THEME • FINANCIAL REPORTING & VALUATION

Impairment Analysis: Bridging the gap between Appraisers and Auditors responsibilities

By CA. Snehal Pawar•Member of the Institute•The Chartered Accountant Journal • October 2023 (Vol. 72, No. 04, pp. 35–38, Journal pp. 447–450)

In recent times, the use of auditor-employed experts as part of the audit procedures has increased. This can be attributable to various factors including audit risk, expertise and skills required to test critical inputs that form part of the valuation exercise, Management or Management-employed appraiser’s expertise required to perform the valuation, etc.

Point in discussion is Standard on Auditing 620: Using the work of an auditor’s expert. While the SA 620 is effective for all audits beginning on or after April 1, 2010; the practical application/adoption of the same has seen increased interest and adoption more recently. However, the auditor has sole responsibility for the audit opinion expressed, and that responsibility is not reduced by the auditor’s use of the work of an expert. Further, the Valuation Standards Board has laid down stricter valuation guidelines and responsibilities to adhere to such standards and guidelines vests on the appraiser’s shoulders. Therefore, one can now witness that there is greater accountability and responsibility on both, the appraiser and auditor.

This article is focused to tackle practical challenges while performing audit review of valuation performed for impairment testing under Ind AS 36- Impairment of Assets. To make this document more relatable, the subject is presented in a FAQ format.

Most of us are aware that the objective of Ind AS 36 is to prescribe the procedures that an entity applies to ensure that its assets are carried at no more than their recoverable amount.”

Carrying Amount
−
Recoverable Amount
=
Impairment Loss

Credentials and Experience

Question: Who is responsible for determination of Recoverable Amount? How to evaluate competencies, capabilities, and objectivity of Management-employed appraiser?

The Management of the entity (“Management”) is responsible for determination of Recoverable Amount. The Management shall either prepare these with the assistance of skilled personnel internally or employ an independent third-party appraiser for determination of Recoverable Amount. In either case, the person undertaking the impairment analysis should have the necessary qualification, experience, skills, and knowledge in the relevant field.

Auditor’s RoleAppraiser’s Role

For the auditor to express an opinion whether there exists an impairment loss; the auditor is required to review either the Management prepared analysis of Recoverable Amount or use work of an auditor’s expert.

The auditor is required to verify and document reasonable and appropriate evidence in connection with the competencies, capabilities and objectivity of the person assisting in determination of Recoverable Amount.

This is critical to stay compliant with Standard on Auditing 230: Audit Documentation (“SA 230”). Typically, this should incorporate the appraiser’s work experience relevant to financial reporting related valuation and check if they have the necessary qualification / license to practice in the jurisdiction.

The appraiser shall incorporate their valuation profile as part of or supplementary to the Valuation Report citing various types of engagements performed along with details of their professional qualifications / accreditation and licenses to perform valuation in the specific class of asset for financial reporting purposes.

As best practice measures, the appraiser shall disclose their independence in the cover letter of the Valuation Report.

Recoverable Amount

Question: What is Recoverable Amount under Ind AS 36? What are the valuation techniques/methods to determine FVLCOD and VIU?

If either of these amounts exceeds the asset’s carrying amount, the asset is not impaired, and it is not necessary to estimate the other amount.

The Recoverable Amount of an asset or cash generating unit (“CGU”)
Fair Value Less Cost of Disposal (“FVLCOD”)
OR
Value in Use (“VIU”)

To understand the two methods for determining the Recoverable Amount, let us look at various elements of each of these methods.

ParticularsFVLCODVIU
Definition

FVLCOD = FV Less Cost of disposals

Fair Value is defined as “the price that would be received to sell and asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.”1

Cost of disposals are incremental costs directly attributable to the disposal of an asset or CGU, excluding finance costs and income tax expenses.2

Value in use is the present value of future cash flows expected to be derived from an asset or CGU.3

Valuation techniques

Fair value is a market-based measurement. Therefore, it is measured using the assumptions that market participants would use when pricing the asset or CGU as at the measurement date.

Example:

  • Condition and location of the asset
  • Restrictions, if any, on the sale or use of the asset

As a result, Fair Value could be determined using either of the generally accepted valuation techniques/approach depending on fair value hierarchy of inputs available. These approaches are:

  • Income approach
  • Market approach
  • Cost approach

Once the Fair value is determined using any of the commonly accepted valuation methods (example: discounted cash flow method, Guideline Public Company Method or Guideline Transaction Method), the cost of disposal is subtracted from the Fair Value to arrive at the Fair Value less Cost of Disposal.

