| source Business Standard Companies Act likely to jolt realty firms |
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Mumbai, 20 April The recently- enacted Companies Act, 2013, is expected to give a jolt to real estate companies, already facing a severe fund crunch due to falling sales and high debt on books. Section 185 of the Act, among other things, says a company cannot give loans to (or provide security on a loan taken by) a person in whom its director is interested. According to the Act, " any person in whom a director is interested" could mean a director of a lending company or its holding firm, or a partner or relative of any such director, or a firm in which any such director or relative is a partner, or a private company of which any such director is a director or member. Sai Venkateshwaran, partner &head ( accounting advisory services) at KPMG in India, says promoter directors of several real estate companies could potentially be covered under this law, as many of them are directors of both parent and subsidiary companies. " It could become a liquidity issue for many realty companies. Earlier, funds raised by one company could be freely transferred to another group firm where there was need for liquidity. With the new rules, companies' ability to balance liquidity needs across group entities gets restricted," Venkateshwaran explains. Though the corporate affairs ministry has clarified that a company can lend to its fully- owned subsidiaries, Venkateshwaran doubts this will apply on realty firms. That's because many real estate companies only partly own their subsidiaries — project partners, including land owners, private equity contributors and other investors bringing in capital, too, are owners. Turn to Page 7 > Move to improve transparency but make liquidity more difficult to come by TOUGH TIMES AHEAD Some Companies Act clauses that might pose a challenge for realty developers CLAUSE: No related- party transactions IMPACT: Realty developers have to capitalise each project company and can't take surplus money out CLAUSE: Secure debentures with properties or assets with equivalent value IMPACT: Developers need to find enough assets or properties to secure debentures CLAUSE: If convertible preference shares are issued, value of that must be determined beforehand and taken as total capital of the company IMPACT: Risk of losing majority ownership of a company to NBFCs of PE funds CLAUSE: A company is treated as listed if any of its securities is listed on the exchanges IMPACT: Unlisted companies might have to adhere to conditions meant for listed entities |
| Companies Act likely to jolt realty firms |
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"There used to be a free flow of funds from holding companies to subsidiaries. The changes in the Companies Act will ensure each project will be capitalised sufficiently and surplus cash will not be given to directors or taken out of a company," he says. JC Sharma, vice- chairman of realty company Sobha Developers, says it might affect some developers in the short term but will bring strength to investors and buyers over a longer period. Consultants, however, say the clause that asks for issue of debentures to be secured through creation of a charge on properties or assets of a company, with value sufficient for payment of debentures and interests thereon, could also pose a challenge to real estate companies. Typically, in real estate, land and properties are given as charge to banks, and debentures are secured with future receivables that are not shown on the company's balance sheet. "If you are issuing secured debentures to non- banking financial companies, the Act requires it to be secured against properties or assets with value equivalent to that of debentures," says Venkateshwaran, adding raising funds from NBFCs through debentures might become difficult now, as such financiers might not invest through unsecured debentures. ASK's believes the government needs to clarify on the clause. " The Act says you have to secure debentures with identifiable securities. But, many a time, that is not possible if you are giving a pool of securities to multiple lenders. It will be a burdensome exercise for realty companies," he says. For instance, developers sometimes give land as security to a bank and create secondary charge or ' pari passu' on the same asset if they are to take a second loan from another bank. " In such cases, it will become a challenge for developers," Rohokale adds. Real estate companies, which normally allot convertible shares to NBFCs or PE funds on a preferential basis, will also face a challenge in doing so. The Act says if shares are offered on a preferential basis with an option to apply for and get equity shares allotted, the price of the resultant shares will be determined beforehand. This will make use of convertible preference shares challenging, as the conversion price is usually linked to the expected return at the time of conversion ( and not based on a price determined at the time of issue). The Act also considers convertible preference shares as part of total share capital in determining the holding- subsidiary relationships. This, experts say, will make an NBFC or a fund parent in a project where the borrowing company has a small equity capital base. For instance, if a company has ₹ 10 crore worth of equity share capital and issues convertible shares of ₹ 50 crore to an NBFC on a preferential basis, the company will be considered a subsidiary of the NBFC or fund, and not a company with 100 per cent equity shares. "NBFCs will find out new avenues to deploy their funds but it is more of a challenge for realty firms," Venkateshwaran says. However, Sobha's Sharma says this clause will improve debt- equity ratios of realty companies. " It will lead to a higher equity base and improve our ability to raise more money through debt," he adds. More importantly, the Companies Act also says that a company will be considered a "listed company" if any of its securities is listed on stock exchanges, against the earlier practice of treating one as a listed company if its equity shares are listed. " Even if your debentures are listed, clauses relating to a listed company will kick in and you have to live as a listed company, despite you being privately owned," says Venkateshwaran. ASK's Rohokale says the Act aims to bring in a new level of governance. "Earlier, many unlisted companies did things in a hush- hush way. Now, everybody has to fall in line and be ready to be governed." >FROM PAGE 1 |
