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Financial Institutions, Banking & Market Infrastructure
1The Financial System
The Financial SystemDirect Finance and IntermediationBank-Based and Market-BasedHow to Map Any…A Financial ClaimFinancial Health of an InstitutionSystemic Importance
2Banking
Net Interest Income and…Bank Margin and Deposit MixBank ResolutionBank RunsCommercial BanksCentral Bank and Commercial BankBank ReservesInterest IncomeIssuer and Acquirer BankAsset-Liability ManagementThe Bank Balance Sheet…Provision CoverageAsset QualityOpen Banking and Account Aggregators
3Deposits and Lending
Co-LendingRetail and Corporate Lending…On-Balance-Sheet Lending Against Co-Lending…Loan TypesDepositsSavings AccountsLoan to ValueLoan-to-Value CalculatorBank Funding and SpreadFixed and Floating-Rate Loans
4Institution Economics
What a Financial Institution…How to Build a…Where a Financial Institution…How Efficiency Ratios Read…What the Cost to…Cost to Income CalculatorCo-Lending EconomicsCapital Adequacy CalculatorReturn on Assets and…Disclosed, Derived or Concluded
5NBFCs and Digital Credit
Credit UnderwritingCredit Cost vs Provision CostAlternative Data in CreditTraditional vs Alternative Credit…Fintech LendersNBFC vs Fintech LenderCredit BureauxDigital LendingEmbedded FinanceLoan OriginationLoan Book EconomicsWarehouse LinesDigital Public InfrastructureFirst Loss Default GuaranteeBank vs NBFCDirect vs Intermediated Distribution
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How Insurance Pools Risk…UnderwritingLoss Ratio, Expense Ratio…Insurance Ratio CalculatorLife and General InsuranceInsurance and AssuranceInsurance FloatHow an Insurer Earns,…ReinsuranceSolvency RatioPremium Growth
7Asset Managers
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8Brokerages and Exchanges
What a Broker Does…Broker and DealerFull-Service and Discount BrokersThe Order BookOrder FlowStock ExchangeTrading VenuesMargin FundingBrokerage EconomicsThe Bid-Ask Spread
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Credit Underwriting: How a Lending Decision Is Made

Credit underwriting is the decision a lender takes about whether to lend, how much, at what price and on what terms, using money it has mostly borrowed and owes back on a date of its own. The decision produces a price for a range of outcomes rather than a verdict on a person, and that price must cover the money, the work and the loans that do not come back.

A word first about the empty cells further down. Nine separate conditions a lender must satisfy turn up below, and each one arrives with its value missing and an address standing where the value would be. Each of the nine is decided by an authority that revises it, and a revision does not travel out and correct the records that copied the old figure. Each row therefore carries the question and the door to knock on, and the answer is fetched on the morning the answer matters.

Try it out

A lender is about to decide on a loan. Whose money is mostly at stake in that decision?

Whose money is on the table before anybody reads an application?

Start on the wrong side of the balance sheet, and start there deliberately. Almost every explanation of lending opens with the borrower, and by the time it reaches the lender's own position the reader has already formed the picture that a lender is somebody with a pile of money deciding who deserves it. The picture of a lender with a pile of money to hand out makes the rest of the subject impossible to follow.

Rukmini Finance Limited, an invented lender, lends and takes no deposits. The lender carries assets under managementThe book of loans a lender is carrying at a given moment, measured in rupees. Because every ratio is struck on it, it gets named every single time. of Rs 18,000 crore. Behind that book sit Rs 14,400 crore of borrowings raised in the market and Rs 3,600 crore of its own net worthThe lender's own money. The amount left over for the owners of the business if every rupee it owes were repaid, and nothing more mysterious than that.. Divide Rs 14,400 crore by Rs 18,000 crore and 80.0 per cent of the book was funded with money that belongs to somebody else, on terms somebody else wrote.

Rukmini Finance Limited, invented: the funding side comes first 200 user units stand for Rs 18,000 crore on both columns, so the two are drawn to one scale THE FUNDING SIDE Borrowings Rs 14,400 crore 80.0 per cent of the book Net worth Rs 3,600 crore THE LENDING SIDE Assets under management Rs 18,000 crore one undivided book Every rupee here has to earn its way.
Rukmini Finance Limited funds Rs 18,000 crore of assets under management with Rs 14,400 crore of borrowings and Rs 3,600 crore of its own net worth, so four of every five rupees it lends were themselves borrowed on a fixed schedule.

