Entire Section

  • PIB 4 Part 2 PIB 4 Part 2 — Credit Risk Systems and Controls

    • PIB 4.2 PIB 4.2 Application of this part

      • PIB 4.2.1

        This part applies to an Authorised Firm in Category 1, 2, 3A or 5 with respect to both its Non-Trading Book and Trading Book transactions.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

    • PIB 4.3 PIB 4.3 Credit Risk Management Systems

      • PIB 4.3.1 PIB 4.3.1

        An Authorised Firm must implement and maintain comprehensive Credit Risk management systems which:

        (a) are appropriate to the firm's type, scope, complexity and scale of operations;
        (b) enable the firm to effectively identify, assess, monitor and control Credit Risk and to ensure that adequate Capital Resources are available to cover the risks assumed; and
        (c) ensure effective implementation of the Credit Risk strategy and policy.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.3.1 Guidance

          1. Credit Risk is the risk that a borrower or Counterparty fails to meet its obligations. It exists in both the Non-Trading Book and the Trading Book, and both on and off the balance sheet of an Authorised Firm.
          2. Obviously, Credit Risk arises from loans but there are other sources of Credit Risk such as.
          a. trade finance and acceptances;
          b. interbank transactions;
          c. commitments and guarantees;
          d. interest rate, foreign exchange and Credit Derivatives (including swaps, options, forward rate agreements and financial futures);
          e. bond and equity holdings; and
          f. settlement of transactions.
          3. The objective of the Credit Risk management system must be to ensure that every Authorised Firm holds adequate capital to cover Credit Risk and absorb any potential losses arising from that risk. Since Authorised Firms need to provide credit as part of their usual business, this needs to be achieved by effectively managing the Credit Risk assumed by the Authorised Firm as part of its credit business.
          4. Failure to manage Credit Risk effectively could cause an Authorised Firm to face a situation of inadequate capital, which would threaten its safety and soundness. Such problems normally arise from:
          a. lax credit standards for borrowers and Counterparties;
          b. poor portfolio risk management; and
          c. failure to identify in good time changes in economic or other conditions that may impair the financial strength of borrowers and Counterparties.
          5. Therefore, it is essential for Authorised Firms involved in the business of providing credit to design, implement and maintain comprehensive and effective systems to manage Credit Risk.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.3.2

        The Credit Risk management framework of an Authorised Firm must have at least the following principal elements effectively implemented to ensure that the Credit Risk Exposures of the Authorised Firm are of a sufficiently good quality:

        (a) an appropriate Credit Risk environment, defined by a documented Credit Risk strategy and a documented Credit Risk policy;
        (b) application of the Credit Risk strategy and policy, where appropriate, on a consolidated basis and at the level of individual subsidiaries;
        (c) sound processes for assuming and managing Credit Risk;
        (d) prudent lending controls and limits, including policies and processes for monitoring Exposures in relation to limits, and approvals of exceptions to limits;
        (e) adequate appropriately skilled human resources to manage the Credit Risk function;
        (f) independence of credit approval and review functions from credit initiation functions to avoid any real or potential conflicts of interest;
        (g) prudent procedures for approving credits, defined by a documented credit procedures manual;
        (h) effective systems for credit administration, measurement and monitoring; and
        (i) adequate controls over Credit Risk.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.3.3 PIB 4.3.3

        (1) An Authorised Firm must ensure that its Governing Body retains responsibility for the Credit Risk management framework and ensure it is appropriate for the nature, scale and complexity of operations, in the context of prevailing market and macro-economic conditions.
        (2) An Authorised Firm must ensure that its senior management or an appropriate designated body, regularly reviews and understands the implications as well as the limitations of the risk management information that they receive from the Credit Risk management function, in order to evaluate the suitability and effectiveness of such information in enabling them to provide effective oversight over the Credit Risk management function.
        (3) An Authorised Firm must ensure that its Governing Body regularly reviews and understands the implications as well as the limitations of Credit Risk management information and reports presented to it, to ensure that the contents and the format of such reports are suitable for effective Governing Body oversight.
        (4) An Authorised Firm must ensure that its Governing Body is responsible for carrying out regular stress testing on the credit portfolio which is appropriate for the nature, scale and complexity of the Credit Risks assumed by the Authorised Firm. An Authorised Firm must ensure that its Governing Body annually reviews the stress scenarios and takes action to address any perceived issues arising from those reviews.
        (5) An Authorised Firm must establish and enforce internal controls and practices so that deviations from policies, procedures, limits and prudential guidelines are promptly reported to the appropriate level of management.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.3.3 Guidance