VIU is an entity-specific measurement.

The estimated future cash flows should be over a period of 5 years. Longer period needs to be justified with strong rationale.

The estimates of future cash flows should include:

  • Projections of cash inflows from continuing use of asset
  • Projections of cash outflows necessarily incurred to generate cash inflows from continuing use of the asset and can be directly attributable, or allocated on a reasonable and consistent basis, to the asset; and
  • Net cash flows, if any, to be received (or paid) for the disposal of the asset at the end of its useful life

Future cash flows shall be estimated for the asset in its current condition and exclude cash flows expected to arise from:

  • Future restructuring to which an entity is not yet committed; or
  • Improving/enhancing asset’s performance

Audit Review & Documentation Framework

Question: How can appraiser’s/valuer’s report assist auditors in obtaining reasonable and sufficient evidence as part of audit procedures?

A detailed and well-documented Valuation Report is fundamental to the audit procedures. However, here is a tabular presentation of certain key estimates that each appraiser can focus on documenting in their Valuation Report. This shall enable any independent reader of the Valuation Report to fully understand the analysis who has basic knowledge of valuation.

Auditor’s ResponsibilityHow can Appraiser’s help bridge the gap?
Projections Reasonableness Testing

Auditor is required to understand, verify, and document the reasonableness of estimated future cash flow projections directly attributable to or allocated to the asset or CGU including various inputs and estimates in connection with:

  • revenue growth rates
  • profitability margins and growth rates
  • recurring and non-recurring expenses
  • maintenance capex versus additional capex requirement
  • working capital requirement
  • terminal growth rate

Projections are ultimately the responsibility on the Management. Appraiser can ensure that the Management provided Board approved projections for the purpose of impairment analysis.

Further, appraiser shall document the sources of information in a separate section outlining various information/ data points that form part of the analysis and has been used in the value conclusion. This information can be provided by the Management based on their knowledge and experience in the industry, appraiser’s research from subscription-based platforms/database, industry reports or public domain and discussion with the Management.

Few sources of information that assist an auditor in understanding and documenting Projections Reasonableness memo are:

  • Financial and tax due diligence reports at the time of acquisition, if any.
  • Board approved projections and related KPIs.
  • Historical financial statements and trend analysis.
  • Previous year’s budgets and reasons for variations, if any.

This assists auditors in understanding the reliability and consistency of the inputs used and verify for the accuracy of the same.

If possible, appraiser shall document their observations

Discount Rate – Selection of method and components

The auditors are required to check and comment on the selection, consistency and appropriateness of the inputs that form the discount rate. In practice, the most common method of determining the discount rate is the Weighted Average Cost of Capital using the CAPM. Typical inputs used to build the discount rate are:

  • Risk free rate
  • Equity risk premium
  • Beta
  • Size and company specific risk premia
  • Cost of debt
  • Tax rate
  • Debt/Capital ratio

In summary, appraiser is required to document the method used for discount rate selection, various sources of input used in the discount rate conclusion and reason for selection of certain premia (quantitative or qualitative) that form part of the discount rate.

Certain key elements that should be outlined by the appraiser either through their Valuation Report or through a supplementary documentation / communication are as under:

  • Currency Consistency: Explanatory note on how discount rate is consistent with the underlying economic factors of the currency in which the cash flows are denominated.
    Example: If the estimated future cash flows from the continuing use of the asset or CGU are denominated in USD.
  • Risk Alignment: Explanatory note on how assumptions related to discount rate are consistent with those that are inherent in the cash flows.
    Example: Ideally, any adjustment related to risk of achieving the estimated cash flows over the projected period should be part of the cash flows. However, in case such adjustments do not form part of the cash flows, then appraiser can bake in the risk of not achieving Management projections as part of company specific risk premia in the discount rate build-up. Ideally, other risk premia constitute various components based on size, growth, profitability analysis that enable the appraiser to quantify such additional risk premia.
  • Tax Consistency: Explanatory note on assumptions related to cash flows and discount rates being internally consistent.
    Example: After-tax cash flows should be discounted using an after-tax discount rate and pre-tax cash flows (in case of VIU) should be discounted at a rate consistent with those cash-flows.
  • Sources Disclosure: It is recommended to add a “Sources of information” section to give the reader references to various sources for each input used in the discount rate.

References & Standards

  1. Ind AS 113 – Fair Value Measurement
  2. Ind AS 36 – Impairment of Assets
  3. Ind AS 36 – Impairment of Assets
Author may be reached at eboard@icai.in
Published by The Institute of Chartered Accountants of India (ICAI)