The consequence is the whole reason to start here: the money the lender lends has a repayment date of its own, and that date does not move because a borrower's month was hard. Think of a stall outside a single office building that buys its stock on thirty day terms from a wholesaler. The wholesaler's thirty days were not negotiated with the customer in mind. However reasonable a request for ninety days from a regular customer might be, the stall cannot grant it and stay open. The liability came first and it decides the business.

Owing money back on a fixed date is the position every lending decision below is taken from. Rukmini Finance is not choosing who deserves money. The lender is deciding what to do with money it has already promised to return, at a price that has to be enough to return it.

What is underwriting actually producing?

State it flatly before anything is added. Underwriting is a decision taken now about money that comes back later, on information that is incomplete by construction, using funds that belong to somebody else. Every difficulty in the subject falls out of those three clauses, and no amount of technology removes any of them.

The decision produces a price for a range of outcomes, not a verdict on a person. When Rukmini Finance approves a loan at 14.50 per cent a year on the amount lent, it is not saying that this money will come back. The lender is saying that at that price, across everybody it lends to on those terms, enough comes back to pay for the borrowing, pay for the work, absorb the part that does not return, and leave something over. The rate is a statement about a spread of outcomes the lender expects to meet many times, and it is meaningless applied to one.

A price for a range of outcomes is the claim everything below defends. A great deal of loose talk about lending, some of it from inside lenders, treats an approval as a character reference and a decline as a judgement. An approval is neither. Approval and decline alike are arithmetic about a population, priced for a period.

What four things does every decision settle?

A lending decision is usually described as a yes or a no, and that description throws away most of it. Four separate questions get settled, and only the first one is the yes.

One decision, four separate answers 1. WHETHER To lend at all. This one really is a yes or a no, and it is one of four. 2. HOW MUCH The amount, which is a question in its own right and does most of the work. 3. AT WHAT PRICE The rate and the charges. This is where the funding side turns up. 4. ON WHAT TERMS The schedule, any security, and what follows a date that is missed. A lender that can only say yes or no has thrown these two away, and they are the two that let it say yes at a price that works.
Every underwriting decision settles four things separately, whether to lend, how much, at what price and on what terms, and a lender that can only answer the first has thrown away the two that let it say yes at a price that works.

Look at what the middle two buy. A request that fails at one amount can succeed at a smaller one. A request that fails at one price can succeed at a higher one, if the price is allowed to move. Compress four decisions into one and the lender has not become stricter, it has become blunter, and blunt costs it business at both ends: it turns away lending it could have priced, and it takes on lending it has underpriced.

The fourth question is quieter and does more than it looks. The schedule decides when the lender finds out that something has changed. A loan repaid monthly reports on itself twelve times a year. The same amount repaid once at the end reports once, at the end, and the end is the last moment anybody can do anything about it. Whether the loan stands on any securityAn asset named in the loan agreement that the lender can look to if the money is not repaid. The assets that count as security, and the way security is taken, are settled separately. belongs to the same question.

Try it out

A lender's process can only produce a yes or a no on each application. Which two of the four decisions has it given up?

Where does a lender's information come from, and on what permission?

Four routes, named by kind rather than by product. The first is what the borrower states. The second is what a credit information companyA company that collects repayment records from lenders and returns them, with a score, when a lender asks. The records it may hold, and the way an entry gets corrected, are taken up separately. holds and returns when it is asked. The third is what the borrower's own financial records show, where the borrower has agreed to share them. The fourth is what the lender already knows from an earlier loan it made itself.

Four routes in, one gate on every one of them 1. What the borrower states 2. What a credit information company returns 3. The borrower's own financial records 4. What this lender already knows PERMISSION PERMISSION PERMISSION PERMISSION THE DECISION Whether, how much, at what price and on what terms. Taken on whatever came through the four gates. What a lender may collect, keep and share, and on what consent, is set by the Reserve Bank of India at rbi.org.in. This drawing names the gate and states none of the condition on it.
Information reaches a lender by four separate routes and none of them opens without permission, and what a lender may collect, keep and share is set by the Reserve Bank of India at rbi.org.in.

