which has remained as NPA for a 11-09-2002 period not exceeding 18 months. (12 months from 31-03-2005) Doubtful Asset is one, which has remained in the sub-standard category for 18 months. (12 months from 31-03-2005) 3.0 Income Recognition Policy: Income from non-performing assets (NPA) is not recognized on accrual basis but is booked as income only when it is actually received. Interest on advances against term deposits, NSCs, IVPs, KVPs & LIC policies may be taken to income account on the due date, provided adequate margin is available in the account. If any loan a/c becomes NPA as at the close of the year, interest accrued and credited to income account in the corresponding previous year, should be reversed or provided for if the same is not realized. 4.1 The difference between the original advance and minimum balance indicates the repayment received towards the principal. Repayment towards principal = Original advance – Minimum balance. 4.2 The difference between the present balance and minimum balance indicates the arrears of interest and charges i.e. interest and charges debited to the loan but not paid by the borrower. Interest arrears = Present balance – Minimum balance – Advance payments if any. 5.0 As on 31-03-2011: In case of loans repayable in equated monthly 05-10-2001 installments (EMI) where a part of the interest is included in the installment, NPA shall be determined on the basis of non-payment of EMI. In other words, credit summations in the borrowal account up to www.spandane.com
  • 4. Compiled by Spandane 4 NPA 2010-11 31-03-2011 should be divided by EMI to arrive at number of EMI received. If EMI due up to 31-12-2010 is received by 31-03-2011, the account will be classified as PA. 6.0 The Term loan will be treated as NPA when interest and / or installment 05-10-2001 04-09-2004 of principal remain overdue for a period of more than 90 days. (As on 31-03-2011) If interest due for the quarter ended 31-12-2010 is not paid, it becomes NPA on 31-03-2011. (i.e. overdue for more than 90 days). If installment towards principal due on 31-12-2010 is not paid, it becomes NPA as on 31-03-2011 (i.e. overdue for more than 90 days) 7.0 The date of existing NPA accounts will remain same as mentioned last year unless it was wrongly calculated last year. If account is NPA as on 31-03-2011, then confirm whether account was classified as NPA during earlier years. If yes, then continue old NPA date. 8.0 Interest receivable on all NPA accounts up to 31-03-2011 should be 28-02-1995 reversed / Overdue provision should be made. Interest accrued in respect of non-performing advances should not be debited to borrowal accounts but shown separately under ‘Interest receivable account’ and corresponding amount shown under ‘Overdue interest reserve account’ 9.0 In respect of borrowal accounts, which are treated as performing assets, 30-03-2005 accrued interest may be debited to the borrowal account and credited to interest account and taken to income account. (Instruction to create OIR in respect of such interest has been omitted from new paragraph substituted in earlier circular dated 28-02-1995) www.spandane.com
  • 5. Compiled by Spandane 5 NPA 2010-11 10.1 Valuation of Security in case of NPAs with balance of Rs.10 Lacs and 06-10-2001 above: Stock Audit at annual intervals by external agency should be carried out. The Board may finalize the cut off limit and the names of the external agencies. Collaterals such as immovable properties charged in favor of the bank should be got valued once in 3 years by valuers appointed as per the guidelines approved by the Board of Directors. 10.2 Wherever valuation report in respect of securities is not available or valuation could not got done in the case of doubtful debts on account of non co-operation of borrowers or any other justifiable reasons, then depreciated value of securities shall be taken into account for the purpose of computation of secured and unsecured portion of advance. Depreciated value shall be calculated on straight-line method on the movable assets at the following rates. (The said rates are suggested /based on average life of the Asset. Bank can provide higher rate.) Plant & Machinery 15 % Furniture & Fixture 15 % Consumer durable 20 % Computers 30 % Vehicle 20 % Shop, Gala, Flat, Building etc. can be valued as per prevailing property rates available in Govt. gazette, property magazines etc. Approximate value can also be found out by use of cost inflation index published by Govt. for purpose of calculation of capital gains. Table of CII is printed on cover Page-134 of V. G. Mehta’s I.T. Reckoner for A.Y.2010-11. Bank should evolve the policy for obtaining valuation of property charged in favour of the bank. www.spandane.com