| Related- party deals tie firms in knots |
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The market watchdog, Securities and Exchange Board of India (Sebi) seems to have put the cat among the pigeons when it refreshed its corporate governance code for listed companies, in line with provisions of the new Companies Act. In certain aspects some of Sebi's requirements are more onerous than the Companies Act. This includes those relating to tenure of independent directors and number of directorship, constitution of audit committee, and the scope of related party transactions. However, it is the last one — related party transactions — that has caught the corporate sector in a bind. According to provisions in the Companies Act 2013, shareholders' approval is required for those relatedparty transactions where the board recommends so in case of transactions that are not in ordinary course of business or at arm's length. However, Sebi's definition of related party transaction is much wider. The market regulator mandates all listed companies to lay down a policy for material related party transactions and manner of dealing with such related parties. Shareholders' approval is required for all material related party transactions. Additionally, the definition of related party also includes close family members of directors, private companies in which directors or key managerial personnel along their relatives have control, joint control or significant influence as related parties. This has queered the pitch for most companies, especially those that regularly transact business among subsidiary companies. " The Sebi norms widen an already broad definition of related party transactions. This would result in increased cost of compliance," says Jamil Khatri, global head, accounting advisory services, KPMG. Corporate law experts point out that the new corporate governance norms increases the say of minority shareholders while voting for such transactions, as interested parties have to abstain from such voting. Ankit Miglani, deputy managing director, Uttam Galva Steels points out that approval from minority shareholders for related party transactions will have an impact on business decisionmaking. " It will slow us down," he says. The concern now is that for businesses operating through multiple entity structure and that need to enter into frequent material transactions with each other, the control of the entities effectively may transfer from majority to minority, says Yogesh Sharma, partner, Grant Thornton India LLP, an assurance, tax and advisory firm. Many believe that this may defeat the objective behind the stringent conditions that guide RPT approvals which is to give protection to the interests of minority shareholders. " Some companies especially with low minority interests may prefer to weed out minority shareholders altogether and take 100- per cent control of their subsidiaries," says Sharma. Legal experts point out there is no requirement in the United States for shareholder approval of RPTs as in India. However, market regulators remain wary of RPTs as there are several instances of high- profile accounting frauds in recent years ( that includes Enron in the United States and Satyam Computers in India) that have involved related party transactions in one way or the other. NVenkatram, managing partner —audit, Deloitte Haskins & Sells LLP, points out that the effectiveness of such legislation is dependent to a large degree on the quality of enforcement. " The monitoring and inspection capabilities of both MCA and Sebi would need to be substantially strengthened in order to ensure that the legislation is complied with," says Venkatram. Shriram Subramanian, founder and managing director, InGovern Research Services, an independent proxy advisory firm, agrees that though the listing agreement is more stringent than the Companies Act 2013, it is a much needed. India does not meet the global best practices in many of the provisions of the corporate governance code, he says. "The separation of the role of chairman and MD is still a nonmandatory one. Also, once an independent director completes two terms of five years each, they should not be eligible to again join the board after the cooling off period of three years. All members of the audit committee should be independent directors," he says. Proxy advisory firms point out tht Indian stock exchanges need better tools for monitoring and surveillance of non- transaction related data and announcements by companies. "The cost of non- compliance should be higher," adds Subramanian. The fines imposed should enhance Sebi's coffers and this money should be used to it increase its manpower and other capabilities. Rana Som, former CMD of NMDC, and currently a director in several companies, feels that Sebi guidelines will go a long way in promoting corporate governance norms