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Credit Risk Monitoring:Concepts, Objectives and Guidelines
Introduction
Credit/Loan constitutes the major revenue earning asset of a bank
Banks lend mostly depositors’ money
Credit/ Loanable Funds having cost implications and repayment obligations to the depositors have to be managed efficiently with minimum possible credit (default) risk.
Moreover, credit culture is undergoing rapid change due to
- Globalisation - Disintermediation- Liberalisation - Competition- Consolidation
Incidence of Credit Risk may be higher unless adequately cared and monitored.
Credit Risk
Credit Risk is the possibility that a borrower or counterparty will fail to meet obligations.
Credit risk arises from the bank’s dealings with or lending to the corporates, individual and other banks or financial institutions.
To minimise losses, banks should have comprehensive credit risk management policies
and procedures
Credit Risk Management
To select Good Credit Risk
CRM – Steps
- Risk Identification
- Risk Assessment
- Risk Grading
- Risk Pricing
- Risk Monitoring
Risk Identification
Risk Factors internal to Banks and Financial Institutions. Risk Factors on Account of Borrowing Parties
Internal Risk Factors - Risk in Planning- Risk in Execution/Implementation- Marketing Risks- Financial Risks- Managerial Risks
External Risk Factors- Input/Utility Availability- Govt. Policies - Natural Calamities - Technological Obsolescence - Political Situations
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Preferred Organisational Structure & Responsibilities
Preferred Organisational Structure
Credit Administration(May report separately
to MD/CEO)
Credit Approval(includes regional credit
centres if applicable)
Monitoring / Recovery( includes regional recovery
centres if applicable)
Head of Credit Risk Management(CRM)
Relationship Management /Marketing (RM)
Business Development
Head of Corporate /Commercial Banking
Other Direct Reports(Internal Audit, etc.)
Managing Director / CEO
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Procedural Guidelines
Approval Process Credit ApplicationRecommended By RM / Marketing
Zonal Credit Officer (ZCO)
Head of Credit (HOC) & Head of Corporate Banking (HOCB)
Managing Director
Executive Committee/Board
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Credit Administration- Disbursement- Custodial Duties- Compliance Requirements
Credit Monitoring To minimise credit losses, monitoring procedures and systems should be in place that provide an early indication of the deteriorating financial health of a borrower. At a minimum, systems should be in place to report the following exceptions to relevant executives in CRM and RM team:
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Past due principal or interest payments, past due trade bills, account excesses, and breach of loan
covenants;
Loan terms and conditions are monitored, financial statements are received on a regular basis, and any covenant breaches or exceptions are referred to CRM and the RM team for timely follow-up.
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Timely corrective action is taken to address findings of any internal, external or regulator inspection/audit.
All borrower relationships/loan facilities are reviewed and approved through the submission of a Credit Application at least annually.
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Early Alert Process
An Early Alert Account is one that has risks or potential weaknesses of a material nature requiring monitoring, supervision, or close attention by management.
Short Name and Number Eightused in CRG Categories
GRADING SHORT NAME
NUMBER
Superior SUP 1
Good GD 2
Acceptable ACCPT 3
Marginal/Watchlist MG/WL 4
Special Mention SM 5
Sub Standard SS 6
Doubtful DF 7
Bad & Loss BL 8
Sup-1: Fully Cash covered, Govt./ Int. Bank Guarantee
GD-2: Strong Repayment Capacity
Accpt-3: Consistent Earnings, Cash Flow and Good Track Record
MG/WL-4: Greater attention required – Above Average Risk.
SM-5: Potential Weaknesses – Close attention required.
