Provisions for possible loan losses. Formation of reserves for possible loan losses. The procedure for creating a provision for possible loan losses

Banking organizations are required to create reserves to compensate for the monetary expression of the risks of activities. One of the main risks is the likelihood of default on loans issued. For an even transfer of possible financial losses to the results of work, it is necessary to form a reserve for loan losses. It is formed in an amount calculated on the basis of the standards of the Central Bank of the Russian Federation.

Provision for possible loan losses

The reserve is created to smooth out the negative impact of situations with the depreciation of loans issued. This can happen under the influence of external factors and due to the non-return of money by the debtor. Thanks to the reserve, significant fluctuations in profitability are prevented. The formation of the reserve fund is carried out through regular deductions, which are recorded as part of expenses. The regulation of the issues of reserving money for probable defaults of loans falls within the scope of the Regulation of the Central Bank of June 28, 2017 under No. 590-P.

IMPORTANT! Assessment of issued loans and their distribution by quality category is carried out by banks independently. The amount of potential losses pledged into the reserve is determined by the amount of possible depreciation of credit resources.

The volume of probable losses is equal to the difference between the indicators book value loan (outstanding debt balance) and fair appraised value. Provisions can be created separately for each loan or in relation to a set of homogeneous loan commitments. Assessment of a loan according to its quality level is carried out regularly from the moment the loan money is issued to the client.

REMEMBER! In the role of evaluation criteria for loans, conditions such as the financial position of the debtor and the dynamics of its change, the conscientiousness shown by the borrower in fulfilling the obligations to repay the loan are used.

Formation of the reserve

In calculating the total amount of reserve funds banking organizations take into account the categories of loans. According to the quality standards of the Central Bank of the Russian Federation, there are five of them:

1. For the first category of loans, provisions are equal to 0%. These are standard loans classified as the highest quality category. There is no explicit credit risk.
2. The second group is characterized by regular crediting to the reserve fund of up to 20% of the amounts owed to the bank. These are non-standard credit obligations of customers, which are assigned a moderate level of impairment risk.
3. For debts of the third category, deductions amount to 21-50% of the volume of such loans. This is a portfolio formed by doubtful debts. The likelihood of material damage during their maintenance is high.
4. The fourth group includes debts, the return of which is doubtful. For them, reserves are created in the amount of 51-100%. Such problematic credit funds have a high risk of non-return or delay in payments.
5. The fifth category is made up of bad debts, for which provisions are equal to the amount of credit funds.

NOTE! The amount of the reserve directly depends on the quality of the loans.

central bank recommends considering loans from 2-5 categories as sources of risk. They are called partially or fully discounted. The resources of the reserve funds are credited to an open interest-free account. This account is interest-free, its purpose is to accumulate funds and ensure their safety.

The formation of reserve funds is carried out in national currency... The reserve system should be applied by all banks issuing loans (regardless of the currency of the loan). When implementing guarantee deductions, it is recommended to preliminarily classify loans and make up homogeneous loan portfolios from them. The distribution of loans by portfolios is carried out according to several criteria:

• debts of individuals, legal entities and individual entrepreneurs are shown separately;
• loans are divided into groups of secured and unsecured;
• additional division is made according to the degree of discipline of the debtors.

A professional value judgment is made on the basis of measures for a comprehensive analysis of the debtor's activities and his financial situation. The formalized results should contain information:

• about the existing level of risk of insolvency of the client;
• about the analytical procedures performed and the applied methodology;
• to assess the quality of loan service;
• calculated reserve data for a specific debt.

By legal entities as a source of information for the analysis of solvency are accounting documentation, tax returns, reporting, content of statistical forms.

NOTE! The procedure for the formation of the reserve fund and the methodology for assessing the solvency of borrowers should be spelled out in internal documents jar.

Accounting and tax accounting

In situations where the estimated value of the reserve fund turned out to be less than the volume of deductions actually made to the reserve, the difference in values ​​is allocated and transferred to income items of activity. During the next operation to assess the level of risk of a loan, the category of the loan can be changed. In this case, the debt is reclassified. It is the basis for additional accrual of the reserve or reduction of its size. An alternative way is to write off the entire amount of the reserve fund for a specific debt to the bank's income and form a guaranteed reserve of money in the updated volume.