in India. " It's a balanced approach," he says. For now India Inc, seems to have its hands full while dealing with RPTs. Market regulators remain wary of RPTs as there are several instances of high- profile accounting frauds in recent years Sebi norms [1]Maximum numberof boards a person can serve as independent director ( ID) restricted to seven and three in case the person is serving as awhole- time director in any listed company [1]Maximum tenure of an ID capped at 10 years. However, if a person has already served as an ID for5 years or more on 1 October 2014, ID will be eligible for appointment for a term of 5 years only [1]Two- thirds of the members of audit committee shall be independent directors. The chairman of the audit committee to be an independent director [1]Approval of all material RPTs by shareholders through special resolution with related parties abstaining from voting [1]Related parties includes additional relationships such as person thathas a joint control or significant influence on the company, and fellow joint ventures and associates [1]Boards of companies to satisfy themselves that plans are in place for orderly succession for appointments to the Board and senior management Companies Act 2013 [1]Maximum numberof directorships is capped at twenty, of which not more than ten can be public companies. However, no specific limit is prescribed for IDs [1]The overall term of an ID is 10 years, except that under the 2013 Act, these requirements are applied prospectively [1]Audit committee to be formed with majority being independent directors. No specific requirement for chairman to be independent director [1]The Act requires preapproval of related party transactions which are not in the ordinary course of business or are not at arm's length by a special resolution. Related parties have to abstain from voting [1]Related party covers those relationships which are defined in section 2( 76) [1]No specific requirement Impact [1]The problem of sourcing the right ID on boards will be accentuated for listed companies given the limits [1]ID's of listed companies will need to discontinue their board positions earlier than whatwas contemplated under the Companies Act [1]The Sebi norms seek to provide for greater independence for the audit committee [1]This may result in practical difficulties particularly for transactions with subsidiaries [1]The Sebi norms require abroader set of parties to be identified as related parties [1]Companies have to put succession planning firmly on their agenda CORPORATE GOVERNANCE SEBI SCORES OVER COMPANY LAW Compiled by KPMG India Sebi's corporate governance code and the new company law regime have some clauses that have many Indian companies in a bind |
| FAQs: Related Party Transactions - Expert Take |
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Are requirements of the Companies Act, accounting standard and Sebi norms with respect to related party aligned? No, these requirements are not aligned. Companies Act 2013 requires disclosure at the time of entering into contract or arrangement whereas accounting standard requires disclosure at the time of entering into a transaction Clause 49 adds new class of related parties to the definition thereof given under the Act and includes close family members, fellow group entities, joint ventures of same third party and combinations thereof, which are not in accounting standard or the Companies Act. Revised clause 49 requires shareholders' approval for all material related party transaction with no exception for transactions in ordinary course of business or at armslength. Definition of material transactions differs. In case of deviation, as a thumb rule, provision of the stricter of the applicable regulations shall be followed. A corporate group has several foreign subsidiaries. Will provisions in relation to related parties apply to foreign companies as well? The term ' company', as defined under the Companies Act 2013, is a company incorporated under this Act or any previous company law. Company incorporated under the relevant legislation of a foreign country is not a ' company' under Companies Act 2013. However, transactions by Indian company with a foreign company, which is a subsidiary, associate, fellow subsidiary, joint venture of the same venturer or company under control of same promoter, would be covered, based on understanding of combined reading of revised clause 49 and Companies Act 2013. In case of Companies Act, is the board required to approve all related party transactions? The Companies Act 2013 prescribes that a company needs approval of the audit committee on all related party transactions and subsequent modifications thereto. This is irrespective of whether they are in the ordinary course of business and consummated at arms length price or they are below prescribed thresholds. Further, for listed companies, clause 49 prescribes audit committee approval for all related party transactions and shareholders approval of all material RPTs. For normal transactions, if company has a well laid down policy framework which explicitly lays down terms of contract/ transaction and which are approved by audit committee then a separate approval will be unwarranted for each such transaction. However, any modification/ transaction, which was not contemplated in the framework and approved by the audit committee in its initial approval, would require fresh approval of the audit committee. Legal evaluation or a clarification from lawmakers would be necessary considering the difficulties such an approval might impose. What assessment is required of the existing RPTs, if any? All companies are required to comply with requirements in relation with