          1. An Authorised Firm may structure its credit processes and Credit Risk management function in a manner which suits its or its Group's internal organisational structure, culture and internal practices, provided the key functions and components relevant to Credit Risk management, as mentioned above, are present, and there must be adequate segregation of functions responsible for critical Credit Risk management processes. In particular, the credit initiation function must be independent of the credit approval and review functions to avoid any potential conflicts of interest. In cases where an Authorised Firm finds it necessary to delegate small lending limits to staff in the front office for operational needs, there must be adequate safeguards, e.g. independent review of credits granted, to prevent abuse.
          2. An Authorised Firm's senior management or an appropriately delegated body (such as a credit committee) should be responsible for effectively implementing the Credit Risk strategy and policy approved by the Governing Body of the Authorised Firm. Senior management or such a credit committee will need to establish adequate procedures to identify, quantify, monitor and control the Credit Risk inherent in the Authorised Firm's activities and at the level of both the overall portfolio and individual borrowers/Counterparties.
          3. The appropriate level at which credit decisions are taken will vary according to the type of credit offered and the size and structure of the Authorised Firm. For some Authorised Firms, a credit committee may be appropriate, with formal terms of reference laid down. In other Authorised Firms, individuals may be given pre-assigned authority limits. It will usually be appropriate for the final credit approval authority to be given by staff reporting independently from those staff interacting with clients.
          4. As part of its stress testing programme for Credit Risk measurement, an Authorised Firm should take into account the realistic recoveries available from security or Collateral under stressed market and macro-economic conditions.
          5. PIB Rule 4.3.3 (3) requires the Governing Body of an Authorised Firm to review the management information reports presented to it by the senior management of that firm and assess the reports in respect of their utility and effectiveness in enabling the Governing Body to effectively discharge their responsibilities towards effective oversight of the firm and its credit risk management.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.3.4 PIB 4.3.4

        An Authorised Firm must also consider whether it is prudent to set out specific provisioning requirements for country and transfer risks to which it is exposed.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.3.4 Guidance

          Guidance on country and transfer risk Exposure is set out in PIB section A4.1 (Credit Risk systems and controls) in PIB App4.

          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.3.5 PIB 4.3.5

        Where an Authorised Firm avails itself of Credit Risk mitigations, the Authorised Firm must have mechanisms in place to regularly assess the net realisable value of such mitigations taking into account prevailing market conditions.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.3.5 Guidance

          1. PIB section 4.13 sets out the principles and methodologies for the recognition of Credit Risk mitigation in the calculation of Credit RWA.
          2. Further Guidance on Credit Risk systems and controls (including Credit Risk mitigation), and on the specific areas which the Credit Risk policy should cover, is set out in PIB section A4.1.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

    • PIB 4.4 PIB 4.4 Credit Risk Strategy, Policy, and Procedures Manual

      • Credit Risk Strategy

        • PIB 4.4.1 PIB 4.4.1

          (1) An Authorised Firm must implement and maintain a Credit Risk strategy, which prescribes its stated degree of risk tolerance, level of capital available for credit activities, business strategy for credit activities and Credit Risk management approach.
          (2) The strategy must be:
          (a) documented;
          (b) approved by the Governing Body; and
          (c) regularly reviewed and updated by the Authorised Firm at periodic intervals and at least annually, as appropriate to the nature, scale and complexity of its activities.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

          • PIB 4.4.1 Guidance

            1. An Authorised Firm's Credit Risk strategy should reflect the aim to achieve sound credit quality while ensuring profit and business growth. Therefore the Credit Risk strategy should address the Authorised Firm's approach towards the decision on an acceptable level of risk/reward relationship, after taking into account resource and capital costs.
            2. An Authorised Firm's Credit Risk strategy should allow for economic cycles and their effects on the credit portfolio during different stages of an economic cycle. For example, it should cater for a higher incidence of defaults in the personal loan and credit card portfolios in times of economic recession.
            Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • Credit Risk Policy

        • PIB 4.4.2

          (1) An Authorised Firm must implement and maintain a Credit Risk policy which prescribes all the essential elements of the Credit Risk management system and associated processes.
          (2) The policy must be:
          (a) documented;
          (b) approved by the Governing Body; and
          (c) regularly reviewed and updated by the Authorised Firm at periodic intervals and at least annually, as appropriate to the firm's current financial performance, credit market conditions in its main markets and its Capital Resources position as well the firm's nature, scale and complexity of its activities.
          (3) Any changes to the Credit Risk policy and how exceptions to the policy will be dealt with must be approved by the Governing Body or an appropriately delegated committee of senior management (such as a credit committee).
          (4) An Authorised Firm with one or more branches outside the DIFC must implement and maintain Credit Risk policies adapted to each local market and its regulatory conditions.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.4.3

