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76  Independent Auditors’ Report                                                                                77






 Materiality          customer loans, and hence whether a 12 month or a   specialists to test the collateral haircuts used by
                      lifetime loss provision is recorded;       management and we obtained and reviewed the credit
 •  Overall materiality: £1,400,000 based on 5% of profit before tax from continuing operations.   •   Probabilities of default, including how they are   files and other evidence considered by management
 •  Performance materiality: £700,000.   derived from credit grading models used in portfolio   when determining the ECL provisions to derive our
 The scope of our audit   analysis by the Company;               own independent view in respect of recovery
                                                                 prospects.
 As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial   •   Assumptions used in the loss given default
                      calculation, including collateral haircuts, cure rates
 statements.          and the time to collateral realisation; and   We tested the appropriateness of assumptions used
                   •   The determination of a Post Model adjustment to   in the derivation of probability of default and loss given
 Key audit matters    account for valuation risk in respect of the   default by testing the historical default and loss
 Key audit matters are those matters that, in the auditors’ professional judgement, were of most significance in the audit of   Commercial Real Estate portfolio.   behaviour. We considered how historical behaviour
                                                                 may change going forwards due to the rising interest
 the financial statements of the current period and include the most significant assessed risks of material misstatement   The Company’s disclosures are given in Note 16.   rate and inflationary environment in the UK. We also
 (whether or not due to fraud) identified by the auditors, including those which had the greatest effect on: the overall audit   Management’s associated accounting policies are detailed in   examined a sample of the credit file reviews
               Note 28. Management’s judgements in the application of
 strategy; the allocation of resources in the audit; and directing the efforts of the engagement team. These matters, and any   accounting policy and critical estimates are disclosed in Note 5   performed by management to consider whether there
 comments we make on the results of our procedures thereon, were addressed in the context of our audit of the financial   and 28  and the considerations of the effect of the future   were indicators of increased risk.
 statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.   economic environment are given in Note 28. The Audit
               Committees’ consideration of the matter is set out in the Audit   We considered the reasonableness of the post model
               Committee Report.                                 adjustment for valuation risk in respect of the
 This is not a complete list of all risks identified by our audit.   Commercial Real Estate portfolio by critically
                                                                 assessing the methodology and testing the supporting
  Key audit matter   How our audit addressed the key audit matter   data used within the calculation of the adjustment.

 The application of key judgements and assumptions in relation
 to applying expected credit loss provisioning on loans and      We read the ECL disclosures made by management
 advances to customers                                           to ensure compliance with accounting standards and
                                                                 to ensure that there is disclosure of the effect of
 The Company held £16,929k of expected credit loss (‘ECL’)   We understood and critically assessed the   estimation uncertainty on the reported results.
 provisions against loans and advances to customers in   methodology applied in the impairment models, using
 accordance with IFRS 9 (2021: £14,766k) against total   modelling specialists in the more judgemental areas,
 outstanding balances of £1,054,641k (2021: £992,600k).   including the results of empirical testing on key model   From the evidence we obtained, we found that the
                                                                 judgements and assumptions applied to be
 The determination of ECL provisions is inherently judgemental   components, primarily the probability of default and   reasonable.
 and involves setting assumptions using forward looking   loss given default models, to confirm that the
 information reflecting the Company’s view of potential future   implemented methodology was compliant with   The appropriateness of assumptions used in the accounting for
 economic events. This can give rise to increased estimation   accounting standards.   the effective interest rate of loans and advances to customers
 uncertainty.      Accounting standards required interest receivable and similar   We performed a walkthrough of the EIR model logic,
 There is significant uncertainty in calculating expected credit   We challenged management on model limitations   income to be recognised on an effective interest rate (‘EIR’)   methodology and associated calculations and tested
 losses due to the potential impacts on customer behaviour due   relating to the forecasting of probabilities of default   basis. The EIR approach has the effect of recognising interest   their accuracy and validity.
 to the rising inflationary and interest rate environment in the   and exposure at default calculations.   at a single constant rate that takes into account integral fees
 UK. Uncertainty also arises in respect of calculating ECL      and charges across the expected life of loans and advances to   We confirmed that all fees and charges included
 provisions for defaulted ‘Stage 3’ exposures due to the   We tested management’s ‘staging’ thresholds by   customers.