RPTs, prospectively from the date of applicability of underlying regulation. Any default will be regarded as non- compliance and may attract penal provisions under the Companies Act 2013. The following actions are recommended to avoid any risk of default: [1]Companies should carefully review its related parties under the regulations and identify all existing and new related parties together with all existing and new contracts, arrangements and transactions, etc. Amongst other matters, the manner of dealings shall cover aspects relating to the determination of key terms including arm's length price. [1]An immediate dialogue needs to be initiated with the audit committee to assess and confirm their expectations from the policy and review/ approval protocols. A careful evaluation of existing and proposed RPTs is not unwarranted. [1]Companies shall develop process and methodology and make necessary changes in systems and procedures adapting to the new set of regulations. (The author is Partner in the member firm of Ernst & Young Global ) For the full version visit www. business- standard. com |
| BRIEF CASEN M J ANTONY |
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The Supreme Court has stated that procedural defects and irregularities, which can be cured, should not stand in the way of justice, in a case of cheque bouncing. In this case, Haryana State Coop Supply and Marketing vs Jayam Textiles, the federation supplied cotton bales to the company. The four cheques in payment for the purchase bounced for want of sufficient funds. The federation filed a complaint under the Negotiable Instruments Act. The magistrate dismissed it on the ground that the federation had not produced the authorisation of its board of directors to the official who filed the complaint. The federation appealed to the Madras High Court, but it dismissed the appeal again on the ground that the person who filed the complaint had no proper power of attorney. On appeal, the Supreme Court held that the courts below were wrong for insisting on technicalities. It remitted the case to the trial court where the federation can show the authorisation which it had failed to do earlier. Commenting on the technicalities relied upon by the courts below, the Supreme Court stated that " procedure, a hand maiden of law, should never be made a tool to deny justice or perpetuate injustice, by any oppressive or punitive use." >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> DRT to hear ex- management The Supreme Court has directed the Debt Recovery Tribunal to hear the exmanagement of a company apart from its official liquidator before passing its final order in a Securitisation Act (Sarfaesi) case. In this case, Bharat Steel Tubes Ltd vs Official Liquidator, the company was ordered to be wound up by the Delhi High Court pursuant to the recommendations of the Board for Industrial and Financial Reconstruction ( BIFR). The company moved the Supreme Court against it and the court ordered status quo regarding its assets. The creditor bank meanwhile invoked the Securitisation Act seeking to sell the assets of the company. This led to complex litigation. One important question was whether the exmanagement should be heard by the tribunal. The tribunal held that in view of the winding up order, only the official liquidator was entitled to represent the company and the former management could not be heard. The Supreme Court ordered otherwise, observing that in the facts of the case, preventing the ex- management from placing appropriate material before the tribunal regarding the claim of the creditor bank " may eventually lead to denial of an opportunity to the ex- management to place such facts as they deem appropriate to resist the claim of the bank." >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Cash collection at sweet shop The Supreme Court has dismissed the appeal of M/ s Nathu Ram, sweetmeat sellers, against the Delhi High Court judgment that confirmed the assessment of sales tax and penalty imposed on the firm by revenue authorities. On two random visits to the business premises in Delhi and examination of books of accounts of relevant years, the assessing officer had found substantial discrepancies between the cash inflow and the book of accounts. Taking the average of the two days, the department multiplied it for the whole year to arrive at an estimate. Then 10 per cent was added towards normal growth of business. The firm argued that sale proceeds vary on each day and the sample of two days could not be taken as standard and normal for calculating the tax for the whole year. Moreover, it was not given an opportunity to explain the discrepancies as it received no notice before taking action by the revenue authorities. The Supreme Court rejected all these contentions and stated that the assessing officer had rightly concluded that the total possible sale was much higher than claimed by the firm. " Once it is found that with some oblique motive, effort was made to show lesser sale proceeds than the actual, the orders imposing penalty cannot be questioned," the judgment said. >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Sanction to try in corruption case In a case under the Prevention of Corruption Act, criminal proceedings cannot be stopped mid- course on the ground that the sanction of higher authority was not proper, the Supreme Court stated last week in the case, state of Bihar vs Rajmangal Ram. The Patna High Court had held that in the two cases under the Act, it was the law department of the state and not by the parent department to which the accused persons belonged which granted sanction to prosecute. The accused challenged only the validity of the sanction. The