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III
Table of Contents
INTRODUCTION ................................................................................................1
TARGET MARKET AND PRODUCTS ...............................................................2
1.1 Target Market ............................................................................................. 2
1.1.1 Target Market Corporate and Commercial Bank ................................. 3
1.1.2 Target Market RB ................................................................................ 5
1.1.3 Guidelines ............................................................................................ 5
1.1.4 Responsibilities .................................................................................... 5
1.2 Products ..................................................................................................... 6
1.2.1 Short Term Credit Facilities ................................................................. 6
1.2.2 Term Credit Facilities ........................................................................... 8
1.2.3 Project Finance .................................................................................. 15
1.2.4 Guarantees (Bonds) .......................................................................... 16
1.2.5 Documentary Sight and Usance Letters of Credit .............................. 21
1.2.6 Financing against Shares (FAS) ........................................................ 23
1.2.7 Risk Participation ............................................................................... 24
1.2.8 Islamic Banking Products .................................................................. 27
1.3 Facilities to be taken Over/Swapped from Other Banks/FIs ..................... 27
1.4 Financing against Standby Letter of Credit (SBLC) issued by foreign
banks.............................................................................................................. 28
CREDIT INITIATION ........................................................................................ 29
2.1 Credit Application Package ...................................................................... 29
2.1.1 Standard Credit Application Package (Credits above Rs. 100 M) ...... 29
2.1.2 Simplified Credit Application Package (Credits upto Rs. 100 M) ....... 30
2.2 Responsibility ........................................................................................... 32
2.3 Lines and Special Transactions (One Offs) .............................................. 33
2.3.1 Sub-Allocation/Re-Allocation of Approved Credit Facilities ................ 33
2.4 Risk Rating Systems ................................................................................ 35
2.4.1 Obligor Risk Ratings (ORRs) ............................................................. 35
2.5 Security Classes....................................................................................... 38
2.6 Facility Risk Rating (FRR) Model ............................................................. 40
CREDIT APPROVAL ....................................................................................... 41
3.1 Expected Attributes of Risk Analyst/Senior Risk Analyst .......................... 41
3.2 Expected Attributes of Risk Manager/Senior Risk Manager ..................... 42
3.3 Appointment of Global Relationship Manager .......................................... 43
3.3.1 Responsibility of Global Relationship Manager.................................. 43
3.4 Credit Approval Structure ......................................................................... 44
3.5 Markup parameters .................................................................................. 44
3.6 Credit Approval Process........................................................................... 44
3.7 Supervisory Role ...................................................................................... 45
3.8 Expired Credits ......................................................................................... 45
3.9 Unusual Risks .......................................................................................... 46
3.10 Politically Exposed Entities ..................................................................... 46
3.11 Revaluation ............................................................................................ 46
3.12 Overdue ................................................................................................. 47
DOCUMENTATION AND DISBURSEMENT.................................................... 48
4.1 Documentation Responsibilities ............................................................... 48
4.2 Documentation ......................................................................................... 49
4.2.1 General .............................................................................................. 49
4.2.2 Lodgment ........................................................................................... 51
4.2.3 Temporary Release ........................................................................... 51
4.2.4 Permanent Release ........................................................................... 52
4.2.5 Expired Documentation ..................................................................... 52
4.2.6 Copies in Credit Files ......................................................................... 52
4.2.7 Witness .............................................................................................. 52
4.2.8 Minimum Prescribed Documents for Fund based Facilities ............... 53
4.2.9 Assigned Contract Proceeds – Acknowledgement ............................ 53
4.2.10 Letter of Guarantee (Company) ....................................................... 53
4.2.11 Deferrals of Security/Support Documentation .................................. 54
4.2.12 Facility Offer Letter (FOL) ................................................................ 55
4.3 General Rules .......................................................................................... 56
4.4 Facility Utilization...................................................................................... 62
4.5 Execution of Agreement ........................................................................... 62
VENDOR MANAGEMENT ............................................................................... 63
5.1 Purpose .................................................................................................... 63
5.1.1 Valuator ............................................................................................. 63
5.1.2 Muccaddam ....................................................................................... 63
5.1.3 Clearing and Forwarding Agents ....................................................... 64
5.1.4 Business Information Report Provider ............................................... 64
5.2 VMC Definition and Constitution .............................................................. 64
5.3 Enlistment of Vendors .............................................................................. 65
5.3.1 Scrutiny of Vendors Enlistment .......................................................... 65
5.4 Addition of Regions .................................................................................. 67
5.5 Evaluation of Vendors .............................................................................. 67
5.5.1 Performance Evaluation of Vendors .................................................. 67
5.5.2 Suspension ........................................................................................ 69
5.5.3 Delistment .......................................................................................... 70
5.5.4 Vendors Delisted/Re-Instated by PBA/UBL ....................................... 70
5.6 Services of Vendors ................................................................................. 70
5.6.1 Management of Muccaddam Allocation ............................................. 71
5.6.2 Business Information Report Service Provider .................................. 71
5.7 Limit Enhancements ................................................................................. 73
5.7.1 Limit Enhancement - Valuator/Muccaddam ....................................... 73
5.7.2 Limit Enhancement- C&F Agents....................................................... 74
5.8 One-Off Approval - C&F Agents ............................................................... 74
CREDIT MAINTENANCE ................................................................................. 75
6.1 Credit Process .......................................................................................... 75
6.1.1 Administration of Approved Credit Facilities ...................................... 75
6.1.2 Maintenance of Credit Information ..................................................... 87
6.1.3 General Guidelines ............................................................................ 88
6.2 Annual Review and Renewals .................................................................. 89
REMEDIAL MANAGEMENT ............................................................................ 91
7.1 Credit Classifications Responsibility ......................................................... 91
7.1.1 Watchlist ............................................................................................ 91
7.1.2 Adverse Classification ....................................................................... 92
7.2 Classifiable Exposure ............................................................................... 95
7.3 Excluded Credit Exposures ...................................................................... 95
7.4 Initiating or Changing Adverse Classifications ......................................... 95
7.5 Remedial Action/Strategy ......................................................................... 96
7.5.1 Formal Action Plan ............................................................................ 97
7.5.2 Documentation Review ...................................................................... 97
7.5.3 Classified Credit Reviews (CCRs) ..................................................... 97
7.6 Provisions ................................................................................................. 99
7.6.1 Specific Reserves .............................................................................. 99
7.6.2 General Reserves ............................................................................ 102
7.6.3 Frequency ........................................................................................ 102
7.7 Responsibility/Reporting ......................................................................... 102
7.8 Special Assets Management .................................................................. 103
7.8.1 Transfer of Accounts to SAM/SAM RCADs ..................................... 103
7.9 Recovery Process .................................................................................. 105
7.9.1 Traditional Work Out Modes ............................................................ 106
7.9.2 Non Traditional Work Out Modes..................................................... 108
7.9.3 Litigation .......................................................................................... 110
7.10 Write-offs .............................................................................................. 110
7.10.1 Write-off Mechanism ...................................................................... 110
7.11 Condonation and waivers ..................................................................... 111
List of Annexures ......................................................................................... 112
Abbreviations
Business Head: Senior position looking after a region/center and above in their
respective area i.e. Corporate, Commercial, Agri etc.
Credit Policy and Procedures updated in 2006 has been separated and updated
to form two separate documents; Credit Policy and Credit Manual. Credit Policy
2013 has been recently formulated and approved by Board Risk Management
Committee (BRMC)/Board of Directors (BOD) while this Credit Manual is now
separately formulated. This document defines procedural guidelines for products
and lending cycle from credit initiation to remedial management.
This document has been created keeping in view the current requirement at the
Bank which will aid in seamless accomplishment of implementation of the Credit
Policy rules and guidelines.
R&CP is the owner of this document while the process and procedures laid out
here are owned and followed by all concerned departments handling credits.
Guidelines described in this document are minimum requirements under normal
circumstances. However, R&CP may make amendments or establish additional
controls whenever appropriate.
Review Period
This document will be reviewed after three years as a whole. Meanwhile, any
amendments can be made from time to time, if required.
It is important for the business groups (such as Corporate & Commercial Bank,
Retail Bank, etc.) and risk group to identify and develop target markets and
formulate business strategies.
Different business groups which are writing assets in the bank are operating in
different market conditions and geographies. They are catering to different
industry sectors and various sizes of customers. It is therefore essential to
formulate clear Target Market identification for smooth handling of customers
and managing the credit risk appropriately.
Product Identification – there are certain given products for lending in the
prevailing banking system and these products are being utilized by the
customers in best possible way. However, only through a comprehensive survey
of the market, can a potential business opportunity be identified. New product
development on an ongoing basis is important and the bank will endeavor to do
so.