FOR YOUR INFORMATION! The way of reflecting adjustments in the amount of reserves should be fixed by the local documents of the financial institution.

In reporting forms banking structures information should be disclosed about new loans issued, the facts of writing off bad debts, the level of repayment of existing obligations by clients, cases of loan reclassification. The size of the reserve funds is determined as a whole for the bank, including the resources of branch offices.

The display of information on loan reserves in accounting is carried out according to the rules approved by the Regulation of February 27, 2017 under No. 579-P. The chart of accounts provides for several sub-accounts to systematize data on reserve funds. The movement on these accounts renders a complex of operations for accrual, increase in reserves, restoration of the amounts previously deposited in them with subsequent attribution to income items.

The accounts on which data on reserves of possible loan losses are systematized are classified as passive. The formation process of the reserve is displayed using credit turnovers, the debit movement shows a decrease in the created fund due to the reassessment of the quality of loans or the write-off of bad debts. With help analytical accounting banks create an information base on reserves formed in the context of each client and broken down into agreements or portfolios of homogeneous obligations.

Art. 297.3 of the Tax Code of the Russian Federation regulates issues tax accounting this type of reserves of credit structures. The deductions made are recorded in the expenses of the organization. These costs are recognized as a portion. After writing off the recognized bad debt from the balance sheet, interest on the loan ceases to accrue. If the value reserved funds according to the results tax period was not used by the bank in full, the balance is carried over to the next year. The size of the new reserve should be adjusted for the balances of previous years, which may be included in the current reserve funds.

Typical wiring

The formation of the reserve is reflected in correspondence with the debit of the expense account and the crediting of the subaccount allocated for the reserve funds:

• D70606 - K32015 (32115, 32505, 32211, etc.)- when reserving resources for possible losses on loans issued to other credit institutions;
• D70606 - K44115- provision for loans provided government bodies and extrabudgetary funds;
• D70606 - K45215- creation of a reserve for loans to legal entities;
• D70606 - K45415- provisioning to cover probable losses due to depreciation of loans issued by individual entrepreneurs;
• D70606 - K45515- Reservation of funds for the obligations of clients from the category of individuals.

Provided that the loan is repaid by the debtor, reserve resources lose their relevance. They must be recovered for income. This is done by posting between the debit of the sub-account for the reserve and the credit of account 70601.

Qualitative and quantitative assessment of the loan portfolio risk is carried out simultaneously using the following risk assessment methods loan portfolio:

· Analytical;

· Statistical;

· Coefficient.

The analytical method is an assessment of possible losses (risk level) of the bank and is carried out in accordance with the Regulation of the Bank of Russia dated 26.03.2004. No. 254-P "On the formation procedure credit institutions reserves for possible losses on loans, on loan and equivalent indebtedness ”. This Regulation stipulates that the classification of loans issued and the assessment of credit risks should be carried out by banks on integrated framework depending on the following criteria:

· financial condition the borrower, assessed using the approaches used in domestic and international banking practice;

· The ability of the borrower to repay the principal amount of the debt with interest, commissions and other payments due to the bank under the loan agreement, which characterize the quality of debt service;

· The borrower has high-quality and highly liquid security in an amount sufficient to compensate the bank for the principal amount of the debt on the loan, all interest in accordance with the agreement, as well as possible costs associated with the exercise of security rights;

· The presence and duration of overdue payments on the principal debt and interest on it;

· The number of re-registration of the loan debt during the validity of the loan agreement.

The reserve is formed by the bank in case of impairment of the loan (s), that is, in case of loss of value of the loan due to non-fulfillment or improper fulfillment by the borrower of loan obligations to the credit institution or the existence of a real threat of such non-fulfillment (improper fulfillment) (see Regulation of the Central Bank of the Russian Federation No. 254-P dated 26.03 .2004, clause 1.3.).