  • 6. Compiled by Spandane 6 NPA 2010-11 10.3 Significant credit impairment: Erosion in the value of of security can be 06-10-2001 reckoned as significant when the realizable value of the security is less than 50 % of the value assessed by the bank or accepted by RBI at the time of last inspection as the case may be. Such NPAs may be straightaway classified under doubtful category and provisioning should be made as applicable to doubtful assets. 10.4 Treatment of Loss assets: If realizable value of the security, as assessed 06-10-2001 by the bank / approved valuer’s / RBI is less than 10 % of the O/S in the borrowal accounts, the existence of security should be ignored and the asset should be straightaway classified as Loss Asset. 10.5 Availability of security or net worth of borrower / guarantor should not 09-02-1993 be taken into account for the purpose of treating an advance as non- performing asset or other wise as income recognition is based on record of recovery. 11.1 Cash Credit: CC a/c will be classified as NPA if it is out of order for more 05-10-2001 than 90 days. (As on 31-03-2011) i) O/S continuously > Limit / DP between 31-12-2010 to 31-03-2011 NPA ii) If O/S < Limit and there are no credits during 01-01-2011 to 31-03-2011 NPA iii) If there are credits, then credits should be sufficient to cover Interest debited during the same period. Otherwise cc a/c will be NPA CC Limits sanctioned against the security of Premises, Gold etc. should also be classified as NPA on above criteria. CC Limits sanctioned against the security of LIC, NSC, TDR should be classified as NPA as per guidelines stated in para-12.1 stated below. www.spandane.com
  • 7. Compiled by Spandane 7 NPA 2010-11 11.2 Non-submission of stock statements: The o/s in the account based on 05-10-2001 drawing power calculated from stock statements older than 3 months, would be deemed as irregular. A working capital borrowal account will become an NPA if such irregular drawings are permitted in the account for a continuous period of 90 days even though the unit may be working or the borrower’s financial position is satisfactory. Stock statement as on 31-12-2010 should be obtained failing which the same will have to be classified as NPA as on 31-03-2011. 11.3 As on 31-03-2011: Un renewed CC accounts: An account where the 05-10-2001 regular / adhoc credit limits have not been reviewed or have not been renewed within 90 days from the due date / date of adhoc sanction will be treated as NPA. CC accounts having due date 31-12-2010 or prior should be renewed by 31-03-2011, failing which the same will have to be classified as NPA as on 31-03-2011. 11.4 As on 31-03-2011: Bills remaining overdue for a period of more than 05-10-2001 90 days in case of bills purchased and discounted will be classified as NPA. Bills having due date 31-12-2010 or prior and remaining O/S as on 31-03-2011 will be classified as NPA as on 31-03-2011. 11.5 Any amount to be received remaining overdue for a period of more than 05-10-2001 90 days in respect of other accounts will be classified as NPA. 12.1 Advances against term deposits, NSCs eligible for surrender, IVPs, KVPs and Life policies need not be treated as NPAs although interest thereon may not have been paid for more than 90 days provided adequate margin is available in the accounts. In other words, Advances against www.spandane.com
  • 8. Compiled by Spandane 8 NPA 2010-11 above security should be classified as standard, if (O/S + interest) is less than value of above security as on 31-03-2011. 12.2 Gold Loan: Primary (urban) co-operative banks should fix monthly 17-06-1993 /quarterly installments for repayment of gold loans for non-agricultural purposes taking into account the pattern of income generation and repayment capacity of the borrowers and such gold loan accounts may be treated as NPAs if installments of principal and/ or interest thereon are overdue for more than 90 days. If loan account secured by gold becomes NPA, it should be classified into the different categories of assets as indicated in table given above. 12.3 Gold Loan-Bullet scheme: 26-11-2007 i) The amount of gold loan sanctioned should not exceed Rs 1.00 lakh at any point of time. ii) The period of the loan shall not exceed 12 months from the date of sanction. iii) Interest will be charged to the account at monthly rests but will become due for payment along with principal only at the end of 12 months from the date of sanction. iv) Such loans shall be governed by the extant income recognition, asset classification and provisioning norms which shall be applicable once the principal and interest become overdue. v) The account would also be classified as NPA ( sub standard category) even before the due date of repayment, if the prescribed margin is not maintained. 13.1 As per RBI guidelines a provision of 0.25% has to be made on Performing 23-04-1999 24-05-2000 Standard Assets from the year 31-03-2000 and should be shown separately as Contingent provision against standard assets under ‘Other www.spandane.com
