5. Part - 1 - Overview of Credit and Credit Process
- What is Credit? General Facts About Credit
- Overview of Credit Process
- Credit Management Framework
- General Guiding Principles of Lending
Part - 2 - Credit Risk Management Process
Part - 3 - NPLs Management and Its Strategies
- Meaning of NPLs; Causes of NPLs
- NPLs Management Strategies
- NPLs Write-off and Its Management
Training Outline
April 26, 2024
NPLs Management and Resolution - EIFS
NBE
6. The Training Objectives
6
Upon the completion of this training, the participants should able to:
Understand the basics of credit and credit process;
Demonstrate the credit analysis based on the 5C’s of credit;
Demonstrate Loan monitoring and Portfolio Management techniques;
Identify the credit associated risks and apply risk management techniques;
Identify causes of NPL and understand techniques of NPL Management;
Understand the NBE regulation regarding NPL management;
Understand the causes and cost of NPL.
8. What is Credit?
8
It is the temporary transfer of capital from
those who own it to those who use it.
Credit means receiving something of value now
and promising to pay for it later, often with a
financial charge added by the lender.
9. General Facts About Credit
It is a loan granted to creditworthy clients
with interest (conventional) and/or charges
(IFB).
Tenure-wise Long, Medium and Short term
loans.
Loans with specific maturity period (term
loan), revolving credit facilities like O/D, L/C,
pre-shipment…
It could be secured or unsecured loans
10. Cont…
Among the different functions in the bank, lending
function is the core business line of the banking
which contributes the major share of income to
their profitability.
Thus, the credit operations exposes banks to high
credit risk, and if it poorly managed lead them to
lose significant amount of their income in the form
of loan loss provision.
Loan portfolio management can be considered as
the heart of a commercial bank efficiency as it
plays vital role in the performance of a financial
institution by mitigating credit risk.
11. • Effective credit risk management improves credit
performance through establishing appropriate
credit risk environment, maintaining credit limits
at acceptable level, undertaking sound credit
granting process, proper monitoring and
controlling credit risk.
• Banks credit management processes can be
summarized in three main stages. These stages
are: credit appraisal, disbursement and credit
administration.
Cont…
12. • Poor credit risk management lead to the
accumulation of nonperforming loan (NPL)
under which the generated profit will not only
eroded through loan provision but also the
bank’s soundness, safety and stability of such
bank can be compromised.
• Failure of credit risk management system and
practice as one of the main cause of financial
crises.
Cont…
13. 13
Credit Process
Acceptance of
Credit
Application
Conducting
Preliminary
interview
Collection of the
required
documents
Origination of
LAF & sending to
the CA team
Document verification
and Credit
appraisal/recommend
ation by the CA & CRM
Credit Decision
Decision
Communication
/Appeal hearing/
Contract
Formation ,
Signing,
Registration,
insurance &
disbursement
Collection and
follow up
NPL
Management
14. Credit Policy
General descriptions on what to do (product, sector, terms,
collateral, NPLs etc).
Helps to create the framework, requirements and tolerance
limits for lending;
Credit Procedure
Describes on how to do credit activities
Memos and Circulars
Amendments, new issues etc
Directives of NBE (Single borrower limit, Credit information, Asset
Classification and provisioning, etc
How we do it? (Working manuals)
14
15. The Credit Management System comprises:-
Credit Policies and Procedures of the Bank;
NBE SBB/69/2018 Directive and others;
Credit Risk Management under RMG-NBE;
Credit Risk Management under RMP, specific Bank;
Appropriate organizational structure - Independent;
Adequate Board and Senior Management oversight;
Effective and efficient risk management process;
Adequate internal controls system; Appropriate Credit MIS;
Effective Credit Management Framework
16. General Guiding Principles of Lending
Grant credit in a manner that ensures full repayment;
Identify and manage credit risks in all products and services;
Ensure "know-your-customer" principles;
Increase the profitability of the Bank to the satisfaction of the
stakeholders;
Serve the legitimate needs of the markets and communities with
due consideration to environmental issue;
Ensure persons engaged in lawful and credit worthy
business/investment activities.
Practice prudent credit sanctioning standards; 16
17. All persons engaged in lawful and credit worthy
business/investment activities.
