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Do Financial Institutions Follow Laid Down Procedures

Introduction

In the past people were using barter system in the form of commodity money to exchange goods that they don’t have, but with the advent of money, things have changed and nowadays to satisfy their basic needs & necessities, to acquire luxuries, any other movables & immovable’s people resort to credit financing through financial institutions or otherwise..

In the simplest language, giving credit to people means giving loans & advances including customer’s lines of credit, overdraft and so on.

The range of consumer durable goods has widened enormously and with the rising standard of living many of these things – washers, cookers, refrigerators, etc have come to be regarded as normal household necessaries. Hire purchase makes buying too easy for some people who, however, in consequence may undertake more commitments than they can fulfill.

Giving credit to individuals, corporate, small scale enterprises, factories and others is a highly lucrative business as well as risky. Millions of rupees are advanced to the latter for investment purposes, to create jobs, and actively participate in the country’s development. Though profitability is the main objective of every lender, it must be ensured at the same time that borrowers are able to pay back the amount taken inclusive of interest (risk premium) under some agreed terms & conditions at the respective time period.

1.2 Problem Statement

1.3 AIMS AND OBJECTIVES OF THE DISSERTATION

The goal of the study is to analyze to what extent financial institutions is prepared to advance credit to a wide range of different stakeholders of the economy. In the Mauritian context, there has been a lot a debate since the 2008 financial crisis as to whether the banking sector is playing their role efficiently & effectively to face the challenges ahead of us.

Objectives of the dissertation:

To find out the effectiveness of credit appraisal in the banking sectors.

Carryout bankers satisfaction survey to find out the perspective of the banking sector towards the appraisal process

The procedures adopted by banking sector to evaluate the credit worthiness of their customers.

OUTLINE OF THE STUDY

Chapter one: Introduction

This chapter gives a brief background of credit in a general view and in the context of Mauritius. Moreover this chapter gives the problem statement and eventually it ends up with the aims and objectives.

Literature Review

Literature Review for this project will be divided into three chapters

Chapter Two - Credit appraisal

Chapter Three - Financial Institutions (context of Mauritius)

Chapter Four - Procedures

These chapters above provide the definition of credit appraisal, the different steps involved in the process of appraisal, and the reasons of having good and established credit policies and procedures. It is about reviewing the literature by means of different articles relating to the area under discussion. The literature review enables us to have a useful insight on the findings the researchers about credit appraisal through scandals around the world.

Chapter Five: Research Methodology

This chapter defines the methodologies used to attain the purpose of the project. This describes who the target population for this survey, techniques used for data collection, the methods used to analyze data to acquire the results and the limitation of the study.

Chapter Six: Analysis - Results and Discussions

This chapter shows how the data collected is analyzed through different tests and diagrams using the software SPSS.

Chapter seven: Conclusion and Recommendations

In this chapter, conclusion is derived from the study and some recommendations are suggested.

Chapter 1 Financial Institution

Financial Institution

SubprimeMortgage(Source:http://www.investopedia.com/slide-show/top-bank-failures/indymac-failure.aspx)

In the year 2000, there was a downfall in companies that relies too much on internet transactions and this was to be aggravated by the Sept 11 terrorist attack in 2001. --So in order to keep the economy going, central banks around the world reduce it interest rates which in return created an excess in liquidity on the market. As money was available at a cheap rate, investors were prepared to put their money in riskiest securities. Lenders, especially banks approved subprime mortgage loans even to borrowers having a poor repayment capacity in order to increase their profit. This enable more people to take mortgage loans which ultimately increased the price of houses (dd>ss). The figure whereby the mortgage lender creates a mortgage secured by some amount of the mortgagor’s real property was at its peak in 2005. Finally in 2006 the anticipated trend collapsed.

The end result of these events was that as stipulated in their contract, if the homeowner is unable to pay the principal and/or interest on his or her mortgage, the bank can seize and sell the property. Eventually large lenders and hedge funds were declared bankrupt which create further downfall in economic activity. The following banks were closed during the crisis due to an eroding loan portfolio:

Indymac bank based in Pasadena (July 11 2008) – total assets -$32.01 billion/ deposits $19.06 billion

Washington Mutual -the single largest bank failure in history by assets, went under in September 2008 - with more than $30billion losses ( bought by JP Morgan)

Merrill Lynch was put into a pre-packaged sale to Bank of America

Bear Stearns' acquisition by JPMorgan Chase and Countrywide Financial by Bank of America.