  • 9. Compiled by Spandane 9 NPA 2010-11 Funds and Reserves’ in the Balance Sheet. 13.2 Provision on Performing assets has been enhanced to 0.40 % 24-11-2005 wef 31-03-2006. 13.3 It has now been decided to increase the general provisioning requirement 15-06-2006 on standard advances in specific sectors, i.e., Personal loans, loans and advances qualifying as capital market exposures and commercial real estate loans from the present level of 0.40 per cent to 1.0 per cent. As hitherto, these provisions would be eligible for inclusion in Tier II capital for capital adequacy purposes to the permitted extent. 13.4 It has now been decided to increase the general provisioning requirement 19-02-2007 on standard advances in specific sectors, i.e., Personal loans, loans and advances qualifying as capital market exposures and commercial real estate loans from the present level of 1.0 per cent to 2.0 per cent. As hitherto, these provisions would be eligible for inclusion in Tier II capital for capital adequacy purposes to the permitted extent. 13.5 The provisioning requirements in case of Tier II UCBs for all types of 01-12-2008 standard assets stand reduced to a uniform level of 0.40 per cent except in the case of direct advances to agricultural and SME sectors, which shall continue to attract a provisioning of 0.25 per cent, as hitherto. The revised norms would be effective prospectively but the provisions held at present should not be reversed. 13.6 In view of large increase in credit to the Commercial Real Estate (CRE) 08-12-2009 sector over the last one year and the extent of restructured advances in this sector, it would be prudent to build cushion against likely non- performing assets (NPAs). Accordingly, it has now been decided to www.spandane.com
  • 10. Compiled by Spandane 10 NPA 2010-11 increase the provisioning requirement for advances to the CRE sector classified as 'standard assets' to 1.00 per cent. 13.6 The standard asset provisioning requirements for all categories, after the 08-12-2009 above change, are summarized below: Category of Advance Tier II Tier I 08-12-2009 a Direct advances to Agriculture and SME sectors 0.25 % 0.25 % b Commercial Real Estate sector 1.00 % 1.00 % c All other loans & advances not included in a & b 0.40 % 0.25 % above 14.0 Treatment of NPA borrower wise: All the facilities granted to a 09-02-1993 borrower will have to be treated as non-performing assets and not the particular facility or part thereof which has become irregular. 15.0 Asset classification of accounts under consortium should be based on 20-03-1997 06-10-2001 the record of recovery of the individual member banks and other aspects having a bearing on the recoverability of the advance. 16.0 Regularization of the account around the date of balance sheet: The 06-10-2001 asset classification of borrowal accounts where a solitary or a few credits are recorded before the balance sheet date should be handled with care and without scope for subjectivity. Where the account indicates inherent weakness on the basis of the data available, the account should be deemed as NPA. 17.0 Appropriation of Recoveries: In the absence of a clear agreement 06-10-2001 between the bank and the borrower for the purpose, banks should adopt an accounting principle and exercise the right of appropriation of recoveries in a uniform and consistent manner. www.spandane.com
  • 11. Compiled by Spandane 11 NPA 2010-11 18.0 NPAs should be identified on going basis and required provision for 01-06-2004 NPAs should be made at quarterly intervals in accounts. 19.0 Additional Provisions for NPAs at higher than prescribed rates 16-12-2009 As per the extant instructions, provisions made for NPAs as per Also refer 29-09-2009 prudential norms are deducted from the amount of Gross NPAs to arrive at the amount of Net NPAs. In cases where banks make specific provision for NPAs in excess of what is prescribed under the prudential norms, the total specific provision may be deducted from the amount of Gross NPAs while reporting the amount of Net NPAs. The additional specific provision made by the bank will not be reckoned as Tier II capital. No Significant Changes made by RBI in respect of NPA. Circular 1.1 With effect from 31-03-2005, an asset would be classified as doubtful if it 11-09-2002 Amended remained in the sub-standard category for 12 months. on 27-09- Banks are, however, permitted to phase the consequent additional 2004 provisioning over a four-year period commencing from the year ending 31- 03-2005, with a minimum of 20 % each year. 1.2 Additional provision to be phased over 5 years with minimum of 10 % for 27-09-2004 first 2 years, namely 31-03-2005 & 31-03-2006 2.0 NPAs should be identified on going basis and required provision for NPAs 01-06-2004 should be made at quarterly intervals in accounts. 