None of the four routes opens on its own. Every route runs through a permission, and what a lender may collect, keep and share is decided by the Reserve Bank of India at rbi.org.in and moves. The requirement stands here and the condition attached to it is read at that address, on the day it matters, because a copied condition is wrong from the morning it changes.

The second thing worth fixing early is that a thin recordA borrower about whom little formal information exists, usually because they have not borrowed before. A thin record is a fact about the paperwork, not about the person. is an absence of information about a person, and not information about a person. Those are different objects and they behave differently. Absence of a repayment history means the lender does not know; it does not mean the lender knows something unfavourable. Treating the two as the same is the single most common way a lending process turns a gap in its own records into a conclusion about somebody, and it is a mistake in logic before it is anything else.

Try it out

Take 14.50 per cent a year on assets under management at Rukmini Finance Limited, against 8.50 per cent a year paid on its borrowings. What is its net interest income as a share of assets under management?

How is the price of a loan built up, and out of what?

Most readers picture pricing the wrong way round. The picture is that a lender decides on a rate, charges it, and whatever is left at the end is the margin. Work it that way and the rate looks arbitrary, and every question about why it is what it is dead ends. Build it upward from the funding instead and the rate stops being a choice and becomes a sum, with the margin as the last thing standing rather than the first thing decided.

Before the stack, one piece of arithmetic that surprises people. Rukmini Finance earns 14.50 per cent a year on assets under management and pays 8.50 per cent a year on borrowings, a spreadHow far apart the lending rate and the borrowing rate sit, in percentage points. A useful number, and a different one from the margin the book actually earns. of 6.00 percentage points. So the margin on the book is 6.00 per cent, surely. It is not. The margin is 7.70 per cent of assets under management, and the extra 1.70 points have a name.

Why the margin beats the gap between the two rates 600 user units stand for Rs 1,386 crore, and both bars sit on that one scale THE NAIVE READING 6.00 per cent of Rs 18,000 crore Rs 1,080 crore WHAT THE BOOK ACTUALLY EARNS 6.00 per cent of Rs 18,000 crore Rs 1,080 crore 8.50 per cent of Rs 3,600 crore Rs 1,080 crore plus Rs 306 crore is Rs 1,386 crore, or 7.70 per cent of assets under management of Rs 18,000 crore. The dark block is the lender's own money at no interest cost.
The 6.00 point gap between the two rates applied to the whole book gives Rs 1,080 crore, and 8.50 per cent of the lender's own Rs 3,600 crore adds Rs 306 crore, which together make the Rs 1,386 crore of net interest income that is 7.70 per cent of assets under management.

Read it in two lines and it stops being a trick. Six per cent of Rs 18,000 crore is Rs 1,080 crore. Eight and a half per cent of Rs 3,600 crore is Rs 306 crore. The two amounts add to Rs 1,386 crore exactly, and that sum is the net interest incomeInterest earned less interest paid, over the same period. Net interest income is a rupee amount, and it turns into a rate only when it is divided by a base that has been named. for the year, and set against the Rs 18,000 crore of assets under management that reads 7.70 per cent. The lender's own money funds part of the book and pays no interest to anybody, and on these figures that is worth 1.70 points of margin on assets under management.

Now the stack. Four layers, all struck on the same base, all for the same year, built from the bottom.

Every Rs 100.00/- of the book, for the year, in the order it is spent 40 user units to a percentage point, and the four segments come to 14.50, the yield itself 1. COST OF FUNDS 6.80 2. THE WORK 3.00 3. CREDIT 2.20 4. WHAT IS LEFT 2.50 Rs 1,224 crore paid on Rs 14,400 crore of borrowings, contractual and dated Rs 540 crore of operating expenses Rs 396 crore of credit cost Rs 450 crore before tax, and it is a residual All four struck on assets under management of Rs 18,000 crore, for the year. The lender is invented.
On the Rs 18,000 crore of assets under management for the year, a cost of funds of 6.80 per cent, an operating cost of 3.00 per cent and a credit cost of 2.20 per cent leave 2.50 per cent before tax, and the four layers add to the 14.50 per cent the book earns.