high court allowed it. Reversing the judgment and allowing the proceedings to go on, the Supreme Court stated that " any error, omission or irregularity in the grant of sanction will not affect any finding, sentence or order passed by a competent court unless in the opinion of the court a failure of justice has been occasioned." >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Fishing vessel can't cross state borders A fishing vessel registered in Andhra Pradesh, which sank in Odisha coastal waters, was not entitled to compensation from the insurers as the policy covered only losses suffered in the Andhra coastal waters. The Supreme Court thus dismissed the appeal of the vessel owner, Kokkilagadda Subba Rao against United India Assurance Co, which had repudiated the claim. The company appointed one surveyor who found the boat sank in the Andhra coast. It appointed another who reported that it sank off Odisha coast. The owner claimed compensation in the consumer commission which accepted the insurance company's argument that the boat violated the policy terms by going to the Odisha waters. The Supreme Court upheld that view. >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Insurer to pay forworker's death When the ownership of a motor vehicle is transferred during the validity of the insurance, the new owner would be covered by the policy, the Supreme Court has held in the judgment, Mallamma vs National Insurance Company. It set aside the judgment of the Karnataka High Court exonerating the insurance company from the liability to pay compensation to the legal representatives of a driver who died in an accident in the course of employment with the new owner of the vehicle. The insurance company argued that it was not aware of the transfer of ownership and therefore it was not liable to pay. The Supreme Court rejected the defence pointing out that the Commissioner of Workmen's Compensation had found that on the basis of documents, the stand was false. The court upheld the compensation of ₹ 3.67 lakh to be paid by the insurance company. A weekly selection of key court orders |
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Source Business line
Market regulator raises the bar on corporate governance K. R. SRIVATS
NEW DELHI, APRIL 20: Market regulator SEBI has gone in for more stringent requirements in certain areas of corporate governance under the latest amendment to the listing agreement as opposed to those required by the new company law. This has been done to raise the bar on corporate governance in the country, sources in Securities and Exchange Board of India (SEBI) said. However, the differences between the latest amendment to the listing agreement and the new company law in areas such as approval of related party transactions and limits for independent directors would be burdensome and pose practical difficulties for Corporate India, say corporate observers. Given that the new company law had only recently been enacted, one could argue on the merits of more stringent requirements, they said. SEBI feels the increased requirements in certain areas like related party transactions and independent directors have been mandated to improve the level of governance in listed entities and were not in any manner overriding the requirements of the new company law. "Our latest prescriptions in corporate governance do not certainly override the company law. We have made additional requirements only in areas where the company law is silent", SEBI sources said. SIGNIFICANT DIFFERENCES As per SEBI, all 'material' related party transactions need to be approved by non-related party shareholders. Material means greater than 5 per cent of turnover or 20 per cent of net worth. However, as per the new company law, related party transaction require such shareholder approval only if not at 'arms-length' or not in the 'ordinary course of business' SEBI permits an independent director to be such a director on a maximum of 7 companies. This further reduces to 3 if the independent director is a whole time director in any other company. The new company law permits a person to be on the Board of 10 public companies SEBI prescribes that for the purposes of determining the maximum term that an independent director can be on the Board (10 years), if the independent director has already completed 5 years, that period should be considered (partly retrospective). However, the new company law permits only a prospective application. "Requiring approval from non-related party shareholders even for related party transactions that are at arms-length and in the ordinary course of business would be burdensome and pose practical difficulties. This is particularly excessive for transactions with the company's own subsidiaries", Jamil Khatri, Global Head of Accounting Advisory Services, KPMG in India, told BusinessLine. "Given that the Companies Act has been recently enacted, differences between the amendment and the Companies Act requirements in areas such as approval of related party transactions and limits for independent directors should have been avoided" S.N. Ananthasubramanian, a practicing company secretary, said it remains to be seen whether evaluation of independent directors will prove as effective a measure as it would have been if they were to retire by rotation instead of a fixed tenure. (This article was published on April 20, 2014) |
| Corporate deposits become less risky RAJALAKSHMI NIRMAL |
With new net worth norms and mandatory credit rating, look forward to more safety with corporate fixed deposits
Burnt your fingers investing in a corporate fixed deposit which saw a default? The new Companies Act, which has been notified recently, is remedying this.