AIG (AMERICAN International Group) was bailout in September 16, 2008 by the American government through a loan to AIG in exchange for 79.9% of the company's equity as the company was considered too big to fail.

Chapter 2 CREDIT APPRAISAL

Credit Appraisal

Credit appraisal assessment differs from one institution to another but in general the main criteria’s upon which the decision is based remain the same. The judgment taken to sanction or discard the proposal has to be based on a careful study of various facts offered by the borrower pertaining to him and the proposal as assessed by a relationship manager. Such an objective and thorough study of the information and records should persuade the sanctioning power that the money lent to the borrower for the desired purpose will be safe and it will be repaid with interest over the desired period, if the statement and terms and conditions on which it is sanctioned are satisfied. Such an in-depth study is called the pre-sanction credit appraisal. It helps the approver to sanction the proposal.

Credit appraisal is the process by which a lender appraises the technical feasibility, economic viability and bankability including creditworthiness of the prospective borrower. It also helps in assessing if that customer will be able to repay the loan amount in the stipulated time, or not. The credit-worthiness of a borrower is determined by the banks that have their own methodologies for assessment. Being a very crucial step in the sanctioning of a loan, the borrower needs to be very careful in planning his financing modes. The banks need to be cautious; else they might end up increasing their risk exposure. All banks employ their own unique way of evaluating the creditworthiness of their customers.

Basic information required by the bank while assessing a customer is:

income of applicant and co applicant

Age of applicants

Educational Qualification

Profession

Experience

Other information might include additional sources of income, past loan record, family history, employer/business, security of tenure, tax history, assets of applicants and their financing pattern, recurring liabilities, other present and future liabilities and investments (if any). Out of these, the incomes of applicants are the most important criteria to understand and calculate the credit worthiness of the applicants. As stated earlier, the actual norms used for assessments decided by banks differ greatly. Based on these parameters, the maximum amount of loan that the bank can sanction and the customer is eligible for is worked out. The broad tools (e.g. Credit Scoring) to determine eligibility remain the same for all banks.

The assessment of the various risks that can impact on the repayment of loan is credit appraisal. In short, the banks are determining “Will I get my money back??. Depending on the purpose of loan and the quantum, the appraisal process may be simple or elaborated. For small personal loans (individual) credit scoring based on income life style and existing liabilities may suffice. However for project financing, the process comprises technical, commercial, marketing, financial, managerial appraisals

Monitoring

Credit Documentation

Credit Scoring

Credit Appraisal Process

Credit Processing

Credit approval/sanction

Disbursement

Managing credit/recovery

Credit Administration

Figure 1 Credit appraisal

Modern approaches

The recent approaches for credit appraisal are statistical in nature. These approaches are more objective as they are based on statistical model. One of the most common approaches is the credit scoring model.

Credit-Scoring

Banks mostly relied on the analysis of financial statement to evaluate the applicant’s ability to pay bank a loan. This is effective to a certain degree but was limited in the sense that, the willingness of the application to continue the payback could not be determined even if the later is financially well off.

This flaw can be addressed by using the credit scoring model to evaluate the loan applications they receive from consumers. Each financial institution can develop their own credit scoring models on retail lending. These models are created by analyzing facts about previous financial transactions and current situation of an individual or organization.

Step 1 - Credit Processing

This phase of the credit processing is where all the necessary information or data is collected and whereby credit applications are screened. The credit application must be adequately detailed to allow the gathering of all information required for credit evaluation at the beginning. Thus financial institutions must ensure that they have in place the necessary checklist to verify that all necessary information is available.

Organizations should set out pre-qualification screening criteria, which would act upon as a guide for their officers to be able to establish the types of credit that are up to standard. For Example, the criteria may include rejecting applications for blacklisted customers. These criteria would save time by avoiding institutions to process applications that would be later rejected.

In addition, all credits should be for genuine purposes and adequate procedures should be established so as to make sure that financial institutions are not used for fraudulent activities. Institutions must safeguard their reputation by not granting credit to customers of questionable repute and integrity.