It is also important to note that the Bank has a large existing Loan portfolio which
was build up over decades without any RAC screening. Once the RACs are
For fresh customers being booked in various industry sectors the mapping
against existing RAC hurdle (where available) of that industry will be highlighted
in the Credit Application and relevant CC may evaluate the risk and mitigate it
through better facility and security structure.
For any industry sector where an appropriate RAC has not been developed,
Business Groups and relevant CC will decide how to assume additional risk in
that industry sector.
The current target market definition for various business groups is given as
follows:
Corporate Bank
The target market for Corporate Bank will be the corporate clients/commodity
finance in all industry sectors of the country and in the areas where the
Corporate Centers are present. In these areas the attributes of clients will be:
Clients handled other than the Corporate Centers region, even if their exposure
falls under the Corporate Bank target market, shall be handled by Commercial
Bank mainly through Commercial Centers. However, if special circumstances
arise and customer’s willingness is obtained, the Group Executive–Corporate &
Commercial (GE-Corp & Com) can transfer the relationship handling to
Corporate Bank; to be handled on a remote basis.
All multinationals will fall under Corporate Bank target market (Multinationals are
defined as: Companies with 50% ownership of foreign entity and the foreign
entity operates in multiple countries).
Any fresh client which is required to be booked by Corporate Bank and falls
under Commercial Bank target market of the concerned city will require No
Objection Certificate (NOC) from Head Commercial Assets.
Exceptions to the above will be decided by GE-Corp & Com on case to case
basis keeping in view other parameters of the customer.
Commercial Bank
Target market for Commercial Bank will include facilities above Rs. 15M for
Commercial, Seasonal, Facilities against Liquid Securities, all Product Program
Manual (PPM) based facilities above Rs. 15M, Medium Enterprise and Trade
related lending as per the Prudential Regulation (PR) and exposure handling
requirement of State Bank of Pakistan (SBP) respectively for each segment.
This will also cover all industry sectors of the country.
Any fresh client which is required to be booked by Commercial Bank and falls
under Corporate Bank target market will require NOC from Regional Corporate
Head of the concerned region of Corporate Bank.
Exceptions to the above will be approved by GE-Corp & Com on a case to case
basis keeping in view other parameters of the customer.
International target market will be derived by Head of Risk International & GE-
Risk International and concurred by GE/GH-R&CP.
Target Market for RB will include Small Enterprise customers - less than and
equal to Rs. 15M (aggregate of all banks), Agri Customers and Consumers.
These customers will be handled by branches residing in various regions.
1.1.3 Guidelines
1.1.4 Responsibilities
Ownership of given Target Market lies with each Business group and changes
required need to be discussed and finalized with GE/GH-R&CP.
Credit Proposals need to be in line with target market screens. RAC screen
scoring and respective hurdle scores become effective for those industries
where industry studies have been completed and RAC are in place. This will
mainly be for Corporate and Commercial Bank.
Bank offers wide variety of products including short term credit facilities, trade
products, term credit facilities and Islamic banking products. While Credit Policy
defines products offered by the bank in detail such as NICF, FAFB, FAPC, ERF,
LTFF etc., procedural matters where further explanations are required are
detailed as under:
1.2.1.1 Foreign Bills Purchased – against letter of credit (FBP) and FBP
(Disc)
If documents are complete but not in compliance with the terms of LC,
documents will be purchased with full recourse on exporter and exposure will be
booked on “Customer” against discrepant lines (FBP Disc).
Import documents received under sight L/C are lodged in PAD, and are retired
upon payment including markup (on PAD) from the customer. Import documents
Facility for financing goods imported under sight letters of credit established by
the Bank may be extended at customer’s request. Following procedure shall be
followed for FIM transactions:
PAD will remain outstanding and FIM will not be booked until the goods are
physically handed over to the Bank’s Muccaddam and placed under pledge.
However, in case, LC is being retired through FE-25 (import) loan, goods cannot
be taken under pledge at the time of booking of liability. In this case FE-25 Trust
receipt (TR) facility will be allowed, subsequently, FE- 25 (TR) will be transferred
to FE- 25 Pledge within a maximum period of 20 days.
If partial shipments are allowed under LC, FIM will also be booked in tranches.
The Muccaddam shall submit a stock report in order to calculate the drawing
power limit (DPL) and simultaneously the FIM limit should be input into the
In cases where marine insurance does not cover transit insurance, separate
transit insurance in addition to port to port insurance should be obtained.
Customers will be required to maintain sufficient funds in their accounts with the
bank for issuance of a pay order (PO)/cashier’s cheque or otherwise provide a
PO/cashier’s cheque for payment of custom duty and other charges, so that
C&F Agent can clear goods and hand over the consignment to Bank’s
Muccaddam. RCAD will nominate and coordinate with muccaddam in
consultation with Head RCAD North/South (alternatively in consultation with
Country Head CAD) for pledge of stock.
In cases where FIM is booked under sight LC and it has to be retired by bank’s
own approved facilities (FE-25 or PKR) for the client, RCAD will appoint
muccaddam simultaneously with the C&F agent with clear instructions to
muccaddam to take control of goods from the port once handed over by C&F
agent. RCAD will provide details of such goods taken up by muccaddam:
Financial Forecasts
1. All Credit proposals for long term loans or financial guarantees, Standby
Letter Of Credit (SBLC) and/or usance letters of credit/deferred payment with
tenor for more than one year must be accompanied by financial projections
including balance sheets, profit and loss, and cash generation statements
with assumptions covering the tenor of the facility. In addition to financial
forecasts, term loan proposals will also require project feasibility; and
2. Financial Projections are not required for contingent exposures covering bid,
performance, and advance payment bonds with tenors of three years.
However, if the tenor exceeds three years, projections must be obtained.
The loan agreement shall contain the following default clauses in addition to
general default clauses and breach of any of these clauses would cause prompt
remedial action or loan may be recalled;
Exceptions, if any, (for 1 and 5 only) shall require approval of relevant CC.
Standard Covenants
All funded term credit facilities must be documented through an appropriate loan
agreement drawn up and reviewed by the Bank’s legal counsel on panel. Such
loan agreements must include the following provisions:
Borrowers will furnish the Bank with audited financials within maximum 180
days after close of financial year;
A material adverse change clause among the conditions precedent;
A definite date for the termination of the availability period;
Unless waived by the concerned GE/GH, commitment fee should be included
as a part of the compensation;
Borrower will maintain leverage ratio as prescribed by SBP and current ratio
as per bank’s policy;
Bank will arrange valuation of assets by a UBL enlisted valuator, nominated
by RCAD (in case of syndicated loan, valuation to be carried out by the PBA
approved valuators nominated by the lead bank);
Borrower will maintain its project assets adequately insured against all
standard risks;
Borrower will promptly pay all obligations to Bank and other agencies, such
as government taxes, dues etc.;
Borrower will not create lien, mortgage, or encumbrance over its assets
without written consent of Bank;
RCAD shall ensure that these terms and conditions are mentioned in the Loan /
Finance Agreements.
Documentation Review
General Conditions
Under these rules, any change in the terms and conditions or covenants of a
term credit as originally approved must be referred to the original level of
approval. Any unused commitments, except as provided for under the rules for
sub-allocation of credit facilities, can only be utilized for the purpose originally
approved, and cannot be intended to accommodate other needs. Unused
commitments no longer necessary for the purpose originally approved must be
cancelled.
All fresh Corporate Bank customers (For name clearance) or Long term Loans to
existing Corporate customers (where IBG is not involved) shall be initiated by
Corporate Bank through an Engagement Committee Approval (“ECA”) for a
given client.
Ownership of the ECA (Syndication) lies with IBG which acts as the custodian of
the ECA document and the process and is responsible for following up on its
progress. IBG is also primarily responsible for addressing any queries that may
be raised by relevant signatories to this document and in this process may enlist
the assistance of asset writer as considered necessary.
The ECA shall typically cover the following important aspects of a transaction:
1.2.2.4 Syndications
Syndication activities are divided into Primary (i.e. up to financial close) and
Secondary (i.e. post financial close) distribution.
All Syndication transactions shall be routed through the IBG. IBG will be
responsible for:
ECA (Syndications) ;
Transaction structuring;
Syndications that are led by the Bank shall be jointly handled by IBG and
relevant asset writer. FIs will be involved whenever required. In such cases,
asset writer participates and IBG arranges the remaining amount of syndicate
through additional contribution from other FIs.
Syndications that are led and arranged by other FIs in which UBL participates as
a minor or major participant, shall be jointly handled by IBG and relevant asset
writer.