The business credit applicant shall present renewed
trade license for the current fiscal year, or investment
license for new projects; (what about Cooperatives?)-
NBE requirement
All applicants who are engaged in business shall
present a tax identification number /TIN/-
CRB/02/2019
General eligibility criteria/to whom?
17
18. Applicants (for individual including Spouse)/mortgagers/
guarantors who are engaged in business shall submit tax
clearance certificates - NBE/MOR requirement
The applicant and/or any of its major shareholders/subsidiaries
shall have no NPL- CRB/02/2019
The applicant shall never be engaged in tax evasion, or in any
breach of exchange and control regulations, or in any other
illegal/unlawful dealings and mal-operation of checking
account until the rehabilitation period is expired- NBE
Requirement
General eligibility criteria/to whom?
18
19. The applicant shall fulfill at least the required minimum equity
contribution which depends up on the banks risk appetite;
The applicant and/or his/her/its guarantor(s) shall give a written
and signed consent for the access of his/her/its credit
information maintained with the Credit Reference System and
sharing of same among all other banks (CRB-02/2019)
The applicant shall present all the documents/information
demanded by the Bank (SBB/69/2018 and bank Procedure)
General Eligibility Criteria…
19
20. The applicant‘s business shall be financially viable,
legally acceptable, technically feasible and
environmental friendly-
In addition to these criteria customer has to fulfill the
specific eligibility criteria for each loans and
advances set by the bank.
General Eligibility Criteria….
20
23. What is Risk?
• Risk is the probability of occurrence of
unfavorable outcome.
Or
• A chance that an outcome or
investment's actual gain will differ from
an expected outcome or implies future
uncertainty about deviation from
expected earnings.
• In a worst case, risk includes the
possibility of losing some or all of an
original investment.
What is Risk?
28. Brainstorming-4
• What is Credit Risk?
• How Credit Risk Arise?
• How Credit Risk Managed?
• What are elements of effective
Credit Management?
Credit Risk Management
29. • Credit Risk is the risk that a financial contract will
not be honored according to the original set of
terms or expectations.
• Credit risk emanates from a bank’s dealings with an
individual, corporate, financial institution or a
sovereign.
• Credit risk is probably the most critical risk in the
banking system.
• Why credit risk is the most critical risk?
What is Credit Risk?
32. • Incomplete/
Improper advise;
• In exhaustive
document
requesting
• Business nature
and loan product
mismatch.
2. Receiving
credit
application
Credit Processing Vs. Credit Risk Management…
32
33. • Not exhaustive
interview as a result
of not performing a
quick professional
review of the
presented document
and seeking
justification;
• Not concentrating on
the critical issues
• Unfriendly approach
of the interviewer
• Tailor made
preparation of the
customer for the visit
3.Preleminary
interview and
site visit
Credit Processing Vs. Credit Risk Management…
33
34. • In exhaustive
due diligence
report
• Incomplete
document
collection
• Legal issues of
the documents
• Weak KYC
analysis
4. Due
diligence
report and
credit
document
collection
Credit Processing Vs. Credit Risk Management…
34
35. Customer Recruitment
Recruiting credit worthy customer is very essential.
Hence, after the customer lodges his/her/its request, the CRM shall
conduct interview, business visit, collect the required documents
and produce Due Diligence Report (DDR);
Interview
Enables to obtain adequate and complete information with regard
to:
The purpose for which the funds are required;
The amount and nature of other liabilities of the borrower
Sources of repayment of the loan
35
36. Customer Recruitment…
Interview …
The collateral being provided;
The main customers and suppliers of the business;
The availability of an alternative market;
The willingness of the shareholders/owners and
management to repay loans and their track record
with the Bank;
Other information as required
36
37. Business Visit
Conducted to collect additional information required to
assess the credit worthiness of the applicant;
During business visit, the CRM shall collect information on
the following issues:
Operations of the business
Stock conditions
Machineries and collateral condition
Management and employees relationship
Record keeping habit etc…
Customer Recruitment….
37
38. Required Loan Processing Documents
Legal documents (trade license, TIN, tax exempt
certificate, tax clearance certificate, MOA, AOA, power of
attorney if any, marriage/non-marriage, etc.)
Collateral related documents (LHC, approved plan, libre,
Performa invoice, valuation certificate, if applicable etc.)
Financial related doc. (Financial statements- Audited*/
Provisional/Interim, business plan/feasibility study etc. )
Management Profile (CV, employment agreement,
education credentials etc.)