The amount of the loss of value by the loan is determined as the difference between the carrying amount of the loan, that is, the balance of the debt on the loan, reflected in the accounts accounting at the time of its measurement, and its fair value at the time of measurement. The fair value of the loan is measured on an ongoing basis from the inception of the loan.

The provision is formed for a specific loan or for a portfolio of homogeneous loans, that is, for a group of loans with similar characteristics credit risk, and segregated in order to form a provision in connection with the credit risk caused by the activities of a particular borrower (group of borrowers), the loans to which are included in the portfolio of homogeneous loans.

In order to determine the size of the estimated allowance due to the influence of factors of credit risk, loans are classified on the basis of professional judgment (except for loans grouped in a portfolio of similar loans) into one of five quality categories (table 3).

Table 3

The Bank creates provisions for portfolios of homogeneous loans in accordance with the methodology used by it for assessing risk for the corresponding portfolios of homogeneous loans. The Bank distributes the formed portfolios of homogeneous loans into the following quality categories (see table 4).

Table 4

The provision is formed within the amount of the principal debt (the book value of the loan). The reserve is formed in the currency of the Russian Federation, regardless of the currency of the loan.

The credit risk assessment for each issued loan (professional judgment) should be carried out by the bank on an ongoing basis. Professional judgment is made based on the results of a comprehensive and objective analysis of the borrower's activities, taking into account his financial position, the quality of the borrower's debt service under the loan, as well as all the information at the bank's disposal about the borrower, including any risks of the borrower, including information about the borrower's external obligations, the functioning of the market in which the borrower operates.

The bank's professional judgment must include:

· Information on the level of credit risk on the loan;

· Information about the analysis, based on the results of which professional judgment was made;

· Conclusion on the results of assessing the financial position of the borrower;

· Conclusion on the results of assessing the quality of debt service on the loan;

· Information on the presence of other significant factors taken into account when classifying a loan or not taken into account, indicating the reasons why they were not taken into account by the bank;

· Calculation of the reserve;

· Other essential information.

All information about the borrower, including information about the risks of the borrower, is recorded in the borrower's file. The information used by the bank to assess the quality of the loan, including the assessment of the financial position of the borrower, should be available to the governing bodies, internal control units, auditors and banking supervisors.

The bank duly documents and includes in the borrower's dossier professional judgment. Professional judgment is formed and documented at the time the loan is issued and is subsequently drawn up within a month after the end of the period established for reporting to the tax authorities as of the quarterly (annual) reporting date.

The formation of a reserve for possible losses on loans is made at the time of issuance of loans. Every month, on the last business day, the bank adjusts it depending on the balance of outstanding loans, changes in the estimated parameters of the loan quality (collateral, changes in the terms of the original loan agreement, the financial condition of the borrower, the duration of overdue loan payments and interest).

The essence of the statistical method is as follows:

1) analysis of statistics of credit risks in relation to agreements that make up the bank's loan portfolio;

2) characteristics of the measure of dispersion of credit risks in the loan portfolio;

3) determination of the magnitude and frequency of occurrence of credit risk.

The main tools of the statistical method for calculating and assessing the risk of a bank's loan portfolio are: variance, variation, standard deviation, coefficient of variation and asymmetry.

The essence of the coefficient method for assessing credit risk is to calculate relative indicators that allow assessing the credit risks included in the bank's loan portfolio, the calculated values ​​of which are compared with the standard assessment criteria, and on this basis, the level of the bank's aggregate credit risk is qualitatively and quantitatively determined.

Material from the site

Required bank reserves

Reserve requirements in relation to the obligations of commercial banks, they are used to regulate the overall liquidity of the banking system and are one of the main instruments of monetary regulation.
Mandatory reserves banks provide a part of the credit resources contained in an interest-free account opened with the Central Bank. The credit institution is obliged to create these reserve funds in order to ensure financial reliability.
The reserve policy is a part of the monetary policy of the Central Bank, which is established to control monetary aggregates by reducing the money multiplier and maintaining the money supply in circulation at a certain level.