Where Syndication involves sell-down of all or part of the Bank’s exposure post
financial close, the following procedure shall apply:
1. The terms of a sell-down, including the amount, pricing and timing, shall be
jointly agreed between the relevant asset writer and IBG;
2. Subsequently the relevant asset writer shall formally request IBG to affect a
sell-down after obtaining the prior endorsement of the CC including Head
CRM/GE/GH-R&CP;
3. The sell-down request, once provided to IBG, shall be considered
irrevocable. Exceptions, if any, to be approved by the CC including Head
CRM/GE/GH-R&CP; and
4. IBG shall endeavor to achieve the subject sell-down as per approval
requirements.
3. The credit package will be signed off by both IBG and Corporate Bank;
6. From that point forwards, IBG will act in an advisory capacity but will continue
to independently monitor project progress. In any event, IBG support would
remain committed and available as and when required by Corporate Bank.
The guarantee must be issued as per approved text and formats by in house
legal counsel or vetted by a counsel nominated by legal division;
The guarantees must be signed by TPC authorized attorney holders;
The guarantee must be for a clear, well-defined purpose and for a specific
amount and period and shall contain claim lodgment date as per policy;
The text of the guarantee will have a reference to the underlying contract
agreement stipulating the Bid or Performance Bond or Advance Payment
Guarantee etc. as the rationale for issuing the guarantee;
Payment under the guarantee will be made upon beneficiary’s request or
upon presentation of an agreed document (viz statement of claim) or set of
documents along with guarantee in original, if claim is lodged within validity
of the guarantee;
The guarantee shall state the maximum amount of the Bank’s commitment in
clear terms both in figures and in words; and
The guarantee must have a specific expiry date, and all claims must be
lodged before the expiry date. In case of deviation, approval as per Credit
Policy shall be required.
Type of guarantee;
Unusual conditions which could create unforeseen circumstances;
Extent of Bank’s obligation; and
Financial liability under the guarantee.
2. After the guarantee has been issued, a copy of the same will be attached to
the counter guarantee executed by the customer along with a copy of the
guarantee signed by the customer for record. Standard text of Letter of
Guarantees (LGs) attached (Annexure II).
3. Undertaking shall be obtained from the customer that cash margin will not be
released until original LG or letter of disclaimer is obtained from the
beneficiary.
Sometimes business units extend credit facilities to their customers and/or issue
guarantees/bonds on the strength of a “Counter Guarantee” issued by a bank or
other FI having FIRMU approved “Guarantor” lines.
Procedural Guidelines
In both cases, a DAC will be issued by the RCAD to cover the transaction.
However, as per practice, the business units do not reverse the liability unless
the original instrument is received back duly cancelled, or a letter of disclaimer is
received from the beneficiary. This results in an unnecessary accumulation of
contingent liabilities as the beneficiaries fail to return the original guarantee after
its expiry date, or sometimes the original guarantee is lost.
Phase 1
Phase 2
After having completed the above exercise and for the purpose of settlement of
each case following action to be undertaken:-
A formal letter (as per Annexure III) to be sent to the beneficiary stating, inter
alia, that no claim has been lodged with the Bank by the beneficiary in terms
of the guarantee during its validity period and that the guarantee has expired
and the Bank stands released and discharged of any liability under the
Transfer the contra liability and park it in the expired LG by reducing its value
to PKR One after a period of 30 days from the date of the final reminder letter
sent by registered post and courier service;
Refund the margin, if retained and release the securities after obtaining:
Indemnity drafted by the Chief Legal Council (CLC)/Legal Division from
the customer (Annexure VI);
Approval from relevant CC.
All securities including margin, securing the LG shall be released only after
obtaining the approval of the relevant CC.
If imports into third countries are required, line descriptions should clearly state
port/country of destination, items to be imported/procured etc.
Conditions
100% cash margin will be required for Import of perishable items and
chemicals. For relaxation of margin requirement specific approval of CC will
be required;
LC for import of banned items will not be established;
It will be ensured that specific approvals are obtained for third party and third
port/country L/Cs from the relevant CC;
TR shall be obtained to protect bank’s interest;
Margin requirements shall be determined by the bank taking into account the
risk profile of the customer;
Business Units/CC must ensure:
Adherence to margin restrictions stipulated by SBP/Central Banks at
Overseas Centres;
Demand and turnover of the product/commodity in the market;
Durability, salability and estimated realizable value of
merchandise/commodity being imported;
Custom duties and import tax structure;
Financial strength of the customer;
Customer Documentation
In all cases involving shipping guarantees, the customer will sign standard
shipping guarantee application that includes an irrevocable undertaking that the
related shipping documents, when received, will be accepted unconditionally,
regardless of discrepancies.
Missing Invoices
In case of documentary collections when the invoices are not available with the
Bank, the value of merchandise for issuance of shipping guarantees against
cash margin/cash collateral as per policy will be established on the basis of
supporting documents relating to price along with an undertaking to indemnify
the bank in case of any fluctuation in price resulting in a shortfall in value. Limit
for issuance of shipping guarantees are required to be approved by CC and will
be made available by RCAD.
Open Ended
The requirement for a fixed expiry date will be considered waived in all cases
since carriers and Customs Department do not accept shipping guarantees with
a stated expiration date.
Decontrol
The original B/L should be kept in the file to serve as evidence in the event the
shipping agent inquire or call on the shipping guarantee. CC approval for the
amount of the transaction should be taken.
To manage credit risk on account of FAS facility, Market and Treasury Risk will
issue list of approved shares. It will be responsibility of Market and Treasury
Risk to ensure market liquidity for sell off in case margin calls are not met.
If the margin held falls below 20% and the customer does not replenish the
shortfall after three margin calls bank will sell the shares of the customer to
reduce the outstanding after obtaining approval from GE-Treasury & Capital
Markets under intimation to respective Business Unit.
1.2.6.1 Documentation
‘Risk Participation’ is used by banks to allow other bank or banks to share risks
and returns of a financial transaction. Under this product a Grantor bank may
invite a Participant bank to participate in the risk of an Obligor via a transaction.
The Obligor would be the instrument issuing bank and the instruments may be
(but not limited to) L/C, Promissory Note, Trade Advance, Bills, Banker’s
Acceptance, Buyer’s Credit or a Guarantee; or as the beneficiary of a
Syndicated Facility or a Term Loan, the Grantor may offer to the Participant
Unfunded or Funded Participations.
UBL may act as a Grantor or as a Participant in the above defined product. The
Participant may participate in the transaction with the primary risk being that of
non-payment by the Obligor to the Grantor. The Participation may be on the
following two bases:
When Participant buys the risk it funds the Grantor for an amount equivalent to
the amount of participation either via a direct remittance or a treasury placement,
as collateral which is an additional risk on the Grantor besides taking exposure
on obligor in the underlying transaction. Following examples below show credit
exposure of UBL as a Grantor as well as a Participant in funded risk participation
transactions:
Examples
i. UBL as Grantor
Grantor UBL
Participant Soneri Bank
Obligor HSBC (LC issuing Bank)
Transaction Nature Funded Participation in LC Discounting
Transaction Amount USD 30M
Participation Amount USD 15M
Security (Placement) None with UBL
Pre RP transaction, UBL will book Short Term Trade (STT) exposure of USD
30M on HSBC. Once UBL sells 50% of the exposure to Soneri Bank, credit
exposure of UBL on HSBC will reduce to USD 15M. There will be no net
exposure on Soneri Bank as they would already have provided funds to the
obligor through us.
When Participant buys the risk, it does not fund the Grantor and in case of
default by the Obligor, Participant bank irrevocably and unconditionally
undertakes to pay to the Grantor within a reasonable period (usually defined in
the Master Agreement) of the Grantor’s first written demand an amount equal to
the relevant Participation portion. Following examples show credit exposure of
UBL, as a Grantor as well as a Participant in un-funded risk participation
transactions:
i. UBL as Grantor
Grantor UBL
Participant Mashreq Bank
Obligor Citibank (LC issuing Bank)
Transaction Nature Un-Funded Participation in LC Confirmation
Transaction Amount USD 15M
Participation Amount USD 6M
Security (Placement) None with UBL
Pre RP transaction, UBL will book STT exposure of USD 15M on Citibank. Once
UBL sells 40% of the exposure to Mashreq Bank, credit exposure of UBL on
Citibank will reduce to USD 9M and we will have a STT exposure of 6M on
Mashreq Bank.
Once UBL buys 50% of the exposure from Barclays Bank, it will book USD 5M
STT exposure on South East Bank.
Whenever credit facilities are being taken over/swapped from another bank/FI,
the following guidelines are to be followed:
Currently two SCA packages exist. The SCA package is used for credits above
Rs. 100 million (above $1M for international credits). The Simplified Credit
Application Package is used for credits upto Rs. 100 million (upto $1M for
international credits). Both packages contain several documents which are listed
in the subsequent sections.