Other Internal Documents (credit information, account
statement, credit history etc)
Customer Recruitments…
38
39. Due Diligence Report (DDR): a report that summarizes
and assesses the credit worthiness of the customer
At least it covers:
Basic information of the customer
Business premises
Condition of machineries and collaterals
Production mix and sales trend
Management profile (experience and qualification)
Brief credit history of the applicant with the bank and
others
Comment on the presented financial statements
Credit request and its purpose
Overall observation and comments on the
Customer Recruitments…
39
41. It is a critical assessment of the creditworthiness of a
borrower through:
The identification of anticipated risks and setting
risk mitigating measures;
SWOT analysis: strengths & weakness- internal to
the business, and opportunities and threats-
external to the business/
Credit Analysis
41
42. How to perform credit analysis/Appraisal?
1. Character
2. Condition
3. Collateral
4. Capacity
5. Capital
Through the analysis of 5
C’s of the credit
42
43. • Inappropriate
credit
recommendatio
n by the
analyst/ RM.
• Missing of the
relevant data
for the
decision,
• Missing the
required
covenants,
terms and
conditions
6. Credit
decisions/
Risk
Mitigation
Credit Processing Vs. Credit Risk Management…
43
44. • Weak credit
follow
up/physical,
legal and
financial follow
up/
• Disbursement
without the
fulfillment of
the terms,
conditions and
the proposed
covenants.
7.Monitorin
g the credit
performanc
e
Credit Processing Vs. Credit Risk Management…
44
45. • Communication
gap
• Weak follow-up
• Weak Problem loan
Management.
• Inappropriate asset
classification (i.e.
against (SBB/
69/2018 of the
central bank).
8.
Provisioning
and loan
Workout
process
Credit Processing Vs. Credit Risk Management…
45
46. The followings are basic elements of effective credit
risk management:-
i. Board and Senior management oversight;
ii. Adequate credit policies, procedures, limits;
iii. Independent risk management function;
iv. Effective credit follow-up & monitoring, and
workout function;
v. Effective Credit MIS – furnish appropriate
reports; and
vi. Trained staff i.e. qualified to implement the
system.
Elements of Effective Credit Risk Management
47. Credit Risk Identification
The first step in the process of managing
credit risk is:-
identifying existence of potential risks in the
bank. Risk identification can start with
identifying the activities/products/operations
units which make a bank vulnerable to credit
risk. Moreover, credit risk should be identified
at the time of new product development.
Steps of Credit Risk Management
48. The credit risk identification of the lending operation can be analyzed both at
transaction level and portfolio level:
A. Transaction level
An element of risk is inherent in any type of loan and other placements
because of the uncertainty of the repayment. We should establish appropriate
policy and procedures to identify credit risk at transaction level:
• Various approaches like, 5 C’s, :
• Character: the borrower’s credit worthiness and honesty;
• Capacity: both the borrowers legal standing and its management expertise in
handling the business so that the borrower can repay the loan;
• Capital: wealth condition measure by financial soundness and market
standing;
• Collateral: the banks second source of repayment or security in case of
default;
• Condition: the general economic environment of industry specific situations/
of the loan.
Cont…
49. B. Portfolio level
It refers to the inherent risk in the composition of the credit
portfolio, in general, and is highly influenced by the
concentration of the following criteria:
• Agriculture: production and yield risk due to unpredictable
impact of weather, pests and diseases, and other calamities
on farm production such as droughts and flooding,
perishable Horticulture.
• Manufacturing: dependency on imported raw material,
power supply.
• Construction and building: rises in cost of living,
unemployment, adverse economic conditions.
• OD: difficult to monitor utilization, diversion.
• Collateralization: on the type of security- clean, movable, or
immovable
Cont…
50. A Bank shall consider quantitative and Qualitative
factors:
Example
Quantitative Factors:
NPL (Non-performing Loans) Ratio,
Special Mention loans, particularly past due more
than 60 days,
Provision coverage for NPLs, and regular loans
Credit Concentration level,
Average loan recovery rate – collateral,
Credit Risk Measurement
51. A Bank shall consider quantitative and Qualitative factors:
Example
Qualitative Factors:
CMD structure, manning,
Quality and level of underwriting – credit worthiness
assessment & appraisal,
Asset classification and provisioning practices – NBE
directive No.SBB/69/2018,
Loan Grading (risk factors-internal and external rating),
Strength of Credit follow-up & monitoring function,
Strength of Credit workout strategy effectiveness,
Foreclosure and credit litigation effectiveness,
Adherence to NBE directives and own policies & procedures,
Cont…
52. Additional Measurement Tools:
• What is Stress Testing?
