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Loan Policy- Credit Risk Management N.Gopal Deputy General Manager/MOF CAB Pune July 5, 20101RBI CAB Pune.

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Presentation on theme: "Loan Policy- Credit Risk Management N.Gopal Deputy General Manager/MOF CAB Pune July 5, 20101RBI CAB Pune."— Presentation transcript:

1 Loan Policy- Credit Risk Management N.Gopal Deputy General Manager/MOF CAB Pune July 5, 20101RBI CAB Pune

2 July 5, 2010RBI CAB Pune2

3 Loan policy- Genesis, Importance- Credit risk Management Need for loan policy Ingredients of a good loan policy Loan Policy and risk Management Prudential ceilings and loan policy Final Analysis July 5, 20103RBI CAB Pune

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6 Credit sanctioning guidelines, and the written documentation setting forth standards as determined by a bank's senior management. A bank's loan policy also establishes minimum credit standards for taking on loans. It sets policies and procedures in treatment of delinquent loans, and the type of customer a bank wants as a borrower. July 5, 2010RBI CAB Pune6

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8 1980s The world and the way of banking changed American banking history witnessed several credit induced bank disasters E.g. Continental, Sea First and Texan Banks 1990s Credit freeze due to East Asian Crisis 2000 GTBs credit induced problems Lessons The common triggers of crisis Aggressive and unplanned lending Credit concentration failure to diversify, Risky practices, inadequate monitoring Result Poor credit culture Credit culture is largely dependent on the loan policies pursued by a bank July 5, 20108RBI CAB Pune

9 First six years of the millennium saw paradigms shifts in bank lending India became more closely integrated to the global economy Interest rates moved both ways Traditional avenues for lending slowed down Competition Policies responses had to become dynamic outward and forward looking to meet challenges July 5, RBI CAB Pune

10 1. Board & Management Oversight 2. Portfolio Management 3. Management Information Systems 4. Market Analysis 5. Credit Underwriting Standards 6. Portfolio Stress Testing & Sensitivity Analysis 7. Credit Risk Review Function July 5, 2010RBI CAB Pune10

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16 Theory Broadly defining the credit culture Broadly laying out the external-internal environment Lookups Statutory issues & Regulatory Market, present environment Studies Industry, survey etc Setting up Risk Appetite Fixation of internal norms & prudential ceilings Deciding on risk rating Implementation Laying out procedures, appraisal standards, schematic issues July 5, RBI CAB Pune

17 Credit Culture This is the way we handle credit Establish Business Priorities Choose Credit CultureStrategies July 5, RBI CAB Pune Credit Policy determines the credit culture

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19 Based on Corporate priorities Based on Corporate priorities Credit Culture could be one of four types Credit Culture could be one of four types CORPORATE PRIORITY CULTURE Emphasis on asset quality, long term growth Values Driven (Conservative, Prudent) Short term gains Earnings Driven (Regardless of risk) Market share, Size Volume Driven /Aggressive No clear priorities Unfocussed July 5, RBI CAB Pune

20 A Delicate Balancing Act Overriding objective of credit policy Healthy Balance between Credit Volumes, Earnings & Asset Quality Within the framework of Regulatory prescriptions, Corporate goals - social responsibilities July 5, RBI CAB Pune

21 Credit expansion Steady expansion, sustained, continuous & prudent growth Steady rise in profits but emphasis on Quality Assets Profitable Relationships Statutory and Regulatory line This philosophy seeks to instill a value driven credit culture July 5, RBI CAB Pune

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23 RBIs Guidelines on Risk Management Systems in Banks require a typical Credit Policy to cover: Standards of presentation of credit proposals, financial covenants Rating standards and benchmarks Prudential limits on large credits and asset concentrations Standards for Loan collateral, Loan Review Mechanism Pricing of loans, risk monitoring and evaluation Legal and regulatory compliances Delegation of credit sanctioning powers Prohibition on lending July 5, RBI CAB Pune

24 No ambiguity in postulations- chance for different understanding interpretations Loan policy must clearly mark the boundaries Government RBI Bank Loan policy should ideally list out restrictions that credit grantors can refer Loan policy must provide for exceptions- list out if possible Loan policy must also lay down the levels of authority for certain credit decisions Regulatory reviews, inspections also provide opportunities for aligning loan policy to regulatory thinking July 5, RBI CAB Pune

25 Sector specific guidelines should also contain Dos and Donts based on present environment, statutory and regulatory guidelines e.g. Financing Real Estate, Capital Markets, bill discounting, NBFC lending etc Ban on lending to units producing ozone depleting substances is an instance of statutory restriction While assessing the adequacy of a loan policy these Dos and Donts should be weighed by the credit grantor Deterrents to non compliance to these dos and donts July 5, RBI CAB Pune

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27 Target markets, industry and business sectors are identified Sectoral study Trends in consumption, impact on a sector Growth potential, capital investment, Delinquencies Conclusions Translating experiences into policy Industry Study Products, Capital investment, Sunrise/sunset Turnover, Labour, locational concentration Market, fashion trends etc Seasonality Regulatory environment July 5, RBI CAB Pune

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29 Policy not to stop with managing transaction risks Has to address intrinsic risk also Portfolio perspective The risk inherent in certain lines of business is known through industry analysis Industry analysis to look at three vital factors Historic elements Predictive elements Lending elements July 5, RBI CAB Pune