The SCA package (Annexure VII) for initial extensions of credit and for annual
reviews is expected to contain a comprehensive appraisal for the relationship.
The application should be accompanied by a set of supporting documents,
collectively described as the SCA Package, comprising the following:
1. Executive Summary;
2. SCA;
3. Facility Appendix;
4. Basic Information Report;
5. Comparative position of financial statements;
6. Obligor Risk Rating (ORR) sheet;
7. Facility Risk Rating (FRR);
8. RAC, where applicable;
9. Borrowers Basic Fact Sheet;
10. Credit Information Bureau (CIB) report on the customer and group
companies, where applicable;
11. BRR report, where available;
12. SBP observation/annexure, if any;
13. RCAD’s observations sheet, if any;
14. Valuation Report and Desktop Valuation Report where applicable;
The Simplified Credit Application package for credits below Rs. 100M (Annexure
VIII) comprises of the following documents.
After implementation of Loan Origination System (LOS) all Corporate SCAs are
required to be routed and approved on LOS, while all Commercial and RB cases
will gradually be taken on LOS system due to long transition period and large
number of customers.
Presentation
Annexure VIIE and VIIID include detailed guideline to present the analysis in
accordance with the complexity of the transaction, the customer’s financial
position, and the degree of risk involved. Presentations are expected to be
complete, and no essential elements are to be omitted. Current Ratio shall be
calculated as per Annexure IX.
2.2 Responsibility
Business Units will be responsible for credit initiation and for accuracy of
information in the SCA package. Preparation of the SCA package will involve the
following broad steps:-
RCAD to:
Assign a routing number (log in routing register), and ensure that all relevant
documents are attached, e.g. BIR, BBFS, CIB report, Bank/Market Checking,
Financials, etc. and CAD Issues Sheet (if any). In case of electronic routing,
a unique credit application number is assigned by LOS to each credit
application.
Initial all pages of facility appendix (for LOS cases RCAD to check on
system);
RCAD should sign the check list of documents attached (For LOS cases
RCAD to ensure complete check list is uploaded in the system);
Check BBFS and ensure that all fields are filled by RM;
The DAC will be issued after all documentation formalities for the facility
to be sub-allocated have been completed;
All regulatory requirements that apply to the sub-allocated line have been
met;
Risk of new/ increased facility is equal to or lower than the risk of the
facility prior to the change i.e. from Fund Based to Non-Fund Based;
Tenor of the new or increased facility is equal to or shorter than the tenor
of the previously approved facility;
The facilities are for any related borrower of equivalent risk within the
same customer group relationship, provided cross company guarantees
are obtained. Sub-allocation may also be allowed to associated concerns
of sole proprietorship and partnership firms if required criteria are met.
For sub-allocation to any group concern comprised of Limited
Companies, it will be ensured that the particular group concern complies
with all applicable PR for the level of exposure being sub-allocated; and
S.NO. FROM TO
ERF – I, II, FAPC, FBP-A/C
L/C Sight, LC-DA, FAFB
1. NICF (Pledge/Hypo)
L/G (with a tenor not more than
one year)
L/C – Sight
2. L/C-DA L/G – (with a tenor not more than
6 months)
Non-funded lines as specified in
Credit Policy.
Funded lines as specified in
3. Non-Funded Lines (e.g. STT,
Credit Policy.
guarantor line or custodian line or
intermediary line or vice versa)
considered as equal risk
In addition to the above, Head FIRMU may also approve allocation, sub-
allocation by blocking approved line of same risk on one off basis.
2.4.1.1 Methodology
The ORR is evaluated using the ORR Grid for Corporate, Commercial, SE, ME,
Individuals and FIRMU (Annexure XIII, XIV, XV and XVI). The following
guidelines may be used to arrive at the numerical ORR for a particular borrower
(further details for calculation of Corporate/Commercial, SE, ME and Individuals
are provided in Annexure XVII):
Step 1: Map the customer’s characteristics against the Rating Factors and
allocate the appropriate score to each characteristic.
Step 2: Make a sum total of all marked characteristics.
Step 3: Map the sum total of all factors to arrive at final ORR of the customer.
ORR 1 - This highest rating is reserved for a handful of multinational and large
institutional customers. Customers with this rating should have unusually solid
and stable profitability, liquidity, and debt coverage in the past and are projected
to continue this performance over the long term.
ORR 4 - Customers portray operational and financial stability over a three to five
year time horizon, but are more likely to be weakened by adverse business,
financial or economic conditions than customers with stronger ratings.
ORR 6 - These customers face more uncertainty over future operating cash
flows, and are often under stronger competitive pressure. Their future over the
next three to five years, in both good and bad times, is less well safeguarded by
operational and financial performance, with smaller margins of protection on
principal repayments and interest.
Customers which are watchlisted due to subjective or above factors and have
delayed payments by 16 to 29 days (16-59 for SE customers) will fall in this
category.
Customers which are watchlisted due to subjective or above factors and have
delayed payments by 30 to 59 (60-89 days for SE customers) days will fall in this
category.
ORR 11 - Customers with Credit Rating 11 are of very poor standing with little
prospect for improvement. Principal recovery will require rigorous remedial
management. Customers under the Doubtful category as defined under the
SBP’s PR (i.e. where mark-up/interest or principal is overdue by 180 days or
more from the due date (1 year or more for SE customers) would also fall under
this risk rating.
ORR 12 - This risk rating clearly recognizes and measures assets impaired due
to loss of principal (which may be partial) as well as mark-up, thus justifying the
provisioning for the same. Customers under the Loss category as defined under
the SBP’s PR (i.e. where mark-up/interest or principal is overdue by one year or
more from the due date (18months or more for SE customers) would also fall
under this risk rating or trade bills (import/export) bills or inland bills are not
paid/adjusted within 180 days of the due date.
CRM/CC must reassess the ORR whenever a review event (frequent overdues,
deferrals, material adverse change in the company or industry) occurs, and if
appropriate, the ORR must be revised/downgraded. The outcome of the review,
including details of major issues to resolve, should be recorded. Further, ORR
should be downgraded if the deferrals are outstanding for more than 1 year.
In case of credit limits approved for FIG and TCM, the review of ORR should be
done annually for the banks with which permanent credit limits are in place.
The following security classes have been identified which would be subject to
review with the changing market dynamics:
Class I:
Class III:
Class IV:
Class V:
Token/Registered Mortgage;
Pledge of goods financed by UBL; and
Lien on import documents under Sight LCs.
Class VI:
Equitable Mortgage;
Hypothecation of stocks and receivables;
Hypothecation over plant and machinery; and
Others (TRs etc.).
MIS would be developed to reflect all security fields for necessary reporting and
monitoring.
In line with efficient risk management practice, FRR Model has been formulated
for implementation. FRR comprises of two components; risk associated with the
type of collateral and facility itself. The model (Annexure XVIII) has been devised
to meet various types of transactions comprising of single facility to multiple
facility structure. Usually customers avail multiple facilities, this model also
enables us to calculate facility wise FRR as well as aggregate FRR of the
customer.
The purpose of this model is to outline a criterion that truly reflects expected loss
of exposure (in the event that default has occurred) of each facility as well as of
aggregate facilities. It is aimed to have lending risks properly identified to aid risk
approving process and reflect true credit quality. Calculation methodology for
FRR Model is defined in Annexure XVIII.
This Model shall be applicable with immediate effect. Till the time the Model is
incorporated in LOS, FRR Sheet as per the attached annexure shall be prepared
manually and attached with the SCA in LOS or sent as a hard copy/scanned
copy to the sanctioned authority.
Risk Analyst;
Senior Risk Analyst;
Risk Manager; and
Senior Risk Manager.
Credit approving authority may be delegated to Senior Risk Manager jointly with
Risk Manager.
There are some large business groups which spread their business operation in
various countries, business relationship groups. For these Customers, GE-Corp
& Com/RB/International/GH-Islamic Banking will appoint Global Relationship
Manager (GRM) based on the following factors:
Accessibility;
Strength of the relationship;
Complexity of relationship; and
Amount of facilities extended.
To manage issues pertaining to all group accounts at various locations, deal with
Non-Performing Loan (NPL) management and account monitoring. SCA of the
group will require GRM’s input and signature in addition to respective RM(s).