Notice which base the first layer sits on. Rukmini Finance pays 8.50 per cent a year on borrowings, but borrowings are only Rs 14,400 crore of an Rs 18,000 crore book. The identical Rs 1,224 crore therefore reads 6.80 per cent against assets under management. Both figures are correct and they are answers to different questions. Neither may be written down without its base beside it in the same sentence.

The year, worked in orderHow it is struckRupeesPer cent of assets under management of Rs 18,000 crore
Interest earned14.50 per cent a year on Rs 18,000 croreRs 2,610 crore14.50
Interest paid8.50 per cent a year on Rs 14,400 croreRs 1,224 crore6.80
Net interest incomeThe first line less the secondRs 1,386 crore7.70
Operating expensesThe cost of doing the workRs 540 crore3.00
Credit costLending that did not all come backRs 396 crore2.20
Profit before taxWhat survives the three subtractionsRs 450 crore2.50

The last row carries the whole of it. On a book of Rs 18,000 crore, what survives is 2.50 per cent, and 2.50 per cent is Rs 450 crore. A residual of 2.50 per cent is the honest scale of a lending business, and it is much thinner than the 14.50 per cent headline suggests. Thinness is also why the cost of fundsWhat a lender pays for the money it lends, stated as a rate for a period. On a book funded four fifths by borrowing it is the largest single item there is. is the first thing anybody who understands lending looks at, rather than the last.

Try it out

For the year, and all struck on assets under management standing at Rs 18,000 crore, Rukmini Finance Limited has 7.70 per cent of net interest income, 3.00 per cent of operating expenses and 2.20 per cent of credit cost. What is left, and in rupees?

Play with it

Move the cost of funds and watch what is left

One control, the rate Rukmini Finance Limited pays on its Rs 14,400 crore of borrowings for the year. Everything else is pinned: a book of Rs 18,000 crore under management, net worth of Rs 3,600 crore, 14.50 per cent a year earned on the book, Rs 540 crore of operating expenses and Rs 396 crore of credit cost. The control opens at 8.50 per cent, and that setting reproduces the worked year above exactly.

6.00 per cent a year8.50 per cent a year11.00 per cent a year
Every Rs 100.00/- of the book, for the year 40 user units to a percentage point, and the four always come to 14.50 COST OF FUNDS 6.80 THE WORK 3.00 CREDIT COST 2.20 WHAT IS LEFT 2.50 Every reading is per cent of assets under management of Rs 18,000 crore, for one year. The middle two never move. Rukmini Finance Limited is invented and so is every figure attached to it. The margin on the book against the gap between the two rates 10.00 5.00 0 6.00 8.50 11.00 Cost of funds, per cent a year on borrowings MARGIN ON ASSETS UNDER MANAGEMENT THE GAP BETWEEN THE TWO RATES The distance between the two lines is the lender's own Rs 3,600 crore working, and it widens as money gets dearer.
Cost of funds
8.50
Net interest income
Rs 1,386 crore
Left before tax
Rs 450 crore

At 8.50 per cent a year the lender pays Rs 1,224 crore for its money, keeps Rs 1,386 crore of net interest income, which is 7.70 per cent of the Rs 18,000 crore of assets under management, and after Rs 540 crore of operating cost and Rs 396 crore of credit cost has Rs 450 crore left before tax, and that is 2.50 per cent of the identical base.

Educational illustration. Invented lender, invented figures, one year, no market rate shown anywhere. The yield, the operating cost and the credit cost are held still while the funding cost moves, which is a thing no lender ever experiences: in practice all four move together. At the top of the control's range what is left before tax comes to Rs 90 crore, which is 0.50 per cent of assets under management, one fifth of what it was. It would take about 11.63 per cent a year on borrowings to remove it altogether, which is past the end of this control. What a lender actually pays for money is set by the market it borrows in and by its own standing there.