          The Credit Risk policy must:

          (a) be consistent with the approved Credit Risk strategy, considering a range of factors, including but not limited to an approved degree of risk tolerance, capital allocated to Credit Risks, business strategy and market conditions in its main credit markets;
          (b) provide sound, well-defined Credit Risk norms and criteria for approval of credit applications;
          (c) clearly specify the Exposure limits, product types, business segments, nature of target borrowers and the nature of Credit Risk that the Authorised Firm wishes to incur;
          (d) set out, where appropriate, the amounts and terms and conditions under which Counterparties or clients may be eligible or ineligible for credit;
          (e) include minimum information that is required to be obtained for processing an application for credit;
          (f) include well defined criteria and policies for approving new Exposures as well as renewing and refinancing existing Exposures, identifying the appropriate approval authority for the size and complexity of the Exposures;
          (g) include effective credit administration policies, including continued analysis of a borrower's ability and willingness to repay under the terms of the debt, monitoring of documentation, legal covenants, contractual requirements and Collateral, and a classification system that is consistent with the nature, size and complexity of the Authorised Firm's activities or, at the least, with the asset grading system prescribed in PIB Rule 4.5.4;
          (h) include comprehensive policies for reporting Exposures on an on-going basis;
          (i) include comprehensive policies for identifying and managing problem assets;
          (j) include a provisioning policy approved by the Governing Body which ensures that all loans are promptly and prudently provided for;
          (k) set out limits and approval processes involved for the approval of credit facilities that can be approved by the delegated authorities, and stipulate that the Governing Body retains responsibility for the governance of such limits;
          (l) require that major Credit Risk Exposures exceeding a specified amount or at a minimum all Large Exposures of the Authorised Firm are approved by the Authorised Firm's senior management or its designated body like credit committee; and
          (m) require that all Credit Risk Exposures that are especially risky or inconsistent with the approved credit strategy of the Authorised Firm are approved by the Authorised Firm's senior management or its designated body such as a credit committee.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.4.4

          In relation to conflicts of interest and Related Person transactions, the policy must:

          (a) set out adequate procedures for handling conflicts of interest relating to the provision and management of credit, including measures to prevent any Person directly or indirectly benefiting from the credit being part of the process of granting or managing the credit;
          (b) subject to PIB Rule 4.4.5, prohibit Exposures to Related Persons on terms that are more favourable than those available to Persons who are not Related Persons; and
          (c) if Exposures to Related Persons are allowed on terms which are no more favourable than those available to Persons who are not Related Persons, set out procedures that:
          (i) require such Exposures, and any write-off of such Exposures, exceeding specific amounts or otherwise posing special risks to the Authorised Firm, to be made subject to the prior written approval of the firm's Governing Body or the Governing Body's delegate; and
          (ii) exclude Persons directly or indirectly benefiting from the grant or write off of such Exposures being part of the approval process.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.4.5 PIB 4.4.5

          The prohibition in PIB Rule 4.4.4(b) does not apply to providing credit to a Related Person under a credit policy on terms (such as for credit assessment, tenor, interest rates, amortisation schedules and requirements for Collateral) that are more favourable than those on which it provides credit to Persons who are not Related Persons, provided the credit policy:

          (a) is an Employee credit policy that is widely available to Employees of the Authorised Firm;
          (b) is approved by the Authorised Firm's Governing Body or the Governing Body's delegate;
          (c) clearly sets out the terms, conditions and limits (both at individual and aggregate levels) on which credit is to be provided to such Employees; and
          (d) requires adequate mechanisms to ensure on-going compliance with the terms and conditions of that credit policy, including immediate reporting to the Governing Body or the Governing Body's delegate where there is a deviation from or a breach of the terms and conditions or procedures applicable to the provision of such credit for timely and appropriate action.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