RM should clearly write the frequency of mark-up collection from customer in the
Facility Appendix. CC is required to approve the proposed frequency under
following guidelines:
1. All long term loans should have mark-up reset and payment frequency linked
with respective KIBOR. Markup payment frequency should be at least
quarterly. In case higher frequency is proposed specific CC approval shall be
required, subject to clearance of regulatory requirements;
2. All short term facilities should have mark-up reset and payment frequency by
customer linked with the tenor of KIBOR (for example, for 1 month KIBOR,
monthly reset and payment of mark-up). Deviation will require specific CC
approval;
3. All money market lines (MMLs)/deals should have repayment of principal and
mark-up paid simultaneously by the customer at the maturity. Any exception
will require CC approval; and
4. Regulatory requirement to be complied with in all cases.
Decline
In case the credit is declined, the authority signing last (upto the level of Senior
Risk Manager) will provide the decline memo while sending SCA/Credit Memo
back to RCAD. Memo shall contain comments on:
Decline memos shall be required upto the level of Senior Risk Manager. RCAD
shall route such decline memo along with the declined proposal to Head CRM/
GE/GH-R&CP directly for review.
Approval
Where credits are approved the approval conditions (if any) need to be clearly
outlined and RM/RCAD are required to adhere to them.
In order to ensure controls and maintain proper records, approvals via emails
should be avoided unless it is an urgent transaction. In such cases, RCAD is
required to disseminate information to all concerned. Additionally, RCAD is
required to perform checks post approval with respect to PR, Bank’s Credit
Policy and/or any other regulations issued by SBP and highlight discrepancies, if
any. Copy of email shall be kept in Credit File for reference by RCAD.
All Credit approvers are required to review the approved credits of their one level
down credit approvers by reviewing samples on quarterly basis. This is
applicable till the level of Head CRM (meaning the final level reviewing one level
down credit approvals will be Head CRM).
Under these circumstances where credit has been reviewed and approved by
the CC, RCAD will issue conditional DAC, with the memo to the respective
branch, highlighting the exception and advising that debit shall not be removed
without prior approval from RCAD. For this, only the expiry of the credit must be
changed and the new expiry of the approval is to be inserted in the system and
debit of limits shall remain blocked.
While RCADs will provide MIS of credits which are expired and will be expiring in
the coming months to all concerned, it is a joint responsibility of Business and
CRM to have expired credits at low levels, all the time.
1. Credit transactions with tenor longer than the stipulated period as per policy;
2. Term Loans having:
Bullet payment at maturity (loans exceeding one year tenor); or
Grace period in excess of 2 years;
3. Lending for the purpose of providing equity to a business;
4. Issuance of open-ended guarantees and/or guarantees which may be
extendible at the sole option of the beneficiary and guarantees with auto-
renewal clause (ARC); and
5. Concentration of collateral with limited marketability.
Approval level:
1, 2 and 3 – GE/GH-R&CP.
4 and 5 – one level higher than relevant CC.
Guarantees with ARC favoring Government and Government owned entities and
top tier multinationals at Overseas Centres shall be approved by relevant CC.
All politically sensitive credits (fresh and renewals) as well as credits linked with
persons holding public offices shall be approved by GE/GH-R&CP in addition to
relevant CC including Senior Risk Manager and Head CRM.
3.11 Revaluation
If the depreciation of PKR is more than 5% from the booked rate of the loan, RM
will ask the customer to reduce his/her liability proportionately or obtain approval
of enhanced amount with adequate security. An undertaking to cover exchange
fluctuations shall be obtained from the customer at the time of initiation.
Such loans, where the exchange rate has depreciated more than 5% and the
liability is not reduced or security is not topped up by the customer promptly, will
be watchlisted. Subsequently, business shall submit a resolution plan after
agreeing with the customer in 30 days.
3.12 Overdue
It has been observed that TPC continues to issue LCs upto the limit approved in
cases where the import bills have been overdue for considerable period. This is
against the true spirit of due diligence to be conducted while lending to
customers. Inability of the customer to pay for current dues signals that the
customer’s cash cycle is disturbed and would face problems for further
repayment of the loan. Additional lending to such customers might lead to
deterioration of the portfolio. Therefore, such cases will require additional
approval (as specified in Annexure XX) for continuation of issuance of LCs,
Finance against Trust Receipts (FTRs) and FIM – (sub limits) for overdue
accounts within the approved limits.
Prior to issuance of DAC and on receipt of approved SCA, RCAD will ensure the
following:
Routing number allotted to SCA to be logged off from routing register, routing
sheet to be filed (for LOS, this is system generated), and copy of SCA to be
provided to Documentation Officer in order to check/record credit approval
and CC’s covenants, if any;
A copy of Credit Approval forwarded to MIS Officer for updating of database;
Upon written request from RM, RCAD to prepare IB documents, as per credit
approval, completely filled in, including, principal amount, rate of markup,
frequency of markup for each facility, expiry of IB Agreement, details of
collateral etc.;
RM to fill date of execution in IB documents and RCAD to ensure accurate
date of execution is filled.
Signature of the customer shall not be obtained on blank documents;
Provide copy of approval to RM, along with completed set of IB and related
documents;
Independently nominate/assign external vendor (Muccaddam, Valuator, etc.)
for provision of various reports. Review and identify the discrepancies in the
reports for rectification by the vendor. All muccaddam and valuator vendors
to be spread over equally for customers;
Nominate approved legal counsel for review/vetting of legal documents
(Non–Standard);
Review legal opinion provided by the legal counsel and draft of agreements,
undertaking, or any other legal and property document etc;
RM will be responsible for providing complete/executed legal documents as
per requirement of approved legal counsel;
Documents must be executed in the presence of RM(s)/bank officer(s)-
attorney holders; and
After careful review of the credit documents, external reports and legal opinions,
RCAD will:
4.2 Documentation
4.2.1 General
In case of pledge of shares, Bank’s lien should be recorded through CDC and
letter of lien (shares) should be obtained duly signed by the owner of shares.
Following additional documents relating to the Title Deed must also be obtained:
4.2.2 Lodgment
Documents will be returned within 7 working days from the date of release.
Documents relating to SAM accounts will be returned within 15 working days
from the date of release. RCAD will diarize the receipt of released documents
and ensure that the documents are received on due dates. Release of
documents for more than 7 working days (15 working days for SAM accounts)
will require approval from relevant level of CC originally required for total facility
approval.
Request for permanent release of credit documents will also be initiated by the
RM+TL/Unit Head/RHRA+RCH/HCA/CHRA (as per Annexure XXI B) and
approved by the relevant level of CC originally required to approve credits as per
Credit Approval Authority & Structure, provided that:
4.2.7 Witness
All working capital lines will be evidenced by a demand promissory note and a
buy back agreement. Both documents will be made out for the total amount of
the line including mark-up and will be listed in the security/support section of the
SCA and renewed every year. It is also recommended to obtain a letter of
continuity from the borrower in order to perfect the loan documentation.
At the time of annual review, the RMs shall obtain details of projects/contracts in
hand with their original and residual value from the customer.
Security documents have been segregated into Mandatory, Crucial and Semi
Crucial documents (Annexure XXII A). All Waivers/Deferrals have to be properly
justified by RM. Following guidelines will be observed for allowing deferrals:
Maintenance
The credit facilities of the customer shall automatically be frozen after 30 days
on expiry of the deferral.
Requirements
The facility offer letter must have the following minimum information:
Rule # 1
Rule # 2
When a term loan agreement is listed as security/support, this implies that Bank
will not only have the agreement itself but will also have all other related
documents mentioned in the agreement. Usually these documents are listed in a
section of the agreement called “Conditions Precedent” and they include such
things as certificates of corporate authority, etc. Transaction lawyer will be
responsible to confirm completion of conditions precedent mentioned in term
loan agreements.
Rule # 4
Loan Documents taken as evidence of debt may or may not be listed in the
security/support section since they are essential to the granting of credit and
therefore may be assumed to be always obtained in each and every case. The
security/support section should include only the documents that serve as
security or support since their obtaining depends on the CC’s perception of the
risks involved. In case the credit is extended beyond 90 days due to delay in
annual review, the validity of loan documents is essential and fresh loan
documents must be obtained, if required.
Rule # 5
Rule # 6
Rule # 7
Rule # 9
Rule # 10
Rule # 11
Copies of the Computerized National Identity Cards of all persons who sign the
documents as borrower/witness/guarantor should be obtained.
Rule # 12
In addition to relevant CC, the approving authority for the waiver of PG rests with
GE/GH-R&CP. However, PGs for credit lines fully secured by cash
collateral/liquid securities will not be required (as a partial facility among multiple
facilities or total cash/liquid secured). For this RCAD shall confirm that the facility
is fully secured by cash/liquid securities.
For overseas lending, rules and regulations of local central banks to be complied
with.
Rule # 13
Rule # 14
Rule # 15
Any change in the ownership of the company (within the shareholding structure)
or outside shall require NOC from the Bank.
Rule # 16
Bank’s lien should be created with proper evidence (certificate from the relevant
authority) in case of any tangible collateral taken as security.
Rule # 17
Rule # 19
Rule # 20
All pages of the documents should be signed by the borrower in order to avoid
any dispute later on.