The essence of bank reserve requirements

In accordance with the law, a banking institution is obliged to classify assets, highlighting doubtful and bad debts, and create reserves in the manner established by the Central Bank to cover possible losses, possible losses on loans, foreign exchange, interest and other financial risks and guaranteeing the return of deposits.
The obligation to fulfill reserve requirements arises from the moment of obtaining a license for the right to carry out banking operations.

Types of bank reserves

Required bank reserves- tool for control Money by reducing money accumulation commercial banks... A similar mechanism is established in order to limit the lending opportunities of financial institutions.
The required reserves of the bank are kept at the Central Bank as a guarantee financial fund ensuring reliable fulfillment of its obligations to customers. These highly liquid assets cannot be used in the event of unfavorable circumstances for the bank.
Bank reserve fund- part equity capital formed due to the growth net assets... The reserve fund serves to cover losses of the bank arising from its activities, as well as to increase authorized capital... At the end of the year, the bank can make contributions to the reserve fund only if there is a profit.
Provisions for possible losses
The formation of a bank reserve is done in order to avoid the following risks:

• failure to fulfill obligations on the part of the bank's counterparties for operations or concluded transactions;
• decrease in the value of bank assets;
• an increase in the volume of liabilities / expenses of the bank in comparison with previous periods.

Provision for possible loan losses
The provision is formed in case of loan impairment due to default by the borrower financial commitments or there is a real threat of such failure. The provision is formed for a specific transaction or for a group of loans with similar characteristics of credit risk (loan portfolio). See below for details.
Other bank reserves
In addition to the main reserves of the bank, there are others to prevent possible losses on other assets:

Bank reserve under balance sheet assets for which there is a risk of losses;

Reserve for instruments reflected in off-balance sheet accounts;

Reserve for forward transactions;

Bank reserve for other losses.

In fact, of all the listed bank reserves, only the reserve fund is effective - due to this fund, the bank can influence its expenses. The increase in all other reserves does not affect financial stability, and therefore not as effective.

Provisions for possible loan losses

Provisions for possible loan losses – money fund formed commercial bank to cover risks on active operations, in particular on credit transactions. Potential risks mean loan impairment due to default or improper performance by the borrower of its obligations.
The formation of the reserve provides the bank with a more stable financial environment and allows it to avoid fluctuations in the amount of profit associated with the write-off of loan losses. Provisions for loan losses are formed from deductions for expenses.

Definition of loans

Loans mean not only lending operations, but also the following transactions with financial instruments from which monetary claims arise:

• Loans granted, including interbank loans, other funds placed, including claims to receive (return) debt securities provided under a loan agreement.
• Amounts paid by a credit institution under bank guarantees, but not collected.
• Monetary claims for factoring transactions.
• Rights of claim acquired under the transaction (assignment of claim).
• Requirements for acquired mortgages.
• Bank claims for transactions with financial assets with a deferred payment.
• Requirements for payers for paid letters of credit.
• Requirements of a credit institution as a lessor for operations finance lease(leasing).