30 Historic Risk Elements should look at: Financials: capital, cash flows, w.c. cycle Stability: demand, growth Longevity of the industry: demand, trend need etc Predictive Risk Elements would include: Structure: constitution Diversity: concentration Entry barriers- political, financial, feasibility Product Life cycle- ever in demand, seasonal etc Economic Vulnerability, Political / Regulatory risks, Environmental issues and Covariance factors July 5, RBI CAB Pune

31 Lending elements Collaterals-availability, acceptability Security- legal issues, Valuation – Delivery – Loan or an advance Industry study should be periodically reviewed and factored into the policy July 5, RBI CAB Pune

32 In real life policy setting industry analysis may or may not be documented on these rigorous lines In any case a careful consideration of all three risk elements go into the industry limits fixed by each bank This is based on the lending experience and business expectations that the bank has It is intrinsic risks in sectors like real estate and capital markets that explains the regulatory concern about build up of asset concentrations in these areas Inspection and Audit to help verification/validation whether the intrinsic risk in industries with higher exposure limits have been assessed by the bank July 5, RBI CAB Pune

33 Identify focus areas broad confines of strategy, study, restrictions etc. Identify macro economic trends, regulatory stance banks own experience core competencies Retail for instance became a focus area for banks after the interest rate deregulation and the slow down in corporate borrowings SMEs, Agriculture and Micro Finance are today perceived to be major business opportunities July 5, RBI CAB Pune

34 Each bank has its strong points and core competencies Public sector banks have a strong rural and semi urban presence and a history of success in agricultural and rural credit Banks in Western India have a predominant presence in sugar sector Credit Policy to draw on such strengths It should also leverage on sector specific regulatory incentives and relaxations extended from time to time July 5, RBI CAB Pune

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36 Prudential limits limiting magnitude of credit risk Dispersion of credit risk- prevents concentration Determinants- Credit culture Risk appetite Regulatory dictates Prevailing Industry and Economic Conditions Loan policy should articulate the rationale behind the limits, for better appreciation and understanding July 5, RBI CAB Pune

37 Financial Limits Single & Group Substantial Exposure Maximum limit Aggregate limit Industry wise Sector specific Individual Corporate Partnership Proprietorship Aggregate linked to capital funds July 5, RBI CAB Pune

38 Financial benchmarks with conditions under which deviations can be permitted Single and Group borrower limits not exceeding what is prescribed by RBI- permissible deviations Substantial Exposure limit (10% borrowers < 600% of capital) Industry and sector wise ceilings Limits on sensitive sectors subject to asset price volatility High risk and low priority sectors Maturity profile of the loan book July 5, RBI CAB Pune

39 Limit setting is unique to each bank It has to balance risk control against growth imperatives The limits set should reflect the legacy issues in the portfolio There should be higher limits for areas where Bank has a natural advantage Lower limits and ban in sectors where the Banks prior experience has been adverse Limit setting is dynamic and on-going July 5, RBI CAB Pune

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41 Tool for the measurement of credit risk To enable an informed and considered credit decision as good or bad To appropriately price loan products BCBS defines credit rating as summary indicator of risk inherent in individual credit signifying the risk of loss due to default of a counterparty by considering qualitative and quantitative information

42 Policy should provide for rating of all loan accounts- very little exceptions The rating should consist of 8-9 parameters (minimum) Policy to specify minimum entry rating i.e. Hurdle Rate Policy to lay down exceptions to Hurdle rate Policy to lay down procedures to handle accounts which fall below hurdle rating Annual review of ratings- Quarterly, half yearly updates Study of Rating migration Pricing linked to Rating Mapping of external ratings to internal ratings July 5, 2010RBI CAB Pune42

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44 A good loan policy to provide leeway for It should balance the risk and returns on the retail front Schematic Lending D irected credit flow to certain sectors Housing, farming, SME, retail, personal loans, special tie-ups etc Retail loans under various products and schemes designed by the Bank July 5, RBI CAB Pune

45 Returns from retail/schematic lending commensurate with risks? Schemes to match customer expectations? Standard of Due Diligence and KYC? Outsourcing risks adequately addressed? Delinquencies under control in specific product categories? What is the growth in terms of size, earnings and quality? July 5, RBI CAB Pune

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47 Take over route to grow business Policy to clearly lay down ground rules What type of borrower accounts What level of exposures Take over from whom Take over standards Pricing July 5, 2010RBI CAB Pune47

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49 Profitability, Customer Friendliness/service, Compliance Capital Conversation Challenges arise when what the customer needs are not provided for in the policy Trade off business considerations, social responsibility, July 5, RBI CAB Pune

50 Area of potential conflict in perceptions differences between regulator and banks Every policy has to provide for exceptions RBI the regulator also recognizes this But question is how far and how much Deviations/ exceptions dictated by business needs Extent of their impact on risk profile to be seen Within the overall credit culture of the bank July 5, RBI CAB Pune

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52 Credit Policy serves a Gate Keeping function Defines thrust areas in relation to credit culture, profit objectives and regulatory directions Defines acceptable levels of risk by identifying industry segments for fresh exposures Prevents risk concentrations and ensures diversification by setting limits on sectors and individual transactions It provides pricing strategies through the use of Credit Risk Rating framework July 5, RBI CAB Pune

53 Knowledge is the most potent of risk mitigant Does the policy provide for dissemination of knowledge on credit? Is the policy in itself, - Comprehensive, Articulate, accurate and User friendly? July 5, RBI CAB Pune

54 An ideal loan policy should Create right for business growth Maintain quality of assets Provide platform for good procedures/process Ensure regulatory and statutory compliances Be the platform for Credit Risk Management July 5, RBI CAB Pune

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