Two things are worth taking away from moving that control. The first is that what is left before tax falls a long way for a change in funding cost that sounds modest. The residual is the thinnest layer in the stack, and it absorbs the whole of the movement. The second is quieter. Rs 3,600 crore of the book is funded by money that pays no interest at all, so the margin on the book moves by less than the funding rate does. Move the rate by 5.00 points across the whole range and the margin on assets under management moves by 4.00, which is exactly 80.0 per cent of it, the share of the book that is borrowed.

Risk Management Program Bootcamp — Fin Maverick

Credit Cost: what did the lending itself cost, and on what base?

Credit cost is the cost to a lender, over a stated period, of lending to borrowers whose money did not all come back. Credit cost is a line in the lender's own accounts. The charge is measured in rupees and reported as a rate only once a base is named.

Take the Rs 396 crore Rukmini Finance Limited charged for the year: set against the Rs 18,000 crore of assets under management it carries, that reads 2.20 per cent, and both the base and the period belong inside the sentence rather than in a note somebody may never reach. This is where the discipline of the whole reading starts, so it is worth seeing what happens when the base wanders.

One numerator of Rs 396 crore, three bases, three different numbers 20 user units to a percentage point. Only the top row is credit cost. 2.20 per cent over assets under management of Rs 18,000 crore, one year. This is the credit cost. 11.00 per cent over net worth of Rs 3,600 crore, and a name for nothing 28.57 per cent over net interest income of Rs 1,386 crore Same rupees on all three rows. A rate handed over without its base is not a number anybody can use.
One charge of Rs 396 crore laid over three different denominators reads 2.20 per cent, then 11.00 per cent, then 28.57 per cent, and only the top row of the three is the credit cost on the book.

Every one of those three divisions is arithmetically correct. Two of them are not the name of anything. A reader handed the figure 11.00 per cent with the word credit beside it and no base would have no way of telling which division produced it, and would carry away something between five and thirteen times wrong.

The second discipline on this figure is what it is not: Rs 396 crore is not a count of people and it says nothing about any of them. It is a rupee amount in one lender's accounts for one stated year. A rupee charge for a year carries no borrower detail, no count of loans, no rate at which repayments stopped arriving and no score of any kind, so a total of this kind can never be turned into a statement about a borrower. The total does set one bound. Rs 396 crore is the whole of the charge for the year, so no part of the book can have cost more than that, and the way the charge divides inside the book cannot be recovered from the total.

Try it out

A figure of Rs 396 crore arrives labelled a credit cost. What has to travel alongside it before it means anything at all?

Provision Cost: what did the accounts recognise, and on whose clock?

Provision cost is the charge a lender puts through its profit and loss account in a period against lending the lender no longer expects to see repaid in full. Provision cost looks like the same thing as credit cost and it is not. The two get used interchangeably in conversation all the time, so keeping them apart is worth doing carefully.

Credit cost is what the lending turned out to cost; provision cost is what the accounts recognised in the period, and the two answer to different clocks. One is the outcome of lending. The other is a recognition event, and recognition follows a rule about the point at which an advance stops counting as performing and what has to be set aside once it does. The recognition rule is set by the Reserve Bank of India at rbi.org.in, and it moves.

Two costs, two clocks, and only one of them can be filled in here CREDIT COST Amount Rs 396 crore Base Rs 18,000 crore Period One year What the lending turned out to cost, on the lender's own book. PROVISION COST When it starts RBI, rbi.org.in How much RBI, rbi.org.in In which period RBI, rbi.org.in What the accounts recognised, on a rule set by the Reserve Bank of India.
Credit cost can be stated in full with its amount, its base and its period, while every cell of provision cost belongs to a recognition rule set by the Reserve Bank of India at rbi.org.in and is left empty here on purpose.

A filled cell gets copied and a caution does not. The right panel therefore carries an address rather than a value. Taken apart criterion by criterion, the two make a comparison in its own right, and that comparison is covered separately. The one line above is what separates them.

Intermediated Distribution: who is party to the loan when somebody else found the borrower?

A great deal of lending now reaches the borrower through somebody who is not the lender. Another business ran the shopfront, took the application, or built a product with the loan sitting inside it so that the borrower met the loan while doing something else entirely.