The procedure for creating a provision for possible loan losses

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Credit risk is the risk of non-payment by the borrower of the principal and interest or the inability of the counterparty to a credit transaction to act in accordance with the obligations assumed.
In case of non-payment of interest, the bank loses its income, in case of non-repayment of the principal debt, the bank writes off the bad loan as an expense and accordingly incurs a loss on this credit transaction. Methods for calculating the probability of expected income from a credit transaction are given in sufficient detail in the economic literature. Credit risk is mathematically formed as the probability of a loss, the value of which is determined on the basis of statistical data and can be calculated with a sufficiently high accuracy. The magnitude of the risk is assessed according to two criteria: the average expected value and the range of possible results. To determine the amount of risk, it is necessary to calculate possible options the outcome of a credit transaction and their likelihood (based on statistical data).
Of course, other "intermediate" options are also possible, for example, partial repayment of the principal and interest in their various combinations. Knowing the distribution of the probabilities of various outcomes of a credit transaction, the expected income, the standard deviation of income from the mean and the probability of the expected income are determined.
There are the following ways to minimize credit risks:
- diversification of the loan portfolio;
- preliminary analysis the creditworthiness and solvency of the borrower;
- application of methods to ensure the repayment of a loan (pledge, sureties, guarantees, cession, insurance);
- formation of reserves to cover possible losses on loans.
Reducing credit risk is one of the most important tasks of managing the bank's loan portfolio. A conclusion about how urgent the problem of credit risk is can be made by comparing data on overdue loans for the ten largest Russian banks(example of such banks as of January 1, 1992).
Instruction of the Central Bank of Russia No. 62-a of June 30, 1997 "On the procedure for the formation and use of the reserve for possible loan losses" also determines the methods for assessing credit risks.
Provision for Possible Loss Loss (LOI) - a special reserve, the need to form which is due to credit risks in the activities of banks. It provides banks with a more stable environment financial activities and allows you to avoid fluctuations in the value of banks' profits in connection with the write-off of loan losses.
The source of formation of the RVPS is the deductions attributed to the bank's expenses.
The purpose of the RVPS is to cover unpaid loans by clients (banks) on the principal debt. This reserve is used to write off losses on unrecoverable bank loans. Loan debt is recognized as not real for collection, for which the measures taken to collect are full (including the sale of the pledge) and indicate the impossibility of taking further actions to return the loan.
Loans are divided into four groups depending on the magnitude of the credit risk:
1st group - standard (practically risk-free loans);
2nd group - non-standard loans (moderate risk of default);
3rd group - doubtful loans (high level of risk);
4th group - bad loans (there is practically no probability of repayment, the loan represents the actual losses of the bank).
In classifying loans, it is preferable to overestimate rather than underestimate the perceived risk.
Credit risks are assessed by banks for all loans and all customer debt equated to a loan, as in Russian rubles, and in foreign currency, namely:
- for all loans provided, including interbank loans (deposits);
- on promissory notes purchased by the bank;
- for amounts not collected under bank guarantees;
- for operations carried out in accordance with a financing agreement against the assignment of a monetary claim (factoring).
The classification of loans is carried out by the bank independently or by an audit organization (on the basis of an agreement) in the process of analyzing the quality of the bank's assets. The classification of issued loans and the assessment of credit risks are carried out on an integrated basis, depending on the financial condition of the borrower, assessed using the approaches used in the domestic and international practice, the borrower's ability to repay the principal and interest on it. Interest is understood as the interest, commission or other payments of the borrower in favor of the bank stipulated by the loan agreement.
Risk assessment is carried out simultaneously with the provision of a loan (taking into account a bill of exchange, the occurrence of a debt equated to a loan), and subsequently - when changing the parameters that are used as classification criteria.
The risk group is determined based on two assessment criteria:
- loan security;
- the nature of the borrower's performance of the terms of the loan agreement.
Collateral is understood as a pledge, the quality of which is determined by the real (market) value of the pledged items and the degree of their liquidity. When determining the market value of a pledge, the actual and future state of the market conditions by types of property pledged, as well as reference data on the price level, are taken into account.
According to the quality of collateral, the following groups of loans are distinguished:
- secured;
- insufficiently secured;
- unsecured.
Secured loan - loan, which has security in the form of a pledge in cases where the pledge simultaneously meets the following requirements:
- its real (market) value is sufficient to compensate the bank for the principal amount of the debt on the loan, all interest in accordance with the agreement, as well as possible costs associated with the implementation of security rights;
- all legal documentation in relation to the pledge rights of the bank is drawn up in such a way that the time required for the sale of the pledge does not exceed 150 days from the day when the exercise of the pledge rights becomes necessary for the bank. This need arises no later than on the 30th day of the delay by the borrower of regular payments to the bank on the principal debt or on interest.