Credit Risk Stress testing: can range
from relatively simple alterations in
assumptions about one or more
financial, structural or economic
variables, to the use of highly
sophisticated financial models.
Cont…
53. Example - 1
Baseline Data:
• Total Loans and advances (Principal) = 8,899 million,
• Absolute of NPLs = 250 million,
• NPLs Provision held = 50 million,
• Profit Before Tax = 275 million,
• Average Capital = 1,579 million,
• IARR = 62%,
• NBE - Substandard Provision Rate 20%,
• Assumption: NPLs increase by 10%, 30%, 50% i.e.
Substandard Category,
ABC Bank S.C
Credit Risk Stress Testing
54. Magnitude of Shock
Pre-shock
Value
Scenario I Scenario II Scenario III
10% NPLs
increase
30% NPLs
increase
50% NPLs
increase
Total NPLs
Increase in provisions
Profit before tax (Post-
shock)
Average Capital
RoE(Post-shock)
NPLs ratio (Post-shock)
Solution for Example -1
Increase in NPLs – Substandard
55. Example - 2
ABC Bank
Large Borrowers exposure Report
Top 1st = Birr 320 million
Top 5 = Birr 1,120 million
Top 10 = Birr 1,925 million
Top 20 = Birr 3,225 million
Assumption: In case, Top-1, Top-5 and Top-10 default and classified
as Substandard Category,
Cont…
56. Magnitude of shock
Pre-
shock
Value
Scenario IScenario II
Scenario
III
Top 1st Top 5 Top 10
Top borrowers -
Total NPLs (Post-
shock)
250
Increase in provisions 50
Revised Profit 275
Average Capital 1579
Revised ROE 17.42
NPLs ratio 2.81
Solution for Example -2
Default by Large Borrowers – Substandard
57. We can use various techniques of mitigating credit risk:
A. The most common are collateral, guarantees and netting
off of loans against deposits of the same counterparty.
These techniques will reduce or transfer credit risk. In
Ethiopia, the most common credit risk mitigation
technique used is collateral. Banks should primarily assess
the borrower’s capacity to repay and should not use
collateral to compensate for insufficient information.
B. Setting exposure limits,
C. Putting in place sound credit policies and procedures, i.e.
credit granting, administration, managing problem loans.
D. Other methods could be risk based pricing, covenants,
financial conditions reporting, tightening and
diversification.
Credit Risk Mitigation
58. This is the step where banks shall take and
develop a Risk Register, credit review
function, internal audit inspection and
other activities to use all available platforms
to monitor, track and review risks.
Credit Risk Monitoring
59. Absence of adequate written
policies;
Absence of portfolio
concentration limits;
Excessive centralization or
decentralization;
Poor industry and financial
analysis;
Infrequent customer contact;
Excessive OD lending;
Incomplete loan contract and
loan files;
Reliance on collateral;
Loan disbursement before
all relevant documents;
Regulatory pressures;
Instability in the business
environment;
Lack of adequate and
reliable data about the
borrowers;
Unfair competition;
Unreliable financial
information
Common Challenges of Credit Risk
Management
62. Identify the early warning signals of the customer’s business
that requires close follow up and remedial actions
63. Early Warning Signals in Regular Loan Follow-UP
The Credit performer shall detect/Recognize the
early warning signal and shall close follow up the
customer and take remedial action:
Warning signals generally emanate from:
Financial Related problems
Operational Related Problems
Market Related problems
Attitudinal Related problems
63
64. Early Warning Signals in Regular Loan Follow-UP
1. Financial Related problems:
Irregularity in loan repayments
Failure to honor financial obligations, L/Cs, invocation of
guarantees
Sales transactions not routed through Bank accounts
Declining current ratios
Declining profitability/loss
Erosion in TNW
Changing/opening accounts with other Banks
Worsening credit ratings- Internal/External
64
65. Early Warning Signals in Regular Loan Follow-UP
2. Operational Related Problems:
Low activity levels in business/capacity
Disorderly diversification/Frequent change in plans
Growth of overdue receivables
Return of outward bills unpaid/dishonored cheques
Low inventory/stocks movement
Non- payment of wages/utility bills
Frequent labor problems
Loss of critical/important customers
Frequent return/rejection of finished goods
65
66. Early Warning Signals in Regular Loan Follow-UP
3. Market Related problems:
– Inability to source supplies on usual credit terms
– Complaints regarding quality of goods/service
– Legal action against the business by customers
– Loss of markets/key customers
– Change in market preference for the product
– Adverse changes in government policies
– Emergence of new competitors
– Emergence of new technology/products 66
67. Early Warning Signals in Regular Loan Follow-UP
4. Attitudinal Changes
Dissension among directors/partners/promoters
Avoids contact with the bank
Non/delayed submission of financial statements
Falsifying of financial statements etc
67
68. Early Warning Signals in Regular Loan Follow-UP
The Credit Performer should carry out assessment of the
borrower‘s business viability by indicating key performance
indicators such as profitability, activity level, management of the
business, etc.