Credit screening is the stage where organization analyses the customer’s ability to meet his obligation. Here financial institutions should ensure that facilities are granted to creditworthy customers who will be able to reimburse from a reasonably determinable sources of cash flow on time.

Usually financials institutions will require collaterals or guarantee to secure a credit facility in order to mitigate risk. It should be noted that these securities are only to mitigate risk and by means a substitute for a customer’s ability to honor its debts. Security offered should not prevent a full assessment of a customer ability to reimburse its loan facility nor should they compensate for insufficient information from the borrower.

Moreover proper care should be taken while financing working capital. Financial institution should not only rely on guarantees given by the borrower but also on the repayment capacity of the borrower. These types of financing should be in fact supported by an appropriate analysis of projected sales, cash flows, potential working capital ratio, past experience of working capital financing contribution of the borrower.

The appraisal criteria will vary between individual’s customers and corporate credit customers. Corporate customers must provide audited financial statements in support of their application. Generally the appraisal criteria will focus on the following:

Sources of repayment of the borrower.

Amount and purpose of the required facility

Reputation and integrity of the customer

Background of the customer, if any credit previously granted by financial institutions

The repayment capacity of the borrower based on his business plan, and projected cash flow (if any)

Site visits inspection of the borrower’s business location

Experience in the business field

collateral

Credit approval

Financial institutions have the task to put in place guidelines pertaining to credit approval process. For transparency purposes, these should also include the list of approved individuals and/ or committees and the bases of their decision making. Usually selected authorities are approved by board of directors. The approval authority may sanction new credit approvals; renewal of existing credit facilities, and changes in terms of conditions of in the past approved credits, primarily credit restructuring and every decision taken should be documented and recorded. In order to have a more credit caution approach, the credit approval committee must not have any connection with the customer.

Approval authorities of individuals should be equal to their rank in management and their experience. It is more practical to have two officers to approve the credit application in harmony with the board’s policy, depending on the nature and size of the credit. The approval process should also be on a system of checks and balances. More complex credit applications should be viewed by the credit committee.

Local banks operating through branches in Mauritius should centralize their credit approval process at the Head office. All credit approval should be at the same standard, based on established criteria. Financial institution should also have well experienced professionals that will be able to assess, judge, approve and manage credit risk. All credit approval should be scrutinized so that no senior individual in the financial institution is able to take priority over the established credit granting procedure. Board of Directors should review the related party transaction under due processes of good governance.

Credit Documentation

The fundamental part of the credit process is the documentation. Documentation is needed at each phrases of the credit cycle, together with credit application, credit analysis, credit approval, credit monitoring, collateral valuation, impairment recognition, and foreclosure of impaired loan. Credit files must be of standard format and keep in order, with a proper arrangement of cross-indexing to smooth the progress of assessment and follow up. Bank of Mauritius will pay particular consideration on the maintenance of credit files. these files should be efficiently maintained with a good system of cross- indexing to smooth the progress of review and follow up of files.

Financial institutions must make sure that contractual agreements with their customers are vetted by their legal advisers. Credit application must be processed in any case either of their approval or rejection. Bank of Mauritius should have all documentation on hand for examination

At each phase of the cycle financial institutions must set up policies on information to be documented. Details of information will depend on the nature of facility and his previous performance with the organization. For each customer, separate credit file should be maintained. If new files are created, it should be properly cross-indexed.

Financial institutions should keep only the copies of critical documents for safety measures (that is those of legal value, letter of offer also known as sanction letter, sign credit agreements or loan agreements) in the credit files, while retaining the originals in more protected custody. Credit files should not be removed from the organization premises and kept in fire proof cabinets.

Financial institutions should sustain a checklist that can confirm all their policies and measures ranging from pre-sanction to post-sanction are being complied with. The checklist should also comprise the identity of the staff or committee involved in the decision making procedure.

Credit Administration

Financial Institutions must make sure that their credit portfolio is correctly managed, such as loan agreements are correctly prepared, renewal advices are sent regularly to customers and credit files are updated on a regular basis.

An establishment may allocate its credit administration procedure or function to a separate unit or to designated individuals in credit process, depending on the volume and density of its credit portfolio.