The category of secured loans also includes loans issued under the guarantee of the Government Russian Federation, constituent entities of the Russian Federation or under the guarantee of the Bank of Russia, surety of representative offices and guarantees of the central banks of the countries of the Organization economic cooperation and Development (OECD), as well as promissory notes advanced by these banks.
An undersecured loan that is secured by collateral that does not meet at least one of the collateral requirements for a secured loan.
The category of insufficiently secured also includes loans issued against a bank guarantee of banks in OECD countries, and promissory notes advanced by these banks.
An unsecured loan that is unsecured or secured by collateral that does not meet the above requirements.
It should be noted that market price mortgaged property can go down. Therefore, the value of the collateral must be higher than the requested loan.
Current loans are loans for which there is no overdue debt on the payment of the principal debt and no additional rollover agreements have been concluded. The duration of the delay in payment of the principal or interest payments is calculated in calendar days.
When regulating the amount of the created reserve for possible losses on loans, one should adhere to the rule: in the case when the borrower is provided with loans for several credit agreements, all debt attributable to this borrower is attributed to the maximum risk group assigned for one of the loans provided.
When the borrower repays a loan that was previously attributed to the maximum risk group for this borrower, the outstanding loan outstanding for the borrower is classified again and the corresponding amount of the reserve for possible loan losses is determined.
In case of non-repayment of debt, banks are obliged to:
- at the end of the working day, the date of which is the date of repayment of the principal debt, established by the agreement or other document, transfer the balances of the customer's debt in the part of the principal debt to the accounts of overdue debt;
- at the end of the working day, the date of which is the date of payment of interest on the loan at the expense of a new loan granted to it by the primary lender bank or a bank related to it, this newly issued loan is classified as bad.
In the event of a phased debt repayment, the credit risk assessment of the entire loan debt is made on the basis of maximum number days that have passed after the due date of all regular payments (for the principal debt or for interest). Regardless of the mode of debt repayment, a reserve is created for the entire amount of the principal debt.
Provision for possible loan losses (RVL) is formed at the time of issuing a loan in the currency of the Russian Federation - in rubles. The total amount of the reserve (balances on the accounts for recording the reserve for possible losses on loans) should be updated (adjusted) on a monthly basis depending on the amount of the actual loan debt, including taking into account the change in the amount of the principal debt when the ruble exchange rate changes in relation to foreign currencies on the date of regulation, and from the risk group to which this or that loan is attributed (bill of exchange recorded by the bank).
The above procedure for writing off the bank's balance sheet debt applies to all types of loans and other debts of clients, equated to a loan, for which reserves were created, regardless of the amount of the reserve created for these loans.
RVPS is used only to cover outstanding loans on the principal debt by clients (banks), and on promissory notes - for the amount of promissory notes, minus the discount percentage.
Uncollectible or uncollectible debt is written off the bank's balance sheet at the expense of the reserve for possible loan losses. The decision is made by the bank's board of directors or supervisory board.
Reimbursement of losses received in the reporting year is carried out in accordance with the procedure established by the Central Bank of Russia.
The grounds for writing off the loan debt can be:
- determination of the people's judge to terminate enforcement proceedings to collect debt from the debtor (guarantor or surety) in favor of the creditor;
- resolution of the bailiff-executor on the return of the executive document;
- decisions of the arbitration court on the compulsory liquidation of the debtor enterprise (recognition of the enterprise as insolvent, i.e. bankrupt), as well as in the case of voluntary liquidation of the debtor enterprise. In any case, the creditor bank must confirm its participation in bankruptcy proceedings, as well as inability to satisfy their claims at the expense of the debtor's bankruptcy estate;
- a court decision on recognizing the debtor citizen as missing;
- a court decision declaring a citizen dead;
- other documents confirming the impossibility of repayment of overdue loans by the debtor, provided for by the current legislation.
Writing off the loan debt from the bank's balance sheet due to the debtor's insolvency is not a cancellation of the loan debt. Debt written off from the balance sheet is reflected in the balance sheet for at least five years from the date of its write-off; this procedure is established to monitor the possibility of its recovery in the event of a change in the property status of the debtor, cancellation of earlier decisions (rulings) of the judicial authorities, discovery of the place of residence of a citizen recognized as missing or dead, recognition of the bankruptcy of an enterprise as fictitious, etc.
The Central Bank of Russia, in order to exercise compulsory supervision, including based on the results of an audit, has the right to present a demand to the bank for a revaluation of loan debt, if this follows from the results of an assessment of the bank's loan portfolio. Based on the results of the assessment, the bank may be required to both additionally accrue a provision for loan debt, and to reduce the amount of the actually created provision.
In case of detection supervisory authorities The Central Bank Russia of unjustified understatement by credit institutions of the quality of the loan portfolio and a decrease in the taxable base as a result of this, the Central Bank is obliged to submit a requirement to reassess the quality of assets, amend the calculation of the reserve for possible losses on loans and before transferring funds to the budget.