 Company pursuing individual work out strategies for each   examining management’s model monitoring   The loans and advances to customers balance is reduced by   within the EIR calculation are in line with accounting
 exposure.   processes and considering the accounts being   effective interest rate accounting adjustments of £4,117k at the   standards.
 The Company divides its lending activities into two sub-  flagged as higher risk through the Company’s internal   balance sheet date (2021: reduced by £4,069k). This
 portfolios, being real estate finance and asset finance. ECL   governance forums. We examined account   adjustment primarily relates to deferred fees and charges in   We critically assessed the assumptions relating to
 provisions recorded over each of these portfolios are £14,730k   performance to test whether staging thresholds are   respect of the Company’s real estate finance loan portfolio.   forecast future redemption behaviours, particularly
 and £2,199k respectively (2021: £13,836k and £930k).   giving rise to appropriate outcomes.    This adjustment is released to the statement of profit or loss   because the Company writes variable rate real estate
 We focussed our work on provisioning for the real estate      and other comprehensive income in accordance with the   finance loans and the rising interest rate environment
                                                                 in the UK may accelerate redemption behaviour.
 finance portfolio because there is a larger degree of estimation   We assessed the reasonableness and likelihood of   forecast behavioural life of the Company’s loan balance, which
 uncertainty in respect of this portfolio due to this portfolio   the forward looking economic assumptions and   is the main area of estimation uncertainty.   We performed sensitivity analysis on a range of
 constituting 89% of total lending (2021: 91%) and the   weightings assigned to the scenarios using a   The forecast behavioural life depends on management’s   possible alternative outcomes to determine whether
 individual assets in this portfolio are generally larger. This   benchmarking tool developed by our economic   estimate of the future redemption behaviour of loans and   the overall estimate lies within a reasonable range of
 gives rise to management judgements and assumptions in   experts. The severity and magnitude of the scenarios,   advances to customers. This estimate is derived using   best estimates.
 determining ECL provisions having a larger impact on the   specifically the house price inflation forecasts, were   management judgement due to the nascent nature of the
 reported results of the Company in respect of the real estate   compared to external forecasts and data from   Company’s loan portfolio. As such we focussed our work on   We performed substantive testing over the
 finance portfolio. In particular we focused on:   historical economic downturns. Sensitivities of the   this area.   completeness and accuracy of the critical data
 •   Valuation of the provisions for defaulted ‘Stage 3’   ECL provision to the chosen scenarios was   The Company’s disclosures are given in Note 5 and 6.   elements from the Company’s lending system to the
 exposures where a significant degree of   considered. We separately engaged our economic   Management’s associated accounting policies are detailed in   EIR model and supporting evidence.
 management judgement is applied;   experts to consider the reasonableness of the   Note 6. Management’s judgements in the application of
 •   The application of forward-looking economic   Company’s commercial real estate forecasts. We   accounting policy and critical estimates are disclosed in Note 5   We tested the reconciliation of the accounting model
 assumptions used in the models and the weightings   found that the assumptions adopted and assigned   and 6 ]. The Audit Committees’ consideration of the matter is   to the general ledger to ensure accurate recording in
 assigned to those scenarios, particularly in respect of   weightings to the scenarios were reasonable.   set out in the Audit Committee Report.   the financial statements.
 assumptions relating to future residential and
 commercial real estate values since these have the   We tested the complete capture of defaulted   We read the disclosures made by management to
 largest impact on the ECL calculation;   exposures by ensuring loans meeting the operational   ensure that they disclosed the effect of estimation
 •   The appropriateness of the ‘staging’ thresholds   definition of default are included in the portfolio of   uncertainty on the reported results.
 selected by management to determine whether a   Stage 3 loans. We challenged management on the
 significant increase in credit risk had arisen on   judgements used in determining the provisions for
 Stage 3 exposures. We engaged our modelling                     From the evidence obtained, we found that the EIR
                                                                 accounting estimate is reasonable and supportable
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