Re-categorisation of Non-performing Exposures as Performing
CM-1.8.15
A Stage 3 exposure can be moved to Stage 2 or Stage 1 when all the following criteria are met simultaneously:
(a) Thecounterparty does not have any exposures that are past due for 90 days or more (see also Paragraph CM-1.8.6);(b) Repayments have been made when due in accordance with Appendix CM-6.
However, if the repayments are not clearly reflective of improvement in thecounterparty ’s financial position, a longer re-payment history or higher number of instalments must be assessed by thelicensee before re-categorisation of the exposure to a ‘performing’ status;(c) Thecounterparty ’s financial situation has improved so that the full repayment of the exposure is likely, according to the original or, when applicable, modified conditions. This must usually require a credit review process that evaluates the obligor’s current capacity to repay, clarity on the source of cash flow available for repayments, improvements in the level of indebtedness and compliance with various financing covenants imposed by thelicensee . Repayments through liquidation or enforcement ofcollateral is generally not considered as an improvement in the financial health of the obligor; and(d) The exposure is not considered to be in ‘default’ or ‘impaired’ according to the applicable accounting and risk management frameworks.Amended: April 2023
Added: June 2022CM-1.8.15A
Stage 2 exposures can be moved to Stage 1 after the cooling-off period, specified in Appendix CM-6, has passed and the
counterparty’s financial situation indicates it to be equivalent to that of a ‘very lowcredit risk ’ exposure.Added: April 2023CM-1.8.16
Islamic bank licensee must clearly articulate and document policies in respect of the counting of days past due, in particular in respect of the re-ageing of the facilities and the granting of extensions, deferrals, renewals and rewrites to existing accounts. At a minimum, the re-ageing policy must include:(a) Approval authorities and reporting requirements;(b) Minimum age of a facility before it is eligible for re-ageing;(c) Delinquency levels of facilities that are eligible for re-ageing;(d) Maximum number of re-ageing allowed per facility; and(e) A reassessment of the obligor’s capacity to repay.Added: June 2022CM-1.8.17
For the purpose of CM-1.8.16, re-aging occurs when the
licensee changes the tenor or due dates of the credit when rescheduling or restructuring a facility.Added: June 2022CM-1.8.18
Non-performing exposures in the following situations must not be re-categorised as performing without meeting the conditions set forth in CM-1.8.15:
(a) Partial write-off of an existing non-performing exposure (i.e. when thelicensee writes-off part of a non-performing exposure that it deems to be uncollectible);(b) Repossession ofcollateral on a non-performing exposure; or(c) Extension or granting of forbearance measures to an exposure that is already identified as non-performing.The re-categorisation of a non-performing exposure as performing must be made on the same level (i.e. obligor or transaction approach) as when the exposure was originally categorised as non-performing.
Added: June 2022CM-1.8.18A
Non-performing POCI exposures may be re-categorised as performing subject to meeting the conditions stipulated in Paragraphs CM-1.8.15 to CM-1.8.18.
Added: April 2023CM-1.8.19
Islamic bank licensees must have the necessary tools to ensure a robust estimate and timely recognition of ECL. Information on historical loss experience or the impact of current conditions may not fully reflect thecredit risk in financing exposures. In this context, thelicensee must use its experienced credit judgment to thoroughly incorporate the expected impact of all reasonable and supportable forward-looking information, including macroeconomic factors, on its estimate of ECL. Thelicensee’s use of its experienced credit judgment must be documented in thelicensee’s credit risk methodology and subject to appropriate oversight.Added: June 2022CM-1.8.20
Applying the concepts of ECL could vary for each
licensee depending on its underwriting criteria, loss history, terms ofcollateral and a number of other variables, both entity-specific and external. Reasonable and supportable information will not present itself, but would rather require management to determine what is relevant and practical, without undue costs or efforts, to actively gather, analyse and process to make requiredcredit risk assessments to support the ECL process.Licensees will need to adopt an appropriate risk assessment methodology which is commensurate with the size, complexity, structure, economic significance and risk profile of their portfolio. This means that, in general, the larger and more complex a portfolio or institution, the more its risk infrastructure should capture relevant and reliable information and trends that would support the development of a sophisticated approach to determine a risk based ECL. Conversely, for smaller and simpler portfolios or institutions, a less sophisticated approach may be adopted to align with the risk management infrastructure and processes within thelicensee .Added: June 2022CM-1.8.21
Regardless of the size of the
licensee or prominence of the portfolio, the approach adopted by thelicensee should comply with the specific requirements of this section and applicable accounting standards. It is not necessary that everylicensee or every portfolio within thelicensee would apply the same level of sophistication. However,licensees will need to periodically assess whether their approach continues to be appropriate and relevant in light of changing circumstances with the aim of improving its level of estimation over time.Added: June 2022