Are obliged to create a provision for possible loan losses. This follows from the provisions of clause 1 of the Ordinance of the Bank of Russia dated July 14, 2014 No. 3321-U. The reserve is created so that when calculating income tax, it would be possible to take into account the estimated losses from non-repayment of loans issued and interest on them.

We emphasize that the formation of a reserve does not at all mean that a special fund of funds needs to be created on the organization's current account. The reserve is formed only in tax accounting - for this, a certain amount of deductions is regularly recognized in non-operating expenses. General order and the conditions are spelled out in article 297.3 Tax Code RF (subclause 3, clause 2, article 297.2 of the Tax Code of the RF). The specifics of forming a reserve for microfinance organizations are established by Bank of Russia Ordinance No. 3321-U dated July 14, 2014. Read about everything in detail in this recommendation.

Attention: along with a reserve for possible losses on loans, microfinance organizations have the right to create reserves for doubtful debts... But the simultaneous formation of two reserves under the same loan agreement is prohibited.

The debt taken into account when creating a reserve for possible losses is not recognized as doubtful (paragraph 4, clause 1 of article 266 of the Tax Code of the Russian Federation). Therefore, if the microfinance organization included the alleged losses on any loan in the calculation of the provision for possible losses, it is not entitled to take these losses into account when forming the reserve for doubtful debts. Similar clarifications are contained in the letter of the Ministry of Finance of Russia dated September 4, 2015 No. 03-03-05 / 51075 (brought to the tax inspections by the letter of the Federal Tax Service of Russia dated October 1, 2015 No. GD-4-3 / 17136).

How often to form a reserve

Make a reserve on a quarterly basis. To do this, as of the last day of the quarter, take an inventory of the loans issued. And for those obligations that have not been fulfilled by the borrowers on this date in whole or in part, create a reserve. This follows from clause 2 of the Ordinance of the Bank of Russia dated July 14, 2014 No. 3321-U.

If a microfinance organization has restructured loans for the last day of the quarter, it is also necessary to form a reserve for them. Even if there is no delay in payments for such obligations.

Create loan loss provisions separately for:

• principal amount of debt;

• accrued interest on the loan.

Where to begin

To determine the amount of the reserve, you need to know the category of the borrower, whether the loan is secured and how much overdue payments on it are. Stick to the following algorithm.

Step 1. As of the last day of the quarter, separate the restructured loans from the total number of loans issued. These loans should be counted as a separate group.

Attention: Until June 30, 2015, when forming a reserve, microfinance organizations are allowed to take into account restructured loans together with loans for which there is a delay in payments (letter from the Bank of Russia dated December 26, 2014 No. 01-56-2 / 10625).

Step 2. Then identify the loans that were outstanding (in whole or in part) as of the last number of the quarter. Check to whom these loans were issued:

• individuals;

• entrepreneurs;

• organizations.

A separate reserve must be formed for each group of borrowers.

Step 3. For each group of loans (including restructured ones), determine whether these loans are secured by a pledge, surety or bank guarantee... You can find out about this from the terms of the loan agreement. The security of the issued loan will affect the amount of deductions to the reserve. If the issued loan is secured by a pledge, surety or bank guarantee, then the deductions to the reserve for such loans will be lower. If the loan is not secured by anything, the deductions will be higher.

Step 4. Determine how many days the loan payments are overdue. With this in mind, loans should be divided into groups in increments of 30 calendar days... That is, loans with a delay of one to 30 days are one group. From 31 to 60 days - the second, etc.

