The Reserve Bank of India (RBI) has provided a limited period window to restructure loans without downgrading the loan account to “non-standard” for (eligible) customers affected by the COVID-19 pandemic. On its own, debt restructuring is an excellent tool to allow customers to re-negotiate the terms and ensure that the bank recovers its principal. It is, however, important to have continued focus on credit and fraud risk and to use the tool effectively for risk mitigation (not for book growth).
At Think Analytics, we help our partner clients manage such risks through multiple offerings, like credit risk scorecards and probability of default models, developed by our team of data scientists. There is also the option to integrate with Algo360, our flagship product for alternate data elements; commence remote KYC validation through Kwik.ID, our video KYC product; and develop custom applications (web and mobile) for lenders to embark on a digital transformation journey.
Together, we can devise a solution that can be applied as a preventive risk mitigation policy. This solution can also be used for providing top-up to customers who are on the other side of the curve, displaying financial stability.
Challenges in the financial ecosystem affecting customers
Each customer is re-evaluated on their current capability to service a loan—however, six months of payment holiday unfavourably impact the intent to pay even when they have the ability.
The following table presents some of the recent challenges faced by customers:
What is loan restructuring?
When a borrower faces financial stress, they reach out to their lender to revise the terms of their credit facility by modifying one or a combination of tenure of loan/ interest payable on residual loan amount/ outstanding loan. This ensures that as a borrower, one does not miss out on payments towards their loan. Basel norms define debt restructuring as an indicator of asset quality going northwards and wants banks to keep capital allocation for the eventuality.[i] Among the Asian Tigers, debt restructuring was considered as standard business practice in the early 2000s until the global financial crisis.
While debt restructuring is efficient tool to ensure that the bank recovers its principal, it has its own set of challenges. For example, since 2018 in India, there have been instances of a few stalwart banking leaders being asked to move on as debt evergreening was highlighted as favouritism.
Financial institutions can leverage data from the credit bureau as well as review customer behaviour and professional details to help customers plan their restructuring requests (for more information, check Appendix 1a and 1b).
Loan restructuring in five easy steps
- Pre-approved customer list, eligible as per lender’s policy
- Risk scorecard for approved customers along with updated offer details
- Send SMS to eligible customers with a link to open a web/mobile widget for application. Link expires in 30 days
- Auto populate available customer details as per lender’s database
- Request for alternate data—current address, proof of current income
- Offer optional integration with Kwik.ID to verify KYC details. Our video KYC product Kwik.ID currently helps our clients conduct1500+ sessions daily. Kwik.ID is designed to ensure that video KYC is possible even with low bandwidth
- Offer optional integration with Algo360 for mobile app-based customers, to triangulate alternate data on income and net debt obligations
- Integrate with business rule engine configured with risk and policy rules to determine revised terms of loan
- Share updated loan details and T&C with customers, e.g., SMS, email, mobile app notifications
1a: How can existing customer data aid in restructuring?
Financial institutions can leverage data from the credit bureau as well as review customer behaviour and professional details to help customers plan their restructuring requests.
While using data from the bureau and analyzing customer behaviour are ideal sources of risk evaluation in a normal world, they have proven to be inadequate amid the pandemic.
The onus of ensuring correct status post moratorium is on the customer and not on the bank or bureau. Currently, most scorecards depend heavily on repayment cycles and other behavioural indicators that have lost their importance. The stringent timeline by RBI to restructure loans for all such customers by 18 December 2020is further adding to the problem. Hence, it is of paramount importance that alternate macro-and-micro data is made a part of the decision making.
1b: Restructuring as an opportunity for better customer service
Loan-restructuring requests can be serviced in the following ways:
1. Customer approaches the bank for restructuring:
a. Request lender for restructuring by logging on to the website or mobile app form (validity limited as per RBI timelines) for such requests
b. Request through emails or calls: Customers are directed to a mini form that captures customer request to restructure loan
c. Show updated details: If customer is already pre-approved for restructuring, then show updated details, otherwise request for alternate data
d. Verify details submitted by customers and communicate decision
2. Banks/NBFCs approach eligible customers
a. Identify customers eligible for restructuring
b. Share SMS/email link with customers to fill form and alternate data
c. Verify details submitted by customers and communicate decision