As a minimum, a financial organization’s credit administration function should ensure that:

Credit files are classified in order, cross-indexed, and their removal from the organization/premises is not allowed.

The borrower has assigned the required insurance policy in favor of the bank and premiums are effected regularly.

Rental-fee is being effected by the borrower on time in respect of charged leasehold properties.

Disbursement of credit facility is being effected only after all the contractual terms and conditions have been complied and all necessary documentation has been obtained.

Collateral value is monitored on a regular basis.

Principal and interest is being serviced on time by the borrower as well as any agreed fees and commissions.

Information provided to management is both correct and appropriate.

Duties or responsibilities within the financial organization are effectively segregated.

Funds disbursed under the credit agreement are actually used for the purpose for which they were granted to customers.

“Back office? duties and functions are controlled properly

The policies and procedures of the organization are complied with along with other relevant laws and regulations.

On-site inspection of the borrower’s asset or company is effected regularly.

Disbursement

A letter of offer (also called sanction letter) is sent to the customer once the credit facility is approved with all the terms and conditions mentioned. Two copies of the letter of offer are sent to the customer and the duplicate should be duly signed in token of having accepted the terms and conditions and return back to the financial institutions.

In case where the customer do not signify the interest within the next 30 days on receiving the letter, the availability of the credit facility shall expire and the bank will not be obliged to even revive the facility. Disbursement of the credit facility will be effected only after all relevant documents are submitted to the financial institution and after completion of all necessary documentation and registration of collateral , insurance cover in favor of the institution and the vetting of documents by a legal expert and that all terms of sanction are complied.

The disbursement of the credit facility will be released prior to compliance with pre-disbursement terms and conditions and approval by the relevant authorities in the financial institutions.

Monitoring

In order to protect the financial institutions against any potential failure, problem facilities need to be identified before time. An appropriate credit monitoring system will make sure that quick and corrective measures are taken when warning signs shows a weakening financial health of the borrower, for example, unauthorized drawings, arrears in loans and deterioration in the borrower’s operating environment. Financial institutions should have a proper system in place to review the status of the credit and financial health of the borrower al least once a year. More frequent assessment (that is at least quarterly) should be done for large credits, problem credits or when business of the customer is undergoing major changes.

In broad term, the monitoring activity of the establishment should ensure:

Disbursement of funds is strictly used for the purpose stated of the letter of offer (sanction letter)

Financial situation of the customer is frequently track, and management advised in a timely approach.

Contractual agreements are being abided by the borrower.

Collateral exposure is assessed on a regular basis and related to the borrower’s financial health.

The organization’s internal risk ratings reflect the current circumstance of the borrower.

Non performing loans or facilities are identified and classified on a timely basis directly to management for corrective measures.

In order to monitor credits, a review of the up-to-date data or information on the borrower should be examine like:

Background information of the customer from other financial institutions with whom customer is operating.

Findings of site visits

The audited financial statement and latest management accounts

Business plan details of the customer.

Cash flow projections and financial budgets.

Board resolution is required for corporate customers

The borrower should be asked to give explanation of any variances in the projections provided.

Managing non Performing accounts or Recovery

Financial institution should clearly define how non performing accounts are to be managed. The positioning of this responsibility in a credit department will depend on the volume and density of credit operations. It can form part either of the credit monitoring section of the credit department or as an independent unit called the credit workout unit within the department.

Very often, it is more caution and preferable to isolate the credit workout activity from the department that sanctioned the credit facility so as to have a more separate assessment of the non performing accounts. This unit will be responsible to follow the aspects of the problem credit, including a repayment plan of the borrower, rescheduling of the credit facility, monitoring the value of applicable collateral, examine thoroughly all legal documents and also dealing with receiver/manager until the recovery matters are finalized.

Financial institution should also put in place a system that make sure that management is kept advised on a regularly on all developments in the recovery process, from the credit workout unit.

Clear evidence should be kept on file for all steps including legal procedures taken by the financial institution in recuperating the claims against a delinquent customer If there is a delay in the liquidation of security or other recovery processes, the grounds should be correctly documented and projected actions recorded taking into account any updated plans submitted by the borrower.