          • PIB 4.4.5 Guidance

            1. The requirements in these Rules do not prevent arrangements such as Employee loan schemes that allow more favourable and flexible loan terms to Employees of the Authorised Firm than those available under its normal commercial arrangements. However, such a loan scheme must comply with the requirements set out in these Rules, which are designed to address conflicts of interest that may arise in the grant, approval or management of such loans. Such conflicts are especially likely to arise where one or more of the Employees concerned are Directors, Partners or senior managers.
            2. Generally, where an Authorised Firm has an Employee loan scheme under these Rules, the DFSA expects its Governing Body to have ensured, before it or its delegate approved that scheme, that the terms, conditions and particularly limits (both at individual and aggregate level) on which credit is to be provided to Employees under the scheme are adequate and effective in addressing the risks arising from such lending. The Authorised Firm should also be able to demonstrate to the DFSA that the procedures it has adopted relating to an Employee loan scheme are adequate to address any risks arising from such lending. The DFSA expects to have access to records relating to lending under an Employee loan scheme upon request or during its supervisory visits. Any significant breach of or deviation from the procedures adopted in relation to an Employee loan scheme may also trigger the reporting requirements to the DFSA under GEN Rule 11.10.7.
            Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.4.6

          For the purposes of the Rules in this chapter, a Person is a "Related Person" of an Authorised Firm if the Person:

          (a) is, or was in the past 2 years:
          (i) a member of a Group or Partnership in which the Authorised Firm is or was also a member; or
          (ii) a Controller of the Authorised Firm or a Close Relative of such a Controller;
          (b) is, or was in the past 2 years, a Director, Partner or senior manager of the Authorised Firm or an entity referred to under (a)(i) or (ii), or a Close Relative of such a Director, Partner or senior manager; or
          (c) is an entity in which a Director, Partner or senior manager of the Authorised Firm or an entity referred to in (a)(i) or (a)(ii), or a Close Relative of such a Director, Partner or senior manager has a significant interest by:
          (i) holding 20% or more of the shares of that entity, or a Parent of that entity, if that entity is a company; or
          (ii) being entitled to exercise 20% or more of the voting rights in respect of that entity;
          except that a Partner is not a Related Person where that Person is a limited partner of a Limited Partnership formed under the Limited Partnership Law of 2006 or any similar limited partnership constituted under the law of a country or territory outside the DIFC.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • Credit Procedures Manual

        • PIB 4.4.7

          An Authorised Firm must implement and maintain a documented credit procedures manual, which sets out the criteria and procedures for granting new credits, for approving extensions of existing credits and exceptions, for conducting periodic and independent reviews of credits granted and for maintaining the records for credits granted.

          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.4.8 PIB 4.4.8

          The credit procedures manual must establish:

          (a) sound, well-defined criteria for granting credit, including a thorough understanding of the borrower or Counterparty, the purpose and structure of the credit and its source of repayment;
          (b) well defined processes for approving new Exposures as well as renewing and refinancing existing Exposures;
          (c) effective credit administration processes, including continued analysis of a borrower's ability and willingness to repay under the terms of the debt, monitoring of documentation, legal covenants, contractual requirements and Collateral;
          (d) effective processes for classification and grading of credit assets consistent with the nature, size and complexity of the Authorised Firm's activities;
          (e) comprehensive processes for reporting Exposures on an ongoing basis; and
          (f) comprehensive processes for identifying problem assets, managing problem assets, monitoring their collections and for estimating required level of provisions.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

          • PIB 4.4.8 Guidance

            The same criteria should be applied to both advised and unadvised facilities and should deal with all Credit Risks associated with the Authorised Firm's business whether in the Non-Trading or Trading Book or on or off balance sheet.

            Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

    • PIB 4.5 PIB 4.5 Processes for Credit Assessment

      • PIB 4.5.1 PIB 4.5.1

        (1) When utilising external credit rating agencies as part of its credit assessment processes, an Authorised Firm must:
        (a) maintain an internal credit grading system; and
        (b) stress test its capital position on at least an annual basis to consider the capital implications to the Authorised Firm of a significant reduction in the credit quality and associated reduction on credit ratings from credit rating agencies for its credit portfolio.
        (2) An Authorised Firm must not solely use external credit rating agency credit ratings as a basis for its assessment of the risks associated with an Exposure, in particular in respect of a Large Exposure, and must at all times conduct its own credit assessment of such an Exposure.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.5.1 Guidance

          An Authorised Firm should closely monitor the adequacy of the internal credit assessment processes, in order to assess whether there is an upward bias in internal ratings.

          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.2

        An Authorised Firm must implement and maintain appropriate policies, processes, systems and controls to:

        (a) administer its credit portfolios, including keeping the credit files current, getting up-to-date financial information on borrowers and other Counterparties, funds transfer, and electronic storage of important documents;
        (b) ensure that the valuations of Credit Risk mitigants employed by the Authorised Firm are up-to-date, including periodic assessment of Credit Risk mitigants such as guarantees and Collateral;
        (c) review all material concentrations in its credit portfolio and report the findings of such reviews to the Governing Body; and
        (d) measure Credit Risk (including to measure Credit Risk of off-balance sheet products such as Derivatives in credit equivalent terms) and monitor the condition of individual credits to facilitate identification of problem credits and to determine the adequacy of provisions and reserves.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.3 PIB 4.5.3

        The Credit Risk management system and, in particular, the systems, policies and processes aimed at classification of credits, monitoring and identification of problem credits, management of problem credits and provisioning for them must include all the on-balance sheet and off-balance sheet credit Exposures of the Authorised Firm.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.5.3 Guidance

          An Authorised Firm should ensure that its loan portfolio is properly classified and has an effective early-warning system for problem loans.