To this end, companies other than banks and non-banking finance companies (NBFC) have to meet a set of conditions before they can collect deposits from the public.
Companies that have already taken deposits, but who don't meet the criteria, should repay these within a year. So what are these new provisions? How do they help keep your money safe?
Minimum requirements
The first criterion is that only those companies with net worth (excluding share premium) of ₹100 crore or more and turnover above ₹500 crore can raise deposits from public. This weeds out companies that don't have the financial stability to accept deposits, as well as smaller companies that aren't really serious about meeting requirements.
The second, and most welcome, provision is that companies looking to raise public deposits need to get themselves compulsorily rated. Says Sai Venkateshwaran, Partner and Head - Accounting Advisory Services, KPMG, "The company is required to obtain rating on liquidity and ability to pay deposits on due date from a recognised credit rating agency. It is also required that this rating should be obtained for every year during the tenure of deposits."
Such a rating denotes how risky a particular deposit is. Currently, it is not mandatory for companies other than NBFCs to get their fixed deposits rated. So investors tend to overlook risks and fall for the lure of high interest rates. For instance, Ind-Swift Laboratories had offered an interest rate of 12.5 per cent on a three-year fixed deposit and 10.5 per cent on a one-year deposit.
In September last year, the company defaulted. Over 3,000 investors got together and filed a case against the company.
The trouble with corporate fixed deposits is that they are usually unsecured – that is, they don't have the backing of an asset. So when companies default, investors can't ask for liquidation of company assets.
With the new Act, a company which is raising unsecured deposits has to explicitly state it in the offer document and all advertisements inviting deposits, says Harish K Vaid, Senior President Corporate Affairs and Company Secretary, JP Associates. Also, deposit insurance of up to ₹20,000 per deposit is mandatory. Vaid adds, "Every company needs to keep an amount equal to the FDs maturing in two years in a separate bank account, as against the earlier provision, which permitted deposit in liquid assets like FDs with banks."
Refund requirement
All companies that have collected deposits from the public and which do not satisfy the specified conditions are required to refund the deposits in one year's time, or upon maturity, whichever is earlier.
The new Companies Act has specified penal provisions for companies that fail to comply with this rule, says Venkateshwaran. "For default in complying for repayment of the unpaid deposits or interest, the company is punishable with a fine which shall not be less than ₹1 crore. Every officer of the company who is in default shall be punishable with imprisonment, which may extend to seven years."
All the refund money that may come now is likely to go into NBFC deposits, says Chopra. "People have already started looking for deposits of non-banking finance companies. NBFCs' collection has already started going up," he says.
With the new Companies Act, corporate deposit issues are likely to fall, say industry experts. NBFCs are a more secure option. These give interest rates of 8.5 per cent to 10.5 per cent and come with an AAA or AA+ rating.
According to Anil Chopra, CEO of Bajaj Capital, a distributor of financial products, the company has been informed by several players − including Jaiprakash Associates, JP Infratech, Surya Roshini, Ansal Housing and Unitech − that they have stopped accepting fresh deposits.
(This article was published on April 20, 2014)
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