In so doing, the he/she shall identifies those borrowers that
need special attention and categorize them as “watch list” for
further close follow-up and appropriate remedial action.
68
69. Types of Regular Loan Follow-UP
Physical follow-up: Existence and operation of the business status
of collateral and correctness of declared financial data, availability
of RM, labor situations, Turnover of key employees.
Financial Follow-up: Whether assumptions on which lending
decisions was taken continuous to hold good, both with regard to
borrower‘s operation and environment, and whether the end use
is according to the purpose for which the loan was given.
Legal Follow-up: to ensure legal recourse available kept alive at all
times. (Loan/Mortgage contracts, as appropriate);
69
71. What does it mean NPL and how
identify the causes of NPLs?
72. Meaning of Non-performing Loans (NPLs)
Non-performing Loans - loans and advances whose credit
quality has deteriorated such that full collection of
principal and/or interest in accordance with the
contractual repayment terms of the loan or advances is in
question: (SBB/69/2018).
Loans and advances with established repayment
programs are NPL, when principal and /or interest is due
and uncollected for 90 consecutive days or more beyond
the scheduled payment date or maturity.
72
73. Overdraft and loans or advances that do not have
a pre-established repayment program shall be
categorized as non-performing when:
a) The debt remains outstanding for 90 consecutive
days or more beyond the scheduled payment date
or maturity
b) The debt exceeds the borrower's approved limit for
90 consecutive days or more
73
Cont…
74. c) For over draft,
(i) the account has been inactive for 90 consecutive days or
more, but less than 180 days or
(ii) deposits are insufficient to cover the interest accrued
during 90 consecutive days or
(iii) the account fails to show debit balance of 5-19% of the
approved limit at least once over 360 days preceding the
date of loan review.
Cont…
75. Causes of Non-performing Loans (NPL)
75
Causes of problem
loans are broadly
classified in two:
External factors Internal factors
76. 76
1. External Factors:
Business cycle: The expansion phase of the economy is
characterized by a relatively low number of NPLs. However as the
booming period continues, credit is extended to lower-quality
debtors and subsequently, when the recession phase sets in, NPLs
increase.
Unemployment rate: Increases in unemployment may signal a
decrease production as a consequence of a drop in effective
demand. This may lead to a decrease in revenues and a fragile
debt condition.
Cont…
77. 77
1. External Factors:…
Macroeconomic instability (Inflation, interest rate, Exchange
rate etc):The probability that firms will make losses rise; as does
the probability that they will earn windfall profits.
Political
Social
Technological
Environmental(ecological)
Legal etc.
Cont…
78. 78
2. Internal/ Bank Specific Factors
Rapid credit growth: Excessive lending explains loan loss rate
High interest rate: Inappropriate loan pricing (For Banks
changing differentiated interest rate), High interest rate
impairs Business profitability
Lenient Credit Terms: Terms and conditions set during loan
sanctioning has the detrimental factors. Credit managers
reacted to competition from other bankers and that this
competition might have encouraged a weaker lending
standard that leads to loan defaults
Cont…
79. 79
2. Internal/ Bank Specific Factors
Lack of proper skill amongst loan officials, speedy process of
evaluating loans mainly due to external pressure, are among
the factors that lead to huge concentration of non-performing
loans.