3.1 All advances classified as ‘doubtful more than three years’ on or after April 30-06-2004 1, 2004, the provisioning requirement would be 100 %. 3.2 The said date was extended to 01-04-2006. 27-09-2004 3.3 The said date was extended to 01-04-2007. 30-04-2007 www.spandane.com
  • 12. Compiled by Spandane 12 NPA 2010-11 3.3 Provision of Doubtful > 3 years as on 31-03-2007 will be as under: 30-04-2007 As on 31-03-2007: 100% of shortfall + 50% of realizable security As on 31-03-2008: 100% of shortfall + 60% of realizable security As on 31-03-2009:100% of shortfall + 75% of realizable security As on 31-03-2010: 100% of shortfall + 100% of realizable security. 4.1 90 days loan impairment norms will now be applicable to Gold loan & 04-08-2004 small loans up to Rs. 1 lac from year ending 31-03-2005. Exemption of 180 days loan impairment norms to these loans up to 31-03- 2004 has been withdrawn by the said notification. 4.2 Circular dated 04-08-2004 was reconsidered by RBI in view of requests 04-09-2004 made by Banks / Federation/Association of UCBs. 90 days loan impairment norms will now be applicable to Gold loan & small loans up to Rs. 1 Lac from year ending 31-03-2007. 5.0 OIR in respect of unrealized interest on Performing Assets need not be 30-03-2005 created. 6.1 Provision on Standard Assets has been enhanced from 0.25 % to 0.40 % 24-11-2005 6.2 It has now been decided to increase the general provisioning requirement 15-06-2006 on standard advances in specific sectors, i.e., personal loans, loans and advances qualifying as capital market exposures and commercial real estate loans from the present level of 0.40 % to 1.0 % 6.3 It has now been decided to increase the general provisioning requirement 19-02-2007 on standard advances in specific sectors, i.e., personal loans, loans and advances qualifying as capital market exposures and commercial real estate loans from the present level of 1.00 % to 2.0 % 6.4 The provisioning requirements in case of Tier II UCBs for all types 01-12-2008 of standard assets stand reduced to a uniform level of 0.40 per cent except in the case of direct advances to agricultural and SME sectors, which shall continue to attract a provisioning of 0.25 per cent, as hitherto. The revised norms would be effective prospectively but the provisions held at present should not be reversed. www.spandane.com
  • 13. Compiled by Spandane 13 NPA 2010-11 6.5 In view of large increase in credit to the Commercial Real Estate (CRE) 08-12-2009 sector over the last one year and the extent of restructured advances in this sector, it would be prudent to build cushion against likely non-performing assets (NPAs). Accordingly, it has now been decided to increase the provisioning requirement for advances to the CRE sector classified as 'standard assets' to 1.00 per cent. 6.6 The standard asset provisioning requirements for all categories, after the 08-12-2009 above change, are summarized below: Category of Advance Tier II Tier I 08-12-2009 a Direct advances to Agriculture and SME sectors 0.25 % 0.25 % b Commercial Real Estate sector 1.00 % 1.00 % c All other loans & advances not included in a & b 0.40 % 0.25 % above 6.7 Additional Provisions for NPAs at higher than prescribed rates 16-12-2009 As per the extant instructions, provisions made for NPAs as per prudential Also refer norms are deducted from the amount of Gross NPAs to arrive at the 29-09-2009 amount of Net NPAs. In cases where banks make specific provision for NPAs in excess of what is prescribed under the prudential norms, the total specific provision may be deducted from the amount of Gross NPAs while reporting the amount of Net NPAs. The additional specific provision made by the bank will not be reckoned as Tier II capital. www.spandane.com