Rule # 21
Rule # 22
Rule # 23
Any agreement must be signed by the borrower and the Bank e.g. Buy Back
Agreement, Term Loan Agreement etc.
Rule # 24
Term Loan Agreement should be obtained for all term loan financing i.e. Non
Interest Demand Finance (NIDF) in line with the date of disbursement.
Rule # 26
Rule # 27
Operating Procedure:
Transaction vouchers are prepared by Branch Operations. Two Officers will sign
the voucher for utilizing any facility after ensuring that sufficient cushion is
available under the valid approved lines advised by RCAD. Later on the voucher
will be posted into the system by one Officer and supervised by another Officer.
These Officers may be the same who have prepared/signed the voucher or
different as the case may be. Branches where Symbol System is implemented,
transactions shall be supervised by authorized officials, on the system.
Any facility utilization by Branch Operations without valid DAC issued by RCAD
is not permissible. A disciplinary action will be taken against any Officer who
violates the policy.
For financing to rice and other commodity exporters, the Bank releases
consignments from Muccaddam to C&F agent (both on Banks’ approved panel)
for onward shipment. For each such transaction, the customer executes TR with
transit Insurance Policy. An undertaking/indemnity is also obtained from the C&F
Agent.
Credit Vendors
Credit vendors are external agencies which help banks in decision making and
mitigate risk by providing following services to the bank:
Services Includes:
Vendor Management Unit (VMU) is an integral part of Credit Policy Division and
deals with Vendors who provide various services required by the Bank.
5.1.1 Valuator
5.1.2 Muccaddam
Any future credit vendor requirement will be carried out by VMU for due
diligence of any material function/activity required to be outsourced as per
outsourcing guidelines.
To seek approval of VMC for enlistment of vendors who meet eligibility criteria,
VMU will send the following documents:
Site Visit shall also conducted by VMU if Vendor’s Head Office is situated in
Karachi or by respective Head RCAD, if the Vendor’s principal office is outside
Karachi. Required rating and visit report shall be prepared by VMU or RCAD as
the case may be and reviewed by VMU. Format for site visit report is attached
(Annexure XXVIII).
5.3.1.3 Approval
If the rating and recommendations are satisfactory, proposal for enlistment will
be sent to VMC for approval. After approval of VMC, VMU will intimate
enlistment to the vendor.
All related departments will be advised about the new enlistment of vendors on
the Bank’s panel.
Proposals with unsatisfactory ratings will be declined and vendor will be advised
accordingly.
VMU will circulate the Bank’s approved vendors list to all concerned on
semiannual basis i.e. 1st week of January and July.
Addition of region for vendors for conducting business will be scrutinized on the
following requests:
Unsolicited Request (Vendors approach the Bank for addition of region); and
Solicited Request (RCADs approach/request for addition of region).
5.5.1.1 Valuators
Head RCAD will investigate the reported incidence, and recommend to VMU
appropriate action against the valuator in case of following incidents/issues.
Overvaluation;
Misreporting/Misrepresentation of the facts;
Fraud/ Forgery;
Professional Incompetence; or
Misconduct.
5.5.1.2 Muccaddam
Head RCAD will investigate the reported incidence, and recommend to VMU
appropriate action against the Muccaddam in case of following incidents/issues:
Head RCAD, Business, RCRM and CPU/TPC will investigate the reported
incidence, and recommend to VMU appropriate action against the BIR service
provider in case of following incidents/issues:
Head RCAD will investigate the reported incidence, and recommend to VMU
appropriate action against the C&F Agents in case of following incidents/issues:
5.5.2 Suspension
5.5.3 Delistment
In case a valuator is delisted by PBA his name will also be removed from the
Bank’s approved valuator. However, if the said valuator is re-instated by PBA,
he will also be restored on the Bank’s panel of valuators with the approval of
DHCP/HCP, after conducting reasonableness of the case.
Other Vendors (C&F Agents, Muccaddam and BIR Provider) if once delisted
from the Bank’s approved panel will not be considered for re-enlistment.
However, exception for re-enlistment of these Vendors will require approval of
GE/GH-R&CP.
In case of fraud and forgery or any gross misconduct is proved, vendors’ re-
enlistment will not be considered.
Services of Muccaddam, Valuators and C&F Agents will be utilized through the
processes laid out in TPC/CAD/Credit Manual. List of approved Vendors is
attached as Annexure XXXIII (Vendors may change from time to time and
revised list shall be circulated to the concerned).
On request by RCAD/ Business/ TPC, VMU will arrange for BIR service provider
based on the Bank’s approved list.
Business, RCAD and branches will route their request for credit reports through
VMU regarding fresh clients, renewals and enhancements. The cut-off timings
for sending requests is 0900 – 1500 hrs, Monday through Friday, and 0900 –
1230 hrs on Saturday. Request sent after the prescribed timing will be
processed on next working day.
VMU will forward the request to vendor after checking information in respect of
name of the customer, address, place, IBCA number (where applicable),
amount, document/transaction number (in case of payment via system) and
update the MIS sheet.
On the request of CPU/TPC, VMU will approach BIR service provider for credit
reports. The cut-off timings for sending requests is 0900 – 1500 hrs, Monday
through Friday, and 0900 – 1230 hrs on Saturday. Request sent after the
prescribed timing will be processed on next working day.
VMU will forward the request to vendor after checking information in respect of
name of the customer, address, place, IBCA number (where applicable),
amount, document/transaction number (in case of payment via system) and
update the MIS sheet.
For payment to BIR service provider, CPU/TPC Trade will directly send the
amount via System or IBCA to the Central payment section through Sundry
Deposits account. Collection of payment from the customer will be responsibility
of Business, RCAD, CPU/TPC and originating branch.
BIR service provider will not entertain/decline any request without informing
VMU.
BIR service provider will send the report directly to the concerned Business,
RCAD, CPU/TPC and branch with copy to VMU along with Invoice as per
following Turn Around Time:
The concerned Business team, RCAD, CPU/TPC and branch will not disclose
this report to any third party or the borrower/applicant/client.
Branch will pay charges for reports to Central Payment Section through
IBCAs/System on behalf of respective Business, RCAD and CPU/TPC, and
credit the amount in Sundry Deposits A/c. No. 3590-44-8 for Local Credit Report
(and all other reports) and 3590-24 for Foreign Credit Report.
VMU will prepare the vouchers, summary of reports, along with the note for
payment against reports requested during the month and will send to the Central
Payment. This will be done once a month, in the first week of every subsequent
month, and the note for payment will be signed by an official from VMU and the
payment approving authority.
Original invoices will be sent to Central Payment Section for making payment to
the service providers.
Central payment Section will debit Sundry Deposit Account LCR (Code# 3590-
44-8) for Local Credit Report Charges and all other reports and FCR (Code #
3590-24) for Foreign Credit Report Charges. The withholding tax will be credited
to Sundry Deposits Accounts Client services code # 343086.
Central Payment Section will send a PO in favor of BIR service provider to VMU
for onward delivery to BIR service provider.
Business or C&F Agent may request for enhancement in the handling limit of a
C&F agent. VMU will evaluate the request as a one-off case, or on permanent
basis.
For One-Off case, VMU will obtain the “Indemnity bond” from the customer along
with other required documents from C&F agent and submit proposal to VMC. In
case of limit enhancement on permanent basis, VMU will ensure that 5%
security deposit will be provided by the C&F Agents. In case of deviation, VMC
will be requested for the same. However, existing C&F agents who have been
exempted from 5% security deposit requirement shall continue working as per
their existing arrangements.
Following criteria is applied for enhancing the limit of C&F agents: Past track
record of C&F agent with the Bank, market reputation, financial strength,
capacity, working experience etc.
For safe custody of security deposit submitted by C&F agents, bank’s lien is
marked on security deposit and lien marked instrument is provided to RCAD
Corporate Bank Karachi for safe custody.
On approval VMU will intimate C&F agent and after completion of required
formalities inform all concerned about the enhancement in handling limits of the
Agent and update the MIS sheet.
Business may request for the appointment of C&F agent not enlisted on the
Bank’s approved list of C&F agents on One-Off basis.
VMU will review the One-Off request and will obtain the “Indemnity bond” from
the customer along with the other required documents from C&F agent and
submit proposal to VMC for approval.
Call Reports
There must be at least one call per quarter except for lending against cash
collateral or against liquid securities (as defined by SBP). As a general guideline,
following may be discussed in Call Reports:
Credit issues;
Company’s performance year-to-date vis-à-vis sales/profitability;
Industry situation;
Comment on risk areas identified in last SCA package;
Future plans, etc., including potential requirements for incremental facilities;
Workers/labor related issues, timing for union negotiations and prior
experience of such negotiations;
Business/marketing;
Our earnings year-to-date from the relationship;
Current issues;
Potential deals; and
Information on competitors’ strengths/weaknesses and current situation.