SS-6: Weak Fin. Condition
DF-7: Repayment Unlikely
BL-8: No progress in repayment/ on the verge of wind-up
Ref: Reg. Def. on Grading of CL. AccountsA. Objective CriteriaB. Qualitative Judgement
How to Compute CRG
Step-I: Identify all the Principal Risk Components
Financial Risk: Probability of failure to meet obligation due to fin. distress
- High Leverage- Poor Liquidity- Low Profitability- Insufficient Cash Flow
Business/ Industry Risk: Adverse Ind. situation/ unfav. business condition to impact repayment
Management Risk: Probability of Default due to poor managerial ability
Security Risk: Probability of Default due to poor quality of security
Relationship Risk: Risk areas in terms of Borrower/ Dep. relationship
Step-II: Distribution of Weightage to Risk Components
Risk Components Weight* FR --- 50%* B/IR --- 18%* MR --- 12%* SR --- 10%* RR --- 10%
Step-III: Credit Risk Components and Key Parameters
CREDIT RISK
Financial Risk Management
Risk Business/
Industry RiskRelationship
RiskSecurity Risk
Leverage
Liquidity
Profitability
Coverage
Experience
Succession
Team Work
Business Outlook
Size of Business
Industry Growth
Market Competition
Barriers to Business
Account Conduct
Utilization of Limit
Compliance of Covenants/ Condition
Personal Deposits
Security Coverage
Collateral Coverage
Support
Age of Business
Step-IV: Assigning Weight to Key Parameters
FR 50%*Lev. 15%*Liq. 15%*Prof. 15%*Cov. 5%
B/IR 18%*SB 5%*AB 3%*BO 3%*IG 3%*MC 2%*EB 2%
Step-IV: Assigning Weight to Key Parameters
MR 12%*Exp. 5%*Succ. 4%*TW. 3%
SR 10%*Sec. Cov. 5%*Coll. Cov. 3%*Support 2%
RR 10%*AC 5%*UL 2%*CC 2%*PD 1%
Step-V: Input Data to arrive at Score
Manually MS Excel based – steps followed
Step-VI: Arrive at CRG based on total Score
Number RG/Short Name Score
1 SUP 100% (cash covered Govt./ Int. Bank Guarantee
2 GD 85+
3 ACCPT 75-84
4 MG/WL 65-74
5 SM 55-64
6 SS 45-54
7 DF 35-44
8 BL <35
CRG Process
Applicable for all exposures (other than consumerand SE and short term Agri and Micro-Credit Not Applicable for SUP. Grade Applicable for New or Renewal Cases
* RM to collect Inf. as per Data Collection Checklist (App-A)- Documents/Items required for CRG
• Required – Obtained- Pending Item Checklist
RM to fill up Limit Utilisation form (App-B) For assessing realistic earning status
Risk Factors to be evaluated and weighted on the basis of - Up to date & reliable data- Complete objectivity
[CRG Score Sheet App-C]* Criteria* Weight* Parameter* Score* Actual Parameter* Score Obtained* RISK GRADE
CRG to be originated by RM & then an ongoing process- CRG Form (App-D) to follow for Risk Grading in case of existing concerns.
All Credit proposals (New/Renewal) to accompany Data Collection Checklist (DCC) Limit Utilisation Form (LUF) CRG Score Sheet CRG Form
Credit officer to pass on the approved CRG Form to Credit Admn. Dept. and Corp. Banking Unit for MIS
record.
Subsequent Revision of CRG by appropriate approving authority.
Early Warning Signals (EWS)
EWS indicate-- risks or potential weakness of an exposure- demanding close attention by management
In the absence of EWS,- likely of repayment prospects- probability of downgrading to classified assets
Hence, Early Identification, Prompt Reporting of credit signs and Proactive Management of Early Alert
Accounts (EAA)
Credit Risk Grading Form (App. D) as Additional Caution
Irrespective of Credit Score, Identified EAAs to have the following symptoms:
* MG/WL – 4: Loan overdue – 60 days & above Frequent security value or shortfall in DP
* SM – 5: Loan overdue – 90 days & above Major doc. deficiency exit Claim lodged against borrower
Exceptions to Credit Risk Grading
Downgrading/ Classifying an account by Head, CRM during inspection/ portfolio review
Upgrading to be justified by Recommending Officer - Upon complete removal of the reasons for Downgrade.
Marginal/ Special Mention/ Unacceptable, Cr. Risk may be accepted if addl. collateral exists.
- Exceptionally approved
Indep. Assessment of CRG of an Account may be done by Head/ CRM or Internal Auditor
Bank may exercise option to continue with own CRG if equivalent or stricter.
Credit Risk Grading Review
CRG to be periodically updated after lending
Review Frequencies
RG RF (at least)SUP Annually
GD -Do-
ACCPT -Do-
MG/WL HY
SM Q
SS Q
DF Q
BL Q
CRM:Policy Guidelines
Organizational Structure and Procedures
INTRODUCTION:
Credit risk is an essential factor that needs to be managed. Credit risk is the possibility that a borrower or counter party will fail to meet its obligations in accordance with agreed terms. Credit risk, therefore, arises from the bank’s dealings with or lending to corporates, individuals, and other banks or financial institutions. Credit risk management needs to be a robust process that enables banks to proactively manage loan portfolios in order to minimize losses and earn an acceptable level of return for shareholders.