The accountability of individuals/committees who sanctioned and monitored the credit should also be revisited and lessons learned from the examination should be properly recorded in file

Chapter 3 PROCEDURES

Procedures

Continue process

KYC for Individual customer

KYC for corporate customer

Certificate of Incorporation

Trade Licence

Financials statement for at least last two years

Forecast cash flow (New company)

Collateral (if property valuation report

Application form

MCIB disclosure

Company Searches or Search report

CBRIS

5C’s of evaluating credit

Credit Application and (Communication)

Figure. Procedures in the analysis process prior to credit appraisal

Request for credit facility usually begins with the completion of a Credit Application. This information in most cases is procured by the relationship manager for the Credit department to make decisions in setting the credit terms and conditions. It is a direct source of information and it is directly proportional to the quality of discussion with the subject matter.

Information gathering is pushed on another step when references about the application’s current bank and other financial institution are sought. This will have the applicant providing financial statements which can be misleading sometimes but this helps in consolidating the information being compiled for the latter.

Types of Credit

Credit is granted to two main types of customer categories:

Individual Customers

This type of credit is granted to a particular individual customer, for their own use and who is not involved in a profit-making activity.

Commercials

Commercial credits are given to business organizations, traders or retailers who for example sell of goods in large quantities or in volume for the sole purpose of making profit in future.

Reasons for granting credit

The main reasons for any company or firm to grant credit are as follows:

To retain old and existing customers

To acquire new customers and new businesses

To increase market share, especially in growing market.

Competitions: When an organization is operating in a highly competitive market it will try to acquire customers in an aggressive manner

Buyer’s requirements: In the business sectors buyers/dealers finance is required for business startup or day-t-day operations. Most of the time this is not readily available, thus the need to take credit facilities.

Relationship with dealers: Firms sometimes extend credit to dealers to forge long and strong relationships with them.

Thus before granting credit to any customer, laid down procedures should be followed. One of the utmost important procedures is to Know Your Customer (KYC)

Know Your Customer (KYC)

Know Your Customer that is identity of customer must be established for examples (Full name, address, and contact number) so as to know who to contact if in case payment is not being effected or in case of default payment. Individual customer should produce Identity Card (ID) and utility Bills (Proof of address, last three months) as proof documents. Corporate bodies as KYC should produce Certificate of Incorporation, Trade License and of course utility Bills.

Undoubtedly, in the credit appraisal process there is nothing more vital to the process of controlling credit risk than knowing your customers which is an ongoing procedure. To get to know customers requires effective communication. Among the main reasons are the ability to identify if there is any money laundering concerning a particular customer and also if the customer is found in a blacklist of bad payers.

For examples: The Mcb/Npf fraud case (Source: http://www.mcb.mu/news)

According to the news broadcasted in February 2003, an accountant of the National Pension Fund (NPF) called at the MCB to take the fixed deposit balance of funds placed by the NPF with the bank. When they told her there was only Rs100 million in the account, she was shocked. Actually the deposited fund should have been around Rs700 million excluded the interest. This is due to lack of internal control. The repercussion of thus case is that Mauritius enters the gray list but fortunately not in the black list.

Other documents to be produced for Individual customers can consist of:

Pay slip (last three months)

Employment Confirmation letter

Bank statement for last six months (for new customers)

Collateral (if property is given as collateral valuation report is needed). As per Bank of Mauritius (BOM) property given as security for a particular facility need to be revaluate each three years.

For Corporate Bodies other documents to be produce d can consist of:

Financial Statement (last two years)

Forecast cash flow for a start-up business.

After having obtained all the KYC and other documents, application form should be filled in and duly signed by the customer along with the MCIB (Mauritius Credit Information Bureau) disclosure form. The MCIB disclosure form is very important as it gives the financial institution the right to inquire on the indebtedness of the customer. Without the customer authorization the financial institution can not retrieve the MCIB, it will be an illegal act retrieving MCIB without customer consent.

