Loan origination and IFRS 9
Credit risk is a lifetime, not a cutoff
Decide → watch → stage → hold
Originate, monitor, stage, and provision are layers. Models are lanes. A score at application is not the loss you hold — name SICR before anyone books the number. How the number is built lives on the Analytics card (grain, truth, consume).
ORIGINATEDecision — creditworthiness, policy, engineMONITORBook — arrears, emerging risk, in-production scoresSTAGEIFRS 9 — SICR, stage 1 / 2 / 3PROVISIONECL — 12-month or lifetime, PD · LGD · EAD, overlayProblem → use → example
| If the real problem is… | Use | Example case |
|---|---|---|
| New credit without a named affordability test | Origination standard | B2B partner or consumer loan: creditworthiness, data used, and who can override — not a gut “looks fine” |
| Cut-off set once, never watched | In-production scorecard | Application PD: cut-off, through-the-door mix, and override rate on a named cadence — a launch deck is not monitoring |
| Each cut-off trial is a full book backtest | Bayesian opt | Spend the next portfolio run where last week’s surface still moves the decision. Don’t grid forty cut-offs because the engine can. |
| Policy lives in a person, not the engine | Credit engine + owner | Rule or score change in the engine: test, named owner, rollback — chat is not the policy |
| Book looks calm; early arrears are not | Portfolio watch | Segment PD vs observed default; vintage and product — steering is a change, not a slide |
| Everyone is still “performing” | SICR / staging | Significant increase since origination → lifetime ECL (stage 2); credit-impaired → stage 3. A missed payment is a trigger, not a debate |
| Allowance is a round number from last year | ECL methodology | PD × LGD × EAD, 12-month vs lifetime, forward-looking info — a spreadsheet total is not IFRS 9 |
| Model is blind to the downturn you can see | Judgement overlay | Named overlay, size, and exit test; experienced credit judgement is a control, not a plug |
| PD/LGD/EAD don’t match the grain of the book | Named risk parameters | Auto-loan lifetime ECL: account grain, remaining term, prepayment — Analytics card owns the gold table; this card owns the stage |
| Override rate is “how we actually decide” | Override governance | Who can stretch policy, why, and how it is sampled — silent overrides are a second scorecard |
| Capital model and IFRS 9 model never speak | Know the two jobs | IRB EL ≠ IFRS 9 ECL. Reconcile the difference; don’t paste one into the other |
Default order: creditworthiness + policy in the engine → watch the book and the score → stage on SICR → hold 12-month or lifetime ECL (overlay named). Analytics owns grain and gold; this card owns the decision and the stage.
Tool picker
EBA origination GLCreditworthiness, monitoring, model governance
IFRS 9Staging, SICR, 12-month vs lifetime ECL
EBA ECL GLSound ECL practices next to the Standard
BCBS ECL guidanceJudgement, data, and allowance quality
IRB differentiationPD that actually ranks risk — not a label
IFRS 9 supportImplementation notes, not a vendor deck
PD · LGD · EADName the three; freeze the cut you used
Decision vs number
Decision · originate
Creditworthiness, policy, engine, override. A score without a cut-off owner is not a decision.
Number · hold
Stage, then ECL. Analytics can build the table; this card still owns SICR and the overlay.
Memory check
ORIGINATE = decision. MONITOR = book. STAGE = SICR. PROVISION = the loss you hold.
Ladder + gates
- Creditworthiness + policy in the engine
- Cut-off + override owner
- In-production monitoring
- SICR / stage 1–3
- PD · LGD · EAD at the right grain
- Overlay named — or no plug
Kill switch
If you can’t name the stage, the parameters, and who owns the overlay, you don’t book the number.
Anti-patterns
- Cutoff as the whole risk system
- Silent overrides as a second policy
- Stage 1 forever because “they’re paying”
- Pasting IRB EL into IFRS 9 ECL
- Unnamed overlay that never exits
- Scorecard with no in-production watch
- Vendor brochure as the methodology
- Building gold tables and skipping staging
Always on
SecurityWho can see PII and flip a policy rule
GovernanceModel, cut-off, and overlay owners
ObservabilityScore, arrears, and stage movement
EvalsBacktest and through-the-door mix
Human ApprovePolicy, SICR, overlay — not auto-booked