Bank size: Small banks prefer to lend to small firms that lack
hard financial data to support the lending decision and riskier
to the extent that the failure rates of small businesses are
higher than those of larger, established firms;
Cont…
80. 80
2. Internal/ Bank Specific Factors
Poor loan follow up (Monitoring): Some of the loans defaults
ascribe to lower level of attention given to borrowers. More
banks lose money because they do not monitor their borrower’s
property, and fail to recognize warning signs early enough.
Poor Risk Assessment: Risk, and the ways, in which it can be
identified, quantified and minimized, is key concerns for a bank’s
management.
Cont…
81. NPLs Management Strategies
81
As per the NBE directive SBB/69/2018 a bank shall
establish loan workout and recovery team to manage
the NPLs.
Non-performing Loans Management Strategies
Amicable Resolution(workout)
Legal Proceedings
Write-off and Post write-off follow up
82. Amicable Resolution/Loan workout
82
It is undertaken provided recovery is found promising Loan
Workout Negotiation Points:
The borrower’s/guarantor’s proposal for repaying his/her/its
debt;
Source and capacity of repayment (down payment and
periodic repayments);
Settlement conditions;
Collateral;
Tenure/duration of restructuring or rescheduling a loan;
Additional covenants, if any, etc.
83. 83
Options for Amicable Resolution( Loan workout)
Restructuring- changing the tenure and mode of repayment
Securing additional collateral/change of collateral including a
personal guarantee by owners/shareholders;
Cross-collateralizing multiple loans;
Voluntary liquidation of collateral already held;
Sellout/buyout of loan to/from other banks;
Changing the form of loan partially or fully;
Transfer of the loan to another potential borrower;
Enforcing additional conditions/covenants;
Cont…
84. 84
Options for Amicable Resolution( Loan workout)…
Voluntary sale of other assets for loan repayment;
Replacement or improvement of the management;
Assigning a co-manager or a controlling staff;
Reduction of overdraft to a lower limit; and
Approve additional finance if there are appropriate and
concrete justifiable reasons.
Cont…
85. 85
While using the above options, it is mandatory to confirm the
eligibility of the case per relevant directives of the regulatory
body and policy and procedure of the Bank, for such
consideration;
NBE directive SBB/69/2018 states that a bank shall not
renegotiate short or medium term loans and advances to
a borrower for more than 5 iterations and long term loans
and advances for more than 6 iterations.
Cont…
86. 86
The manner of collection of interest and/or principal in
arrears by the bank and issues related to grace period shall
also be part of the renegotiation between the bank and the
borrower depending on specific circumstances of the loan and
capacity of the borrower
A bank may extend additional loans and advances to a
borrower who defaulted from own bank with a view to
rehabilitate loans and advances
Cont…
87. Application of Penalty Rate on NPLs
87
The Bank charges an additional penalty rate of 3% as soon as
a loan account turns non-performing.
The 3% penalty rate shall be waived for a restructured/
rescheduled loan immediately even though it is still in NPL
category.
Re-Transfer of Regularized Loans
Cases shall be transferred back to the CRM where the
customer’s business is believed to generate sustainable cash
flow to warrant full settlement of the debt and fulfills the
relevant NBE directive.
88. Legal Proceedings (Foreclosure or Litigation)
88
It is not always possible to resolve cases in a positive manner.
Hence, if no mutual agreement is reached to the better, legal
proceedings will come to the picture:
Legal process can be executed under any of the following
mechanisms:
When the loan is not recoverable through amicable means;
When the concerned approving team decides on transfer of
loan cases to legal process after exhausting other
settlement alternatives.
89. Write-Off
89
If it appears that part of the outstanding debt is uncovered from
proceeds through the legal process and other all means, proposal
will be presented for temporary removal of the uncollectible
outstanding principal balance (write-off) from the Bank’s balance
sheet:
The property found in the name of the borrower/guarantor,
their spouses or the collateralized property is proved not to
cover the loan fully; and
After having ascertained that there is no other attachable
property to cover the remaining balance fully or partially.
90. Reasons for Proposing Write-Off
90
Absence of Property
Insolvency
Bankruptcy
Higher Cost of Recovery than the Realizable Value of the
Property
Defects in Documentation
Court Judgment against the Bank
Elapse of Statutory Period
91. Post Write-Off follow-up
91
Post write off follow-up will proceed to further exploit
unforeseen opportunities, to recover the loan;
Finally, Draw lesson and compile data for future consumption as
input to avoid similar experience