Credit Policy Guidelines
1. Lending Guidelines
2. Credit Assessment & Risk Grading
3. Approval Authority
4. Segregation of Duties
5. Internal Audit
Preferred Organizational Structure & Responsibilities
Procedural Guidelines
Approval Process
Credit Administration
Credit Monitoring
Credit Recovery
Policy Guidelines
The guidelines contained herein outline general principles that are designed to govern the implementation of more detailed lending procedures and risk grading systems within individual banks.
Lending GuidelinesAll banks should have established Credit Policies (“Lending Guidelines”) that clearly outline the senior management’s view of business development priorities and the terms and conditions that should be adhered to in order for loans to be approved. The Lending Guidelines should be updated at least annually to reflect changes in the economic outlook and the evolution of the bank’s loan portfolio, and be distributed to all lending/marketing officers. The Lending Guidelines should be approved by the Managing Director/CEO & Board of Directors of the bank based on the endorsement of the bank’s Head of Credit Risk Management and the Head of Corporate/Commercial Banking.
Industry and Business Segment Focus
The Lending Guidelines should clearly identify the business/industry sectors that should constitute the majority of the bank’s loan portfolio. For each sector, a clear indication of the bank’s appetite for growth should be indicated (as an example, Textiles: Grow, Cement: Maintain, Construction: Shrink). This will provide necessary direction to the bank’s marketing staff.
Types of Loan FacilitiesThe type of loans that are permitted should be clearly indicated, such as Working Capital, Trade Finance, Term Loan, etc.
Single Borrower /Group Limits/SyndicationDetails of the bank’s Single Borrower/Group limits should be included as per Bangladesh Bank guidelines. Banks may wish to establish more conservative criteria in this regard.
Industry and Business Segment Focus
The Lending Guidelines should clearly identify the business/industry sectors that should constitute the majority of the bank’s loan portfolio. For each sector, a clear indication of the bank’s appetite for growth should be indicated (as an example, Textiles: Grow, Cement: Maintain, Construction: Shrink). This will provide necessary direction to the bank’s marketing staff.
Lending CapsBanks should establish a specific industry sector exposure cap to avoid over concentration in any
one industry sector.
Discouraged Business TypesBanks should outline industries or lending activities that are discouraged. As a minimum, the following should be discouraged:
Military Equipment/Weapons Finance
Highly Leveraged Transactions
Finance of Speculative Investments
Logging, Mineral Extraction/Mining, or other activity that is Ethically or Environmentally Sensitive
Lending to companies listed on CIB black list or known defaulters
Counter parties in countries subject to UN sanctions
Share Lending
Taking an Equity Stake in Borrowers
Lending to Holding Companies
Bridge Loans relying on equity/debt issuance as a source of repayment.
Facility Parameters
Facility parameters (e.g., maximum size, maximum tenor, and covenant and security requirements) should be clearly stated. As a minimum, the following parameters should be adopted:
Banks should not grant facilities where the bank’s security
position is inferior to that of any other financial institution.
Assets pledged as security should be properly insured.
Valuations of property taken as security should be performed prior to loans being granted. A recognized 3rd party professional valuation firm should be appointed to conduct valuations.
Cross Border Risk
Risk associated with cross border lending. Borrowers of a particular country may be unable or unwilling to fulfill principle and/or interest obligations. Distinguished from ordinary credit risk because the difficulty arises from a political event, such as suspension of external payment
• Synonymous with political & sovereign risk
• Third world debt crisis For example, export documents negotiated for countries like Nigeria.
Credit Assessment & Risk Grading Credit AssessmentA thorough credit and risk assessment should be conducted prior to the granting of loans, and at least annually thereafter for all facilities. The results of this assessment should be presented in a Credit Application that originates from the relationship manager/account officer (“RM”), and is approved by Credit Risk Management (CRM). The RM should be the owner of the customer relationship, and must be held responsible to ensure the accuracy of the entire credit application submitted for approval. RMs must be familiar with the bank’s Lending Guidelines and should conduct due diligence on new borrowers, principals, and guarantors.
It is essential that RMs know their customers and conduct due diligence on new borrowers, principals, and guarantors to ensure such parties are in fact who they represent themselves to be. All banks should have established Know Your Customer (KYC) and Money Laundering guidelines which should be adhered to at all times. Credit Applications should summaries the results of the RMs risk assessment and include, as a minimum, the following details: - Amount and type of loan(s) proposed.- Purpose of loans.- Loan Structure (Tenor, Covenants, Repayment Schedule, Interest)- Security Arrangements
In addition, the following risk areas should be addressed: - Borrower Analysis - Industry Analysis - Supplier/Buyer Analysis - Historical Financial Analysis. - Projected Financial Performance. - Account Conduct. - Adherence to Lending Guidelines. - Mitigating Factors. - Loan Structure. - Security. - Name Lending.