Financial information (audited a/cs/management a/cs/future projections).
Call Report;
Company;
Calling Officer;
Calling Upon (Customer/Designation);
Date: DD/MM/YYYY;
Results;
Conclusion; and
Action plans/follow-ups/target dates.
Call reports, on prescribed formats, will be sent by the RMs through email to
their business chain including HCA/CHRA/RCH,RCAD and relevant CC.
Business Heads including HCA/RCH will be responsible for taking action, if any,
after having gone through the contents of the call reports.
The call reports duly reviewed and initialed by the business chain including
HCA/CHRA/RCH, will be filed in the respective credit files being maintained with
the RCADs.
It will be the responsibility of the RCAD to obtain bank and trade checkings
required by the RMs for all cases including renewals and enhancements. RMs
will request VMU for trade checking reports by email and remit vendor’s charges
via credit advice (IBCA) to VMU. VMU will maintain proper record of payments
made to the vendors.
RCAD will submit, two months ahead of scheduled revision date, request for Trade /
Credit Checking (Annexure XXXIV) to RMs to get the necessary details (Point of
contact, Name, Address, Contact No. etc.) to enable RCAD to obtain the
required credit reports from outsourced agencies. RCAD will deliver these
reports to the business chain including HCA/CHRA/RCH for their information. As
the RMs are often in a better position to obtain information about a customer
from its suppliers and competitors who also maintain a relationship with the
Bank, their active involvement in this process and free exchange of the
information they gather about each other’s customers will be helpful.
Negative/adverse remarks in Trade checking reports should be highlighted to
relevant CC.
UBL will also exchange the information regarding its customers on reciprocal
basis with other banks. RCAD will prepare the draft reply consisting of usual
information upon the receipt of written request from other banks and pass on to
RMs for their concurrence before the information is released to the inquiring
bank. RCAD will insert a disclaimer clause “The above information is provided in
strict confidence and without any responsibility on part of UBL and its officers in
the credit report”.
Financial Statements
Pledge Financing
This short term facility is required to be handled and managed in the following
manner:
a) Control of Stocks :
Control of goods under pledge shall only be assigned to Bank’s own officials or a
muccaddam on Bank's approved panel with good track record.
Head RCAD will nominate/assign the muccaddam for a specific pledge site and
will advise RMs accordingly. A monthly report of muccaddams assigned to
various sites shall be submitted to Country Head CAD.
RCAD will attach most recent stock inspection reports (for pledge and hypo) with
SCA. In addition, RCAD will promptly send stock inspection reports with material
issues including misappropriation of stocks to the Business Heads including
HCA/CHRA/RCH and CRM for appropriate action/instructions to the concerned,
to address the issues highlighted in the report. RCAD will also inform CRM in
case periodical inspection of pledged stock is not carried out as per policy.
Bank’s sign board indicating “Goods pledged with UBL” must clearly be affixed
properly at each and every warehouse where goods are pledged in a manner
that board cannot be easily removed.
Stocks will be stored by the borrower with proper stacking to ensure physical
verification by the muccaddam/internal auditor/RCAD or outsourced companies
at the time of inspection of pledged stocks. Bin cards will be placed on each
stack and a register for inward and outward movement of stocks be maintained
for each godown.
Delivery of goods will be allowed to the customers from the warehouse against a
written Delivery Order (DO) issued by the Bank duly signed by two authorized
signatories either from RCAD or from Operations where RCAD does not exist.
The muccaddam will generally ensure that the stocks received earlier are
released first i.e. on First in first out (FIFO) basis, unless practically not possible
i.e. imported cotton/fiber etc.
All stocks pledged as security must clearly be identifiable. Stocks not under
Bank’s pledge to be kept in a separate warehouse. In exceptional cases, on
specific CC approval charged and un-charged stocks or goods pledged with
other banks may be kept in a same godown provided these are segregated,
stacked and in identifiable position. In such cases these should be kept at a
distance of at least 20 feet from each other.
Pledge of stocks, for items other than those as mentioned in the SCA, will not be
accepted as security.
Till such time financing remains outstanding, adequate stocks covering the
liability (with margin) shall remain in the custody of muccaddam.
Initial and subsequent stock reports with every movement will be submitted to
RCAD duly signed by Muccaddam and the borrower. Stock report is to be
submitted at least on a monthly basis, even if there is no movement in stocks.
Submission of stock report will be mandatory at the time of building
inventory/delivery of stocks.
b) Selection of Godown :
While taking possession of pledged stocks the RM and muccaddam will ensure
that the Godown:-
Stock break-up;
Quality of collateral;
Evidence of ownership;
Quality of warehousing;
Adequacy of fire-protection devices;
Adequate protection from theft/burglary;
Status of insurance policy;
Address of pledge site; and
Godown wise breakup.
c) Margin Requirements
The value of goods, held under pledge, shall always be equal to or exceed the
outstanding facility plus the margin prescribed by SBP or as approved by CC
whichever is higher, with the condition to top-up the shortfall if margin is eroded
by 25% and sellout if margin is reduced by 50%. The sellout will require approval
of Senior Risk Manager/Head CRM.
If the margin is eroded by 25% or more, RCAD will immediately notify the
business chain involved in the recommending process for top up within 7 days
keeping relevant CC in loop.
Insurance:
Insurance must cover all standard and related risks (including fire, burglary
and theft);
Insurance policy shall be obtained from Bank's approved Insurance
Company;
Simultaneously, it is also noted that the customers have made significant in-
house arrangements to cater to this risk. Therefore based on the above,
following instructions shall be applicable.
Proposing such waivers will require submission of the request along with
justification. RMs are required to mention such waiver requested in the proposed
section of SCA and provide the following information in the SCA:
In case where Bank’s charge on land and pro-rata value assigned to UBL covers
the full exposure of the Bank then CC will approve waiver of terrorism policy
along with SCA. Also, once waiver of terrorism insurance is approved by the
competent authority this would not require approval at the time of renewal if no
enhancement or no overdues are present.
Insurance policy/cover note shall be made out in the joint names of UBL and
borrower with the condition that UBL will be the “Loss Payee”;
Value of insurance to be adequate to cover Bank’s exposure. (Exposure is
calculated by including margin on the facility amount);
Bank’s share will be mentioned in case of joint insurance policy unless
exempted by CC;
Amount insured by the insurance company is within approved per party limit;
In case of co-insurance, share of each insurance company is authenticated
by co-insurers;
A copy of Insurance Policy Review Sheet is forwarded to Relationship
Management for their review and ratification (in case of any discrepancies);
A separate file is maintained for insurance policy of each customer, along
with the confirmation;
Copy of insurance policy is scanned to database, along with policy
confirmation certificate from insurance company;
A comprehensive tickler/diary be maintained regarding expiry dates of
insurance policies;
Letter for “Renewal of Insurance Policy” to be sent to the customer, jointly
signed by RCAD and the RM, at least one month prior to expiry of the
insurance policy; and
In case pledged goods or mortgage of land does not cover the loan facility
extended including margins required, hypothecated goods, plant building and
machinery will also require insurance coverage.
Aging of receivables
Site Visits
The periodic site visit report on ongoing projects/customers will be placed in the
credit file. SCA package must contain site visit memoranda. It will be preferred if
such site visits are conducted as close to the annual review cycle as possible.
Collateral Valuation
Desktop Evaluation
Credits up to 10M
RMs are required to attach a copy of Desktop Evaluation at the time of routing
the SCA. However, in cases where the SCA is not due for renewal and desktop
RCAD has to ensure that valuation process includes conducting a “Full Scope
Valuation’ of the assets in the first year and then followed by ‘Desktop
Valuations’ in the second and third year (Fourth year only for open plot of land,
and where building is constructed, separate valuation of land). Full Scope
valuation shall be valid for three years (four years for land only) or as stipulated
by SBP from the date of last valuation; and, at the time of classification, the Full
Scope Valuation shall not be more than one year old.
The evaluation report should contain the determinant factors of FSV as required
under PR. Furthermore, PR shall be followed for taking FSV benefit and
provisioning for NPLs.
Documentation Verification
RCAD will verify the signature and check the outstanding balance in the system.
If DP is available, RCAD will issue the Delivery Order (DO) to Muccaddam.
However, it will be the responsibility of RMs to make sure that adequate stock is
available to meet the purpose for which working capital finance is approved.