Three things do not change, whoever ran the shopfront: the loan is the lender's asset, the money the borrower owes is owed to the lender, and the underwriting decision was the lender's. That is worth saying flatly because the arrangement is often described in a way that blurs all three, and a reader who is not clear about them cannot follow anything else in this part of the subject.

Somebody else met the borrower. Everything that matters still sits on the right. THE PARTY THAT RAN THE SHOPFRONT Sourced the borrower, took the application, or carried the product the loan sat inside. THE LENDER Holds the loan as an asset. Is the party the money is owed to. Took the decision, and answers for it. the loan sits here as an asset the money is owed here the decision was taken here and the lender answers for this conduct What is required of a party that sources, services or collects a loan for a lender is set by the Reserve Bank of India at rbi.org.in, and this drawing names that and prints none of it.
The loan is the lender's asset, the money is owed to the lender and the underwriting decision was the lender's whoever ran the shopfront, and what the arrangement adds is a second party's conduct for the lender to answer for.

One thing does change, and it is not small: the lender now has a second party's conduct to answer for. How the borrower was approached, what the borrower was told about the cost of the loan, how repayment was pursued: all of it happened at arm's length from the lender and none of it stops being the lender's responsibility. The requirements on a lending service providerA business that brings a lender its borrowers, handles the paperwork afterwards, or pursues what is due, without the loan ever becoming its own. are set by the Reserve Bank of India at rbi.org.in, and they move.

The everyday version is a caterer who takes a wedding booking through an event agency. The agency found the client, agreed the date and quoted the menu. The food is still the caterer's food, the bill is still owed to the caterer, and if the agency promised a dish that was never on the list, it is the caterer standing in the hall on the night.

Try it out

Another party ran the shopfront and took the application. Who holds the loan, who is the money owed to, and whose decision was it?

Distribution through a third party is one of the two big shifts in how lending reaches people. The other is what happened to the speed of the decision itself, and it is worth guessing at before reading it.

Try it out

Digital lending made decisions faster and opened sources of information that were not previously legible to a lender. What did it do to the arithmetic of pricing a loan?

How Digital Lending Changes Credit Underwriting and Servicing: what moved, and what did not?

Three things changed and one did not, and the one that did not is the one worth the most attention.

Speed changed. A decision that took days is taken in minutes. Speed matters most to the person who needs the money this week rather than next month, and it is a real change rather than a marketing one. Sources changed. Records that a lender previously could not read at all can now be read, where the borrower has agreed to share them, and that widens the set of people about whom anything at all can be known. Servicing changed. Reminders, repayment and collection now run through a channel that reaches the borrower directly and constantly. A channel like that cuts both ways, and conduct in it is regulated for exactly that reason.

Three things moved a long way. One did not move at all. WHAT MOVED SPEED: days to minutes SOURCES: records now legible, with permission SERVICING: a channel that reaches directly WHAT DID NOT MOVE: THE ARITHMETIC The cost of funds still has to be covered. The cost of the work still has to be covered. The loans that do not come back in full still have to be covered. A faster decision taken on more sources is still a price for a range of outcomes. The block on the right is the stack drawn earlier, unchanged by anything on the left.
Speed, sources and the servicing channel all changed while the arithmetic did not, because the price still has to cover the cost of funds, the operating cost and the cost of the loans that are not repaid in full.

The arithmetic did not change, and it did not change even slightly. The stack is the same stack. The price still has to cover the funding, the work and the part that does not come back, and what is left is still a residual. A decision reached in ninety seconds using four sources instead of one is still a price for a range of outcomes, and the range did not narrow because the decision arrived sooner. Speed changes the experience of borrowing and the cost of running the process. Speed does not change what money costs or what a book of loans returns.

Two smaller things are worth naming. Faster disbursalThe moment the money actually leaves the lender and reaches the borrower. The steps between the application and that moment are set out separately. means the lender's own funding has to be ready sooner, which is a funding-side problem rather than an underwriting one. And a servicing channel that reaches a borrower constantly is a channel that can be used badly. The conduct required of anybody recovering what is owed is set by the Reserve Bank of India at rbi.org.in.

What can underwriting not do, however good it is?

Three limits, and none of them yields to better information or better technique.

Underwriting cannot see a future event. Nobody's income, health or employment is knowable a year ahead, and the output is therefore a price across a range rather than a forecast for one loan. Underwriting cannot see what it was never shown. An absence in a record stays an absence, and reading it as a finding is a logical error rather than a conservative choice. And it never learns what would have happened to the loans it declined.

A lender watches one of these two sets and never the other THE LOANS IT MADE: EVERY OUTCOME EVENTUALLY RECORDED AND DATED Each mark is an outcome the lender saw. This is the only set anything is ever learned from, and it is the set the lender chose. THE APPLICATIONS IT DECLINED: NO OUTCOME IS EVER OBSERVED Nothing is ever written into these. The lender never finds out, so no decline is ever contradicted and a rule here can run for years looking correct. The two sets are drawn the same size because this record carries no count of either. No rate is implied.
A lender sees how the loans it approved performed and never sees how the ones it declined would have performed, so a rule that turns away people who would have repaid can run for years without anything in the data saying so.

Sit with the third one. The third limit is the strangest fact in lending, and it is rarely said out loud. Every lender has a complete record of what happened to the loans it made and no record at all of what would have happened to the ones it refused. The evidence arrives from one side only. A decline is therefore a decision taken under a permanent absence of feedback, not a judgement that was later confirmed. A rule that is quietly turning away people who would have repaid produces exactly the same clean-looking numbers as a rule that is working, and no amount of staring at the approved book will separate them.

Try it out

A lender's approved loans are performing well and its decline rule has never been questioned. What has the lender not observed?

Analysing an Issuer's Credit — free micro-course from Fin Maverick

Who sets the conditions a lender works under?

Nine of them turn up in this guide, and the table below collects them in one place rather than leaving them scattered through the reading. Every row carries the party that decides it and the address at which it is read. Not one row carries a value.

India

Nine conditions, each routed to its source

What a lender has to satisfyWho decides itThe value
The conditions on which a finance company is registered and may lend at allReserve Bank of India, rbi.org.in
The owned funds it must have before it is registeredReserve Bank of India, rbi.org.in
The capital it must hold, and the base that requirement is struck onReserve Bank of India, rbi.org.in
When an advance stops being treated as performing, and what is provided against itReserve Bank of India, rbi.org.in
The fair practice requirements a lender works underReserve Bank of India, rbi.org.in
What a borrower is told about the cost of a loan before taking itReserve Bank of India, rbi.org.in
The conduct required of anybody recovering what a lender is owedReserve Bank of India, rbi.org.in
The identity and verification requirements before a loan is madeReserve Bank of India, rbi.org.in
What a lender may collect, keep and share about a borrower, and on what consentReserve Bank of India, rbi.org.in

An address outlasts a figure. Every one of these nine gets revised, and a revision does not go looking for the records that copied the previous figure. A copied figure would be wrong on the morning it moved, and would be read in perfect good faith. An address stays useful for years. One further figure is beyond reach even in principle. A capital ratio needs a risk weighted asset figure, and no risk weighted asset figure has been struck for this lender, so the ratio is not merely absent but uncomputable. A ratio nobody can compute is a different thing from one that was simply left out.

Try it out

The capital requirement that applies to a finance company is needed. What belongs in the empty cell instead?

Analysing an Issuer's Credit teaches you to assess a specific claim rather than a company, and to say where in the structure that claim sits.

How does anyone actually use this?

Four people, one stack, four different questions asked of it

Somebody inside a lender, setting a price. The stack is worked bottom up rather than top down, and the order matters because only the last layer is free. Funding cost is contractual and arrives from the treasury desk. The operating cost is what the process actually costs to run. The charge for lending that does not come back is an estimate the lender has to make and defend. Whatever price covers those three plus the margin the business needs is the price, and if the market will not pay it the answer is a smaller book rather than a thinner layer.

An analyst reading a lender for the first time. Put every figure on one base and one period before comparing anything. Interest paid of Rs 1,224 crore is 8.50 per cent of borrowings and 6.80 per cent of assets under management, and two lenders quoting those two different conventions look wildly different while doing the same thing. Once every line sits on assets under management for one year, differences that remain are real.

Somebody looking at a lender as an investment. The number to interrogate is what is left before tax as a share of the book. Everything above that layer lands on it, and it is the thinnest of the four. On these figures that is 2.50 per cent of assets under management. Ask what happens to it when the funding cost moves. The control above does exactly that, and nobody can say in advance what a lender's funding cost will do.

A household, at a much smaller scale. Anybody who has borrowed to buy something that then earns, a vehicle used for work or a room let out, is running the same stack. The vehicle or the room has to cover what the borrowing costs, what running it costs, and the months it earns nothing, before a rupee belongs to the owner. Four lines set down for one year on one base give arithmetic identical to the one above, with fewer zeroes on it.

The error that gets made: reading an approval as a verdict

The error is made by the person doing the underwriting rather than by anybody borrowing, and that is why it survives so long. The reasoning reads: this loan was approved, therefore this borrower is good; that application was declined, therefore that one was not.

Two things are wrong with it and they compound. The first is that a price for a range of outcomes has been read as a prediction about one outcome. The lender stops holding a distribution in mind and starts holding a list of names sorted into two piles. Once that has happened the pricing question stops being asked at all. A name in the good pile does not need a price, and a name in the other pile does not get one.

The second is the feedback problem drawn above. The lender sees how the loans it made performed and never sees how the ones it declined would have performed. No decline is ever contradicted by evidence. A rule that has quietly narrowed until it is turning away people who would have repaid can run for years, and every number on the approved book looks better each quarter. The book got smaller and safer, and the business got worse.

The cost is a book priced on a distribution the lender has stopped measuring. The evidence that would audit the decline rule is never collected, so nobody can audit it. The fix is one habit rather than a system: ask what would have to be true for this decision to be wrong, and then ask how the lender would ever find out. If the honest answer to the second question is that it would not, that is the thing to fix first.

What lies just outside credit underwriting

Credit cost against provision cost, taken apart criterion by criterion, is covered separately: the one line that separates them is stated above. The records a credit information company holds, the way a score is built and the way an entry gets corrected are covered separately, and so is what alternative data adds to a decision and what it risks. The step by step route from application to money in the account, and the end to end digital version of it, are covered separately. The arrangement in which a partner stands behind the first losses, and the way a lender funds a pool of loans before selling it, each have their own treatment further on. Putting a number on credit risk, whether through a rating scale, a chance of default or the share lost when one happens, is covered separately, and so is the building, validating and governing of a model. Suvarna Commercial Bank Limited, an invented bank that takes deposits, marks the contrast, and the comparison between a lender with deposits and a lender without them is worked properly further along. Every registration, owned funds, capital, provisioning, fair practice, disclosure, recovery conduct, verification and consent condition touched above belongs to the Reserve Bank of India at rbi.org.in, and is read at that address.

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Which door does each blank cell sit behind?

Conditions named here and routed to their sourceWho decides itWhere it is read
Whether a finance company may lend at all, the owned funds it must have before it is registered, and the capital it must hold with the base that requirement is struck onReserve Bank of Indiarbi.org.in read on the day the row is filled
The point at which an advance stops being treated as performing, and what must be provided against it once it doesReserve Bank of Indiarbi.org.in read on the day the row is filled
Fair practice, what a borrower must be told about the cost of a loan before taking it, and the conduct required of anybody recovering what is owedReserve Bank of Indiarbi.org.in read on the day the row is filled
Identity and verification before a loan is made, and what a lender may collect, keep and share about a borrower and on what consentReserve Bank of Indiarbi.org.in read on the day the row is filled
What is required of a party that sources, services or collects a loan on a lender's behalfReserve Bank of Indiarbi.org.in read on the day the row is filled
A published lending series, on the occasion when a number rather than a rule is what is wantedReserve Bank of India, data sitedbie.rbi.org.in read on the day the row is filled

Rukmini Finance Limited, Suvarna Commercial Bank Limited and Setu Payments Limited are invented.
Educational material. Not advice on any investment, tax, budget or market position.

Covered in this topic

Subtopics

Intermediated DistributionCredit CostProvision CostHow Digital Lending Changes Credit Underwriting and Servicing
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