Risk Grading: New Manual, CRGM has been introduced. Approval Authority The authority to sanction/approve loans must be clearly delegated to senior credit executives by the Managing Director/CEO & Board based on the executive’s knowledge and experience. Approval authority should be delegated to individual executives and not to committees to ensure accountability in the approval process. The following guidelines should apply in the approval/sanctioning of loans:
Credit approval authority must be delegated in writing from the MD/CEO & Board (as appropriate), acknowledged by recipients, and records of all delegation retained in CRM. Delegated approval authorities must be reviewed annually by MD/CEO/Board. The credit approval function should be separate from the marketing/relationship management (RM) function. The role of Credit Committee may be restricted to only
review of proposals i.e. recommendations or review of bank’s loan portfolios.
Approvals must be evidenced in writing, or by electronic signature. Approval records must be kept on file with the Credit Applications.
All credit risks must be authorized by executives within the authority limit delegated to them by the MD/CEO. The “pooling” or combining of authority limits should not be permitted.
Credit approval should be centralised within the CRM function. Regional credit centres may be established, however, all large loans must be approved by the Head of Credit and Risk Management or Managing Director/CEO/Board or delegated Head Office credit executive.
The aggregate exposure to any borrower or borrowing group must be used to determine the approval authority required.
Any credit proposal that does not comply with Lending Guidelines, regardless of amount, should be referred to Head Office for Approval
MD/Head of Credit Risk Management must approve and monitor any cross-border exposure risk.
Any breaches of lending authority should be reported to MD/CEO, Head of Internal Control, and Head of CRM.
It is essential that executives charged with approving loans have relevant training and experience to carry out their responsibilities effectively. As a minimum, approving executives should have:
- At least 5 years experience working in corporate/commercial banking as a relationship manager or account executive.
- Training and experience in financial statement, cash flow and risk analysis.
- A thorough working knowledge of Accounting.
- A good understanding of the local industry/market dynamics.
Successfully completed an assessment test demonstrating adequate knowledge of the following areas: Introduction of accrual accounting. Industry / Business Risk Analysis Borrowing Causes Financial reporting and full disclosure Financial Statement Analysis The Asset Conversion/Trade Cycle Cash Flow Analysis Projections Loan Structure and Documentation Loan Management.
Segregation of Duties
Banks should aim to segregate the following lending functions: - Credit Approval/Risk Management- Relationship Management/Marketing- Credit Administration
Banks should have a segregated internal audit/control department charged with conducting audits of all departments. Audits should be carried out annually, and should ensure compliance with regulatory guidelines, internal procedures, Lending Guidelines and Bangladesh Bank requirements.
Internal Audit
PREFERRED ORGANISATIONAL STRUCTURE & RESPONSIBILITIES
The appropriate organisational structure must be in place to support the adoption of the policies detailed in Section 1 of these guidelines. The key feature is the segregation of the Marketing/Relationship Management function from Approval/Risk Management/Administration functions.
Credit approval should be centralised within the CRM function. Regional credit centers may be established, however, all applications must be approved by the Head of Credit and Risk Management or Managing Director/CEO/Board or delegated Head Office credit executive.
Preferred Organisational StructureThe following chart represents the preferred management structure:
C re d it A d m in is tra tion(M ay report separately
to M D/CEO )
C re d it A p pro va l(include s region al credit
centres if app licable )
M o n ito rin g / R e co ve ry( includes regional recovery
centre s if app licable )
H e a d o f C re d it R isk M a na g em e nt(C R M )
R e la tio nsh ip M an a ge m e n t /M a rke tin g (R M )
B u s ine ss D e ve lo pm e nt
H e ad o f C o rp o ra te /C o m m e rc ia l B a n k ing
O th e r D ire c t R e p o rts(In te rn a l A u d it, e tc .)
M a n a g in g D ire c to r / C E O
Key Responsibilities
The key responsibilities of the above functions are as follows. Credit Risk Management (CRM)Credit AdministrationRelationship Management/Marketing (RM)Internal Audit/Control
PROCEDURAL GUIDELINES The main procedures that are needed to ensure compliance with the policies:
Approval Process The following diagram illustrates the preferred approval process:
Credit ApplicationRecommended By RM / Marketing
Zonal Credit Officer(ZCO)
Head of Credit (HOC) & Head of Corporate Banking (HOCB)
Managing Director
Executive Committee/Board
- Credit Administration- Credit Monitoring- Credit Recovery
Thank You All
Thank You All