A credit file will be maintained for each credit relationship as well as for
customers about whom unfavorable information is on record;
Maintenance of the files in good order, the control of their movement and the
accuracy of filing will be the responsibility of RCAD;
Except when not warranted by the volume of filing material, credit files will be
sub-divided into sections such as Credit Approvals, Financial Information,
Correspondence and other subjects as required;
All information of an adverse nature will be marked for permanent retention
and for future reference;
Credit files are of confidential nature. All Charge Documents/Control
Documents, Security Documents and title deeds must be kept in lock and
controlled in fire resistant cabinets and must not be removed from the Bank’s
premises. If credit files are required, RM will return credit files promptly to
RCAD. Credit Files should be under proper lock and control in Steel
Almarih/Cabinet in joint custody; and
Following ticklers (due date diaries) to be prepared and reviewed by the
RCAD on Monthly Basis and shared with the Business Heads including
HCA/CHRA/RCH and CRM :
Reports shall be sent for information of the stakeholders and for the better
planning of designated task of the credit.
Submission Deadlines
CRM and business must take TAT into account to ensure the credits do not
remain expired and the customer does not suffer.
More than 3
Segment Up to 3 months
months
Retail Bank Senior Risk Manager Head CRM
Corporate
Senior Risk Manager Head CRM
Bank
Senior Risk Manager upto the approval authority limit, Head CRM irrespective of the amount.
More than 3
Segment Up to 3 months
months
Risk Manager/Senior Risk
Retail Bank Head CRM
Manager
Corporate Risk Manager/Senior Risk
Head CRM
Bank Manager
Risk Manager upto the approving authority limit, Senior Risk Manager and Head CRM irrespective of the amount.
For FIG and TCM, approval for all temporary extensions and renewal of credit
limits of banks/DFIs will be sought as per Approval authority matrix set by
FIRMU in the Annexure XIX.
7.1.1 Watchlist
Watchlist accounts shall be reviewed after every two months. The reasons for
watchlisting should be documented and specific remedial actions should be
approved by one level higher than relevant level of CC on the attached format
(Annexure XXXX A). Progress relating to remedial strategy should be reviewed
on quarterly basis on the same format.
Weak cashflows;
Declining margins;
Reduction in demand for core products/services;
Deteriorating management controls;
External factors such as economic slowdown; and/or
Introduction of substitutes resulting in decline in sales.
b) Substandard
Financial Performance
Transactional
Other
c) Doubtful
d) Loss
FBP – Bank Risk and settlement risk are not added to total facilities for approval
under the rules. However, these credit exposures are also subject to
classification, if required.
While preparing the CM, the RMs must clearly mention all the facilities being
availed by the customer. This will enable the bank to review the credit on a
holistic basis and timely remedial action could be initiated to protect the bank’s
interest.
Assess the collateral by arranging its fresh forced sale valuation by a bank’s
approved valuator to determine the residual value;
Arrange review of the credit documentation/securities by the CLC
nominated/approved legal counsel, if necessary, to determine accuracy and
enforceability of the securities;
Monitor further facility utilization in the accounts and consider blockage of the
unutilized lines depending upon the situation;
Obtain fresh credit checking and CIB report in order to verify the position of
customer’s outstanding overdues with other banks; and
Analyze the latest financial position of the borrower vis-à-vis his overall
liabilities in order to determine his capacity to settle the obligations.
The typical focus of the remedial strategy in each classification category is:
OAEM
Substandard
Loss
In the CM, the action plan should be clearly spelled out which should necessarily
address the following:
Frequency of reviews
Preparation of CCRs will not be required for NPLs upto Rs.1.0M which shall be
handled differently for recoveries. However SAM-CAD will submit quarterly
progress report on addition of new NPLs and recoveries to CRM.
Records
Bank will provide for potential losses in the shape of Specific Reserves and
General Reserves:
Following shall be the determining factors for final computation of the provisions:
Hypothecated assets and assets with second charge and floating charge
shall not be considered.
Head RCAD will nominate, amongst the approved valuators and assign
valuation of assets, where necessary to valuators with the instructions that
their report must take care of all essential aspects for determining the FSV.
For this purpose, the valuators must verify relevant aspects such as nature of
locality, salability, encroachments, etc. and not merely apply the discount
factor.
If it is impossible for the valuator to obtain the right to enter the premises due
to non-cooperation of the borrower then the last available valid evaluation will
be used.
a) Liquid Assets:
Valuation of Liquid Assets, excluding pledged stocks which are dealt with
at (d) below, shall be determined by the bank. However in the case of
pledged shares of listed companies, value will be taken at market value
as per active list of Stock Exchange on the balance sheet date.
Moreover, valuation of shares pledged against loans/advances shall be
considered only if these are with CDC, otherwise these will not be
admissible for deduction as liquid assets while determining required
provisions.
FSV for Plant and Machinery may be determined for provisioning as per
guidelines issued by SBP.
d) Pledged Stocks:
Note:
In addition to ‘Specific’ and other statutory reserves, the President and the BOD
will consider creation of ‘General reserves’ depending upon following broad
factors: -
7.6.3 Frequency
7.7 Responsibility/Reporting
All relationships with higher degree of risks classified as “Doubtful” or “Loss”, are
required to be transferred to SAM when it is determined by CRM and Business
Group responsible for the account, that the group is no longer in a position to
manage these non- performing loans in the manner originally intended.
Timelines for transfer shall be jointly agreed by business group (where it is
residing) and CRM. However, in some cases business may decide to retain
NPLs, where they feel that they will be able to recover outstanding dues
themselves. Classified cases (Doubtful and Loss accounts) which are retained
by business must be reported on quarterly basis for review of Head CRM, and
DHCP/HCP.
After approval of RTM, SAM CAD shall take custody of all original
documents, credit files and relevant records etc. and should authorize the
SAM Branch to park the liabilities and issue IBCA in favor of the Branch
concerned;
Once the liabilities are transferred and parked at SAM Branch, SAM shall
advise FINCON to transfer the Specific Provision held to SAM Branch
immediately;
Upon transfer of the accounts at SAM Branch, SAM would directly approach
the borrowers and devise strategy for expeditious recovery / settlement;
PAD position issued by FINCON will be reviewed on quarterly basis for
conducting the exercise of specific provision required matching to the
outstanding liabilities as per PR. Excess provisioning due to recoveries made
at SAM shall be transferred to RB as ‘Reversal of Provision’ through and with
the approval of FINCON. However, for other business groups all recoveries
will remain with SAM;
Recoveries made by SAM would first be appropriated towards adjustment of
the liabilities outstanding at SAM Branch. All recoveries made by SAM in
excess of the liabilities booked at SAM Branch would be transferred back to
RB instead of taking such recoveries to SAM mark-up income account or
Gain on NPLs; and
SAM would make all out efforts to recover entire amount of dues legally
recoverable from the borrowers including tracing out their realizable hidden
assets for attachment and their execution. However, any shortfall or benefit
in provisioning or loss on NPLs at the time of conclusion of the case would
be passed on to the RB through and with the approval of FINCON. However,
for other business groups all recoveries and losses will remain with SAM.
The ‘exit strategy’ would involve the recalling of the outstanding and initiation of
legal action including filing of references of willful default under National
Accountability Bureau (NAB) ordinance through SBP.
The recovery process for each account will be reviewed and approved by
relevant CC.
To achieve the objective of early realization of problem credits bank may opt for
rescheduling/restructuring based on the nature and gravity of the situation, best
suited to protect the Bank’s interest.
7.9.1.1 Rescheduling/Restructuring
Policy
The default is not willful, i.e. the borrower is not misrepresenting actual facts
with the purpose of securing concessions;
The borrower has a viable business plan for the future, as demonstrated by
financial projections; such projections are to be thoroughly examined to
General Guidelines:
The bank may come across situations when pursuit of non-traditional workout
strategies such as Debt Asset Swap (DAS) may be preferable to achieve the
desired results. Such options will be exercised subject to presence of the
preconditions including the following:
Approval process
Requirements
Properties with complete chain of documents, transferable title, free from all
kinds of liens, encumbrances, litigation and third party claims, shall be
considered by the CC for recommendations to REC. Additionally CC may
however, recommend proposals where liens, encumbrances and litigation of
other lenders are removable (Subject to clearance – with consent of other
lending).
Legal opinion
The actual transfer of property and due diligence should be supported by input
of CLC which will refer to all rules and regulations issued by SECP, Companies
Ordinance and Banking Ordinance for compliance.
Monitoring
Buyback agreements
Post agreements, updates on activities are to be monitored by RCAD and Asset
Management Division and exception to the agreed arrangement shall be
highlighted to GE/GH-R&CP immediately.
Every case should have a timeline and any deviation shall be highlighted to
GE/GH-R&CP.
Process Flow
If all efforts fail, the bank may opt for litigation. Following procedure shall be
followed prior to litigation:
7.10 Write-offs
The concerned RM/Business Unit and SAM/RCAD will initiate the write-off
proposal highlighting therein: