a)     Policy and Strategy

b)     Organisational Structure

v     The strategy would, therefore, include a statement of the bank’s willingness to grant loans based on the type of economic activity, geographical location, currency, market, maturity and anticipated profitability. This would necessarily translate into the identification of target markets and business sectors, preferred levels of diversification and concentration, the cost of capital in granting credit and the cost of bad debts.

v  The credit risk strategy should provide continuity in approach as also  take into account the cyclical aspects of the economy and the resulting shifts in the composition/ quality of the overall credit portfolio. This strategy should be viable in the long run and through various credit cycles.

     v Senior management of a bank shall be responsible for implementing the credit risk strategy approved by the Board.

The Risk Management Committee will be a Board level Sub committee including CEO and heads of Credit, Market and Operational Risk Management Committees. It will devise the policy and strategy for integrated risk management containing various risk exposures of the bank including the credit risk. For this purpose, this Committee should effectively coordinate between the Credit Risk Management Committee (CRMC), the Asset Liability Management Committee and other risk committees of the bank, if any. It is imperative that the independence of this Committee is preserved. The Board should, therefore, ensure that this is not compromised at any cost. In the event of the Board not accepting any recommendation of this Committee, systems should be put in place to spell out the rationale for such an action and should be properly documented. This document should be made available to the internal and external auditors for their scrutiny and comments. The credit risk strategy and policies adopted by the committee should be effectively communicated throughout the organisation.

Each bank may, depending on the size of the organization or loan/ investment book, constitute a high level Credit Risk Management Committee (CRMC). The Committee should be headed by the Chairman/CEO/ED, and should comprise of heads of Credit Department, Treasury, Credit Risk Management Department (CRMD) and the Chief Economist. The functions of the Credit Risk Management Committee should be as under:

•      Be responsible for the implementation of the credit risk policy/ strategy approved by the Board.

•      Monitor credit risk on a bank wide basis and ensure compliance with limits approved by the Board.

•     Recommend to the Board, for its approval, clear policies on standards for presentation of credit proposals, financial covenants, rating standards and benchmarks,

•      Decide delegation of credit approving powers, prudential limits on large credit exposures, standards for loan collateral, portfolio management, loan review mechanism, risk concentrations, risk monitoring and evaluation, pricing of loans, provisioning, regulatory/legal compliance, etc.

 Concurrently, each bank should also set up Credit Risk Management Department (CRMD), independent of the Credit Administration Department. The CRMD should:

 Relationship management phase i.e. business development.

Transaction management phase covers risk assessment, loan pricing, structuring the facilities, internal approvals, documentation, loan administration, on going monitoring and risk measurement.

Portfolio management phase entails monitoring of the portfolio at a macro level and the management of problem loans.

On the basis of the broad management framework stated above, the banks should have the following credit risk measurement and monitoring procedures:

·     Banks should establish proactive credit risk management practices like annual / half yearly industry studies and individual obligor reviews, periodic credit calls that are documented, periodic visits of plant and business site, and at least quarterly management reviews of troubled exposures/weak credits.

·        Banks should have a system of checks and balances in place for extension of credit viz.:

• -        Separation of credit risk management from credit sanction

• -        Multiple credit approvers making financial sanction subject to approvals at various stages viz. credit ratings, risk approvals, credit approval grid, etc.

• -        An independent audit and risk review function.

 ·        The level of authority required to approve credit will increase as amounts and transaction risks increase and as risk ratings worsen.

 ·        Every obligor and facility must be assigned a risk rating.

 ·        Mechanism to price facilities depending on the risk grading of the customer, and to attribute accurately the associated risk weightings to the facilities.

 ·        Banks should ensure that there are consistent standards for the origination, documentation and maintenance for extensions of credit.

 ·        Banks should have a consistent approach towards early problem recognition, the classification of problem exposures, and remedial action.

 ·        Banks should maintain a diversified portfolio of risk assets; have a system to conduct regular analysis of the portfolio and to ensure on-going control of risk concentrations.

 ·        Credit risk limits include, obligor limits and concentration limits by industry or geography. The Boards should authorize efficient and effective credit approval processes for operating within the approval limits.

 ·        In order to ensure transparency of risks taken, it is the responsibility of banks to accurately, completely and in a timely fashion, report the comprehensive set of credit risk data into the independent risk system.

 ·        Banks should have systems and procedures for monitoring financial performance of customers and for controlling outstanding within limits.

 ·        A conservative policy for provisioning in respect of non-performing advances may be adopted.

 ·        Successful credit management requires experience, judgement and commitment to technical development. Banks should have a clear, well-documented scheme of delegation of powers for credit sanction.