This procedure is provided for by clause 4 of the Bank of Russia Ordinance No. 3321-U dated July 14, 2014.

How to determine the amount of the reserve

Provision for possible losses on loans in the part of the principal debt form for the entire amount of loans included in this or that group. Include all principal debt in the calculation, not just overdue debt. Since the borrower once violated the terms of the contract and did not pay, albeit in part, it is possible that he may also owe the entire amount.

Attention: when creating a reserve, do not take into account debt on loans issued before January 4, 2011 (clause 1 of the Ordinance of the Bank of Russia No. 3321-U of July 14, 2014). It was from this date that the Law of July 2, 2010 No. 151-FZ entered into force and the requirement to create a reserve began to operate.

The reserve for the principal debt is determined by the following formula:

Loan loss provision for interest claims calculate by the formula:

Calculate the reserve for interest requirements for each loan separately. These are the requirements of clause 7 of the Ordinance of the Bank of Russia dated July 14, 2014 No. 3321-U.

Total provision for possible loan losses calculate by the formula:

Note: from 2014 to 2017, it is allowed to form provisions for possible loan losses not in full, but taking into account the minimum values ​​specified in clause 9 of the Bank of Russia Ordinance No. 3321-U dated July 14, 2014. That is, even if the estimated amount of the reserve is greater than minimum value, during these years, the reserve can be created in minimum size... For 2016, this minimum is 60 percent of the calculated value.

How to use the reserve

Use the formed reserve for possible loan losses to write off bad debts on loans. But remember that before writing off a debt, the organization must take all measures to collect it. For more on this, seeHow to issue and reflect in the accounting the write-off of uncollectible receivables .

Write off bad debt on loans in the following order:

• collect all the documents that allow you to recognize the debt as uncollectible ( source documents, contracts, letters with claims to the debtor, extracts from the Unified State Register of Legal Entities or certificates tax office on liquidation of the debtor, court decisions and other documents);

• Conduct an inventory of outstanding loans and determine the debt for which the delay in payments was at least one year;

• issue a manager's decision to write off bad debt on a loan.

This procedure is provided for by clauses 8 and 9 of the Ordinance of the Bank of Russia dated July 14, 2014 No. 3321-U.

If the reserve is not used by the end of the quarter following the quarter of the provision, then carry over the unspent amounts to the next period. Moreover, the amount of the newly created reserve must be adjusted.

So, if the newly created reserve is less than the carry-over balance, then include the difference in non-operating income. If the newly created reserve is greater than the carry-over balance, then include the difference in non-operating expenses.

This procedure is provided for by paragraph 4 of Article 297.3 of the Tax Code of the Russian Federation.

An example of the reflection in the tax accounting of a microfinance organization of the unspent balance of the provision for possible loan losses

Microfinance organization Alpha, as of December 31, 2015, created a provision for possible loan losses in total amount RUB 300,000

The unspent amount of the reserve amounted to 120,000 rubles. This amount must be carried over to the next period (March 31, 2016) and the newly created reserve must be adjusted.

As of March 31, 2016, the organization carried out an inventory of the loans issued. The amount of the provision for possible loan losses amounted to 200,000 rubles.

The amount of the newly created reserve (200,000 rubles) exceeds the unspent amount of the reserve (120,000 rubles) for past period... The difference was:

RUB 200,000 - 120,000 rubles. = RUB 80,000

When calculating income tax in the first quarter of 2016, Alpha's accountant included non-operating expenses RUB 80,000

Tax register

When creating and using a provision for possible loan losses, you need to maintain a separate tax register. Develop its shape yourself. Specify in the document:

• register name;

• accounting period;

• the estimated amount of the reserve;

• a list of loans issued for which there is a delay in payments;

• the amount of deductions to the reserve, which are accounted for as part of non-operating expenses;

• part of the reserve that is included in non-operating income;

• the amount of the provision used to cover losses on bad debts.

The register is signed by the accountant responsible for maintaining it. This procedure follows from the provisions of Article 314 of the Tax Code of the Russian Federation.