Mauritius Credit Information Bureau (MCIB)

Bank’s, Leasing Companies and Insurance (only SICOM) participating in the MCIB will submit information on their customers’ debts. For Insurance Company only SICOM is participating in the MCIB because it is relatively costly to the other insurance companies. But as per Bank of Mauritius all Insurance company will soon be listed in the MCIB database. For commercial banks, it is to be noted that the access to MCIB is free as this facility is given by their regulator, whereas insurance company is being regulated by the FSC (Financial Services Commission). The data submitted are complied in a database of the MCIB and then made available to all commercial banks in Mauritius. It is mandatory for all participating banks to make inquiries in the MCIB database before approving, increasing, or renewing any credit facility

Details that will obtain from an MCIB are as follows:

If the customer is acting as borrower or guarantor

Type of facility granted from other institutions (Loans, credit cards, overdraft, bank guarantee, and letter of credit)

Exchange of credit data with other companies having the same customers

Original amount of facility taken

Outstanding balance that remain to pay

What is the collateral securing the facility (property, insurance policy or fixed deposit)

And lastly if the customer having any arrears (default) with the existing institutions

This will help financial institutions to have a complete picture of the borrower’s overall indebtedness before taking a final decision whether or not to grant the credit applied for.

Company Searches or Search Report

This is very common in banks. Information can be gathered from the search report obtained at the Conservator of Mortgages in the name of the borrower (Individual or Corporate). This piece of information is very important as it shows the overall mortgages in the applicant movables & immovables.

CBRIS (Companies and Business Registration Integrated System)

This facility is being granted by the companies division, Ministry of Finance and Economic Development. The CBRIS give information on corporate bodies, societies and partnerships, if they are operating (status live) or not operating (status wind up).

The importance of the 4Cs

According to Bobby Rozario, (2002) the 4 C’s of credit helps in making the assessment of Credit Risk. They provide a structure within which information could be gathered, segregated and analyzed, thus considering the four C’s:

Capacity

Capital

Conditions and

Character.

The C’s have been extended to five by adding the ‘Collateral’ or extended to six by adding ‘Competition’ to it. No matter how many C’s we come up with, the primary question that remains to be answered is ‘Will I get paid on time’.

For simplicity, it is more appropriate to discuss the structure of credit analysis within the context of the five C’s of credit:

Capacity

Cash and only cash can pay bills. Capacity refers to the customers’ ability to pay. The capacity of any commerce to reimburse its bills would stem from good cash flow.

Capital

Capital would refer to the financial status of the customer. What is he/she worth in term of financial stability? Capital would refer to the financial resources obtained from financial records that a company may have in order to deal with its liability. Very often relationship manager would make this information the most important one. In fact one must know how to examine a financial statement and that too from the point of view of the creditor.

Conditions

Conditions refer to the general economic conditions that may impact on the customer’s ability to pay back his debts. Thus refers to the external impact surrounding the customer’s business. For example the tourism industry might get influenced by the financial crisis and may not have that kind of creditworthiness and ability to pay.

Character

Character refers to the customer’s intention and willingness to pay. People who voluntarily refused to honor their debts (Bad character). The relationship manager should judge whether the customer will make honest efforts to honor their credit responsibility. J.P Morgan (2002), a successful businessman once said that ‘I will do business with anyone as long as he/she is honest!’

As far as character is concerned, in analyzing individual credit, one would consider the following:

Does the customer have a stable job?

Does the customer have a good credit record in the past and present that is any default?

Has the customer previously declared bankrupt?

Does the customer have sufficient income for repayment and what is the source of repayment?

Whereas, in analyzing commercial credit one would consider the following:

Size of business/operation

Where is the location of the business company?

Amount and purpose of facilities and sources of repayment?

Is the business a sole proprietor, corporate bodies or partnertship?

Background information on shareholders, directors, and beneficial owners?

Borrower’s business expertise, and how long in the business?

Any previous insolvency record regarding the company?

The integrity and reputation of the borrower and also if there is any lawsuits pending against the customer?

The repayment capacity of the borrower based on his business plan and projected cash flow.

Collateral

Collateral refers to the guarantees/ security (instruments of risk mitigation) that may be offered in support of a credit in order to mitigate risk. In some cases assets may be necessary and to what extend they are available.

The steps discussed in this section are those followed by financial institutions in Mauritius – mostly commercial banks – in performing the procedures of credit appraisal. After these procedures, a financial institution will be better equipped with information about the customer creditworthiness to move forward on the second stage of credit appraisal also known as the Pre-Sanction stage.

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