  • 14. Compiled by Spandane 14 NPA 2010-11 Action Plan -- NPA / Recovery Management for the year ended 31-03-2011. Sr. No. Action Plan In Review Dates charge 1.0 Cash Credit: 1.1 To ensure that outstanding in 31-08-10 30-11-10 28-02-11 the CC account should be less than the limit / DP at least once in a quarter. 1.2 To ensure that there are 31-08-10 30-11-10 28-02-11 credits in every quarter in CC account. 1.3 To ensure that credits in the 31-08-10 30-11-10 28-02-11 CC account are adequate to cover the interest debited during the said period. 1.4 Outstanding balance in CC 31-01-11 28-02-11 10-03-11 20-03-11 account should be less than the limit / DP at least for one day during the period 01-01- 2010 to 31-03-2011. 1.5 Credit in the CC account for 31-01-11 28-02-11 10-03-11 20-03-11 the said period should be adequate to cover the interest debited during the period. As a thumb rule, credits of approx. 10 % of the limit should be received in the account. www.spandane.com
  • 15. Compiled by Spandane 15 NPA 2010-11 1.6 Stock statement should be 31-08-10 30-11-10 28-02-11 received at least once in a quarter. 1.7 Stock statement as on 31-12- 20-01-11 28-02-11 10-03-11 20-03-11 2010 should be received by 31-03-2011. 1.8 If stock statement as on 31-12- 15-02-11 28-02-11 10-03-11 20-03-11 2010 is not received by 20-01-2011, then branch and HO officials should carry inspection jointly and inspection report should be kept on record. 1.9 An account where the regular 28-02-11 10-03-11 20-03-11 / adhoc credit limits have not been reviewed or have not been renewed within 90 days from the due date / date of adhoc sanction, will be treated as NPA. 1.10 CC accounts having due date 01-12-10 31-01-11 28-02-11 10-03-11 31-12-2010 or prior should be renewed by 31-03-2011. 2.0 Debit balance in Deposit Account: 2.1 Debit balance in deposit a/c should be recovered within 90 days. www.spandane.com
  • 16. Compiled by Spandane 16 NPA 2010-11 2.2 Debit balance in Current 31-01-11 28-02-11 10-03-11 20-03-11 account as on 31-12-2010 should be recovered by 31-03-2011. 2.3 Debit balance in Savings 31-01-11 28-02-11 10-03-11 20-03-11 account as on 31-12-2010 should be recovered by 31-03-2011. 3.0 Letter of Credit Paid: 3.1 Debit balance in LC Paid 31-01-11 28-02-11 10-03-11 20-03-11 account outstanding as on 31- 12-2010 should be recovered by 31-03-2011. 4.1 Term Loan: The Term loan will be treated 31-08-10 30-11-10 28-02-11 as NPA when interest and / or installment of principal remain overdue for a period of more than 90 days. Interest and Installment up to 31-01-11 28-02-11 10-03-11 20-03-11 31-12-2010 should be recovered by 31-03-2011. 5.0 Bill Discounting: 5.1 Bills remaining overdue for a 31-08-10 30-11-10 28-02-11 period of more than 90 days will be classified as NPA. 5.2 Bills having due date 31-12- 31-01-11 28-02-11 10-03-11 20-03-11 2010 or prior should be recovered by 31-03-2011. www.spandane.com
  • 17. Compiled by Spandane 17 NPA 2010-11 6.0 Valuation Report: 6.1 Valuation of security in case 31-10-10 30-11-10 31-12-10 31-01-11 of NPA with balance of Rs.10 Lacs & above should be done at least once in 3 years as per RBI circular dated 06-10-2001. 6.2 Valuation report in case of PA 31-08-10 30-11-10 28-02-11 may also be obtained once in 3 years. 7.0 Loan against security of FDR / RBD / NSC / IVP / KVP / LIC: 7.1 To review the Overdrawn / 31-08-10 30-11-10 28-02-11 Defaulters List and ascertain whether outstanding balance and interest receivable is within the face value of the security + accrued interest till date. 7.2 Follow up should be done for 31-08-10 30-11-10 28-02-11 recovery of interest / overdue amount. 7.3 If TDR, NSC, KVP etc. have 31-08-10 30-11-10 28-02-11 matured, then adjust the proceeds against loan balance. www.spandane.com
  • 18. Compiled by Spandane 18 NPA 2010-11 7.4 In case of OD / DPLN against 31-08-10 30-11-10 28-02-11 security of FDR, MIP etc. interest on FDR & MIP may be credited to SB / CD instead of to OD / DPLN. Review should be made of OD / DPLN against FDR / MIP and take corrective steps. 8.0 Inspection: 8.1 All CC & Term loan accounts 31-08-10 30-11-10 28-02-11 above Rs. 5 Lacs should be inspected by 31-03-2011. 9.0 Obtaining Information from borrowers: 9.1 Audited accounts, Accounts, 15-10-10 15-12-10 15-01-11 15-02-11 Audit report, Tax Audit report, Income tax return copies, company secretarial compliance certificate etc. should be obtained from all borrowers enjoying limit of Rs. 3 Lacs and above. 10.0 Multiple Limits: 10.1 Close monitoring should be 31-08-10 30-11-10 28-02-11 done in case borrower is enjoying Multiple Limits because overdue in one account may result in classifying all accounts as NPA. www.spandane.com
  • 19. Compiled by Spandane 19 NPA 2010-11 11.0 Transfer from Current A/C: 11.1 At times, borrower maintains 31-08-10 30-11-10 28-02-11 Current account in addition to Loan account and carries out operations in CA. Branch should review the operations in CA periodically and transfer the funds from CA to CC / Loan account to avoid classifying these accounts as NPA. 12.0 Notes: Compiled by Spandane / Tuesday, June 22, 2010 www.spandane.com
  • 20. Compiled by Spandane 20 NPA 2010-11 www.spandane.com