130 | Just Group PLC | Annual Report and Accounts 2023
INDEPENDENT AUDITORS’ REPORT continued to the members of Just Group plc
Key audit matter
How our audit addressed the key audit matter
Valuation of investments classified as Level 3 under IFRS 13, including Lifetime Mortgages (“LTMs”) (Group) Refer to Group Audit Committee Report, Accounting policy 1.6 IFRS 9 Financial Instruments and note 20 Fair value of financial assets and liabilities. The valuation of investments classified as Level 3 is typically based on either inputs into a valuation model or observable prices for proxy positions. This is inherently complex and requires the use of significant management judgement. Furthermore, the balances are material to the financial statements. The most significant Level 3 asset class is LTMs. The setting of voluntary redemptions (persistency), as well as key economic assumptions, applied in the valuation of LTMs (including current property values, house price inflation and volatility) are impacted by the uncertainty in the current economic environment. Other Level 3 assets material to the financial statements comprise investments in commercial mortgages, long income real estate (which includes residential ground rents) and other illiquid debt instruments. Specifically on residential ground rents, the valuation could be impacted by the UK government’s Leasehold and Freehold Reform Bill and the associated consultation on potential restrictions to the level of residential ground rents, issued on 9 November 2023.
We performed the following audit procedures to test the valuation of the investments classified as Level 3 (excluding Lifetime mortgages): • Tested the design and, where applicable the operating effectiveness of controls related to the valuation of investments; and • Obtained independent confirmations from third party asset managers (where relevant) for comparison to management’s internal valuations. For a sample of other illiquid assets, we performed the following procedures: • Engaged our valuation experts to assess the reasonableness and appropriateness of the internal valuation methodology applied; • Performed an independent revaluation and investigated any variances outside of our tolerable threshold; and • Tested inputs into the valuation to external sources, where possible. In response to the recent Leasehold and Freehold Reform Bill and the associated consultation on potential restrictions to the level of residential ground rents, we have: • Assessed the appropriateness of the judgements made in determining the impact of the consultation on the valuation of the loans secured on residential ground rent assets; • Ensured that sufficient consideration was given to a range of likely outcomes of the consultation and subsequent changes in legislation; • Challenged management on the stresses and changes in credit ratings applied; and • Assessed and reviewed the associated disclosures given the inherent uncertainty resulting from the consultation. We performed the following audit procedures to test the valuation of Lifetime Mortgages: • Tested the design and, where applicable, operating effectiveness of the controls in place over the determination of the valuation of LTMs, including those relating to model inputs, model operation and extraction and consolidation of results from the valuation models; • Tested the design and, where applicable, the operating effectiveness of controls related to the data used in the modelling of Lifetime Mortgages; • For a sample of mortgages, agreed data used in the modelling of LTMs to policyholder documentation; • Assessed the appropriateness of the methodology, models and assumptions used against recognised actuarial practices, including any changes made during the year, taking into account the impact of current economic conditions; • Performed testing over the actuarial model calculations. We placed reliance on our model baselining carried out as part of the 2020 audit, whereby we independently replicated the asset cash flows for a sample of loans in order to validate that the model calculations were operating as intended. In 2023, we performed additional procedures over changes in the model, baselined an additional sample of loans and tested the analysis of change in modelled results, to assess whether the model continues to operate as expected; • Evaluated the appropriateness of significant economic assumptions, including the property price inflation assumption and property price volatility assumptions used within the valuation process, with reference to market data and industry benchmarks where available, and taking into account the impact of current economic conditions; • Assessed the appropriateness of current property prices derived using Automated Valuation Model; • Tested the key judgements involved in the preparation of the manually calculated components of the asset balance, and the accuracy of the calculations; and • Evaluated the Group’s historic data used to prepare the Group’s mortality, morbidity and voluntary redemptions experience analysis, taking into account the impact of current economic conditions for voluntary redemptions together with industry data on expectations of future mortality improvements and assess whether this supports the assumptions adopted. Based on the work performed and the evidence obtained, we consider the valuation of Level 3 assets to be appropriate.
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