          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.4 PIB 4.5.4

        (1) An Authorised Firm must establish clearly defined criteria for identifying its problem credits and/or impaired assets which ensure that credits are classified as impaired in all cases where there is some reason to believe that all amounts due (including principal and interest) will, or may, not be collected in accordance with the contractual terms of the loan agreement.
        (2) For the purpose of (1), and subject to (3), an Authorised Firm must categorise its credits into five categories as detailed in the following table, where credits in the substandard, doubtful and loss categories must be considered as problem credits:
        Standard includes credits with no element of uncertainty about timely repayment of the outstanding amounts, including principal and interest. Credits are currently in regular payment status with prompt payments.
        Special mention includes credits with deteriorating or potentially deteriorating credit quality which, may adversely affect the borrower's ability to make scheduled payments on time. The credits in this category warrant close attention by the Authorised Firm.
        Substandard includes credits which exhibit definitive deterioration in credit quality and impaired debt servicing capacity of the borrower.
        Doubtful includes credits which show strong credit quality deterioration, worse than those in substandard category, to the extent that the prospect of full recovery of all the outstanding amounts from the credit is questionable and consequently the probability of a credit loss is high, though the exact amount of loss cannot be determined yet.
        Loss includes credits which are assessed as uncollectable and credits with very low potential for recoverability of amounts due.
        (3) An Authorised Firm may also have in place a more detailed credit grading system provided it can address the categories detailed in (2).
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

        • PIB 4.5.4 Guidance

          1. With respect to the ratings above, Authorised Firms should consider Exposures as classified special mention, substandard, doubtful and loss where the loans are contractually in arrears for a minimum number of days of 30, 60, 90-120 and 120-180 days respectively. Authorised Firms should also consider the treatments as set out in PIB Rule 4.5.7 (Evergreening).
          2. Credits exhibiting the following categories should be included in the special mention category.
          (a) a declining trend in the operations of the borrower or in the borrower's ability to continue to generate cash required for repayment of the credit;
          (b) any signals which indicate a potential weakness in the financial position of the borrower, but not to the point at which repayment capacity is definitely impaired; or
          (c) business, economic or market conditions that may unfavourably affect the profitability and business of the borrower in the near to medium term.
          3. Credits exhibiting the following categories should be included in the substandard category.
          (a) inability of the borrower to meet contractual repayment terms of the credit facility;
          (b) unfavourable economic and market conditions or operating problems that would affect the profitability and cash flow generation of the borrower;
          (c) weak financial condition or the inability of the borrower to generate sufficient cash flow to service the payments.;
          (d) difficulties experienced by the borrower in servicing its other debt obligations; or
          (e) breach of any financial covenants by the borrower.
          Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.5

        An Authorised Firm must have detailed policies, processes and resources for managing problem credits which address the following:

        (a) monitoring of credits and early identification of credit quality deterioration;
        (b) review of classification of problem credits; and
        (c) ongoing oversight of problem credits, and for collecting on past due obligations.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.6

        An Authorised Firm must ensure that each and every credit which qualifies as a Large Exposure and is classified as an impaired credit is managed individually. This includes valuation, classification and provisioning for such credits on an individual item basis.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.7

        Any evergreening exercise involving refinancing of past due credits must not result in their being classified as a higher category. In particular, impaired credits cannot be refinanced with the aim of classifying them as standard or special mention credits.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.8

        An Authorised Firm's provisioning policy must specify the following minimum provisioning requirements:

        (a) for substandard assets — 20% of the unsecured portion of the credit;
        (b) for doubtful assets — 50% of the unsecured portion of the credit; and
        (c) for loss assets — 100% of the unsecured portion of the credit.
        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]

      • PIB 4.5.9

        An Authorised Firm must, on a periodic basis, at a minimum monthly frequency, review its problem credits (at an individual level or at a portfolio level for credits with homogeneous characteristics) and review the asset classification, provisioning and write-offs for each of those problem credits.

        Derived from RM111/2012 (Made 15th October 2012). [VER20/12-12]