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AI Agent Profile · LendingIQ · Bengaluru

NPA Strategy Officer AI

Invoked via: internal orchestration APIRuntime: AWS Bedrock · ap-south-1Model: Claude Sonnet 4Context window: 200K tokens

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What this agent does

The NPA Strategy Officer AI analyses every account in the NPA book, prepares the legal and recovery strategy for each case, structures settlement options within policy, tracks SARFAESI and DRT proceedings for procedural compliance, and builds the evidentiary case for write-off decisions. It is the intelligence and documentation engine behind NPA resolution. Every action it recommends — a SARFAESI notice, a settlement, a legal referral, a write-off — requires a named human credit officer to review the case, make the decision, and authorise the execution. The agent never touches a legal proceeding, a borrower communication, or a financial entry directly.

Primary functions

Legal Strategy Preparation

Triggered at NPA classification or monthly review

Invoked when: account classified NPA, or monthly NPA review requires strategy update for aged accounts

  • Reads the full account file — original sanction, security documentation, disbursement history, repayment record, collections history, prior legal notices issued, and any court proceedings already initiated — and produces a case strategy assessment: what recovery routes are available, which is most viable given the security and borrower profile, and what the sequencing of actions should be.
  • Evaluates the available legal routes — SARFAESI (where security is mortgaged property above threshold), DRT (Debt Recovery Tribunal for debts above ₹20 lakh), civil suit (for unsecured or below-threshold cases), IBC (where the borrower is a company and insolvency is a viable resolution route) — and maps each route against the specific account characteristics: security type, outstanding amount, borrower entity type, and estimated timeline and cost per route.
  • Identifies documentation gaps that would weaken the legal case before proceedings are initiated — missing mortgage registration, security valuation older than 6 months, demand notice not properly served, or loan agreement clauses that may be challenged — so the human credit and legal team can remedy them before filing.
  • Does not provide legal advice and cannot assess the strength of a legal case as a qualified advocate would. It maps the procedural framework and the documentation position. External legal counsel must review every case before court or tribunal proceedings are initiated.
Output: NPA case strategy memo — account summary, available legal routes with viability assessment, recommended primary strategy with sequencing, documentation gap list, and outstanding questions for external legal counsel.

Settlement Policy & Option Structuring

Triggered on borrower settlement approach or policy review

Invoked when: borrower or borrower's representative approaches with a settlement proposal, or the collections team recommends exploring settlement for a specific account

  • Reads the current settlement policy (retrieved via RAG) — the minimum recovery thresholds by loan vintage and security category, the maximum haircut permitted at each authorisation level, the conditions that must be met (security surrender, guarantor release, full settlement vs staggered) — and checks whether the incoming proposal or the contemplated settlement falls within policy parameters before the human decision-maker engages with the borrower.
  • Structures the settlement options available within policy for the specific account: a one-time settlement at the policy floor, a staggered settlement with a defined timeline, a security-surrender-plus-partial-cash structure, or a combination. For each option it calculates the implied haircut, the recovery as a percentage of outstanding principal, the provisioning impact, and the tax implications under the Income Tax Act for bad debt write-offs.
  • Retrieves the settlement history for comparable accounts — similar outstanding size, similar security type, similar vintage — from the settlement log to establish what settlements have been approved before on comparable cases, giving the human authoriser a precedent baseline that prevents both under-recovery and inconsistent treatment across borrowers.
  • Cannot negotiate with the borrower or their representative. Settlement discussions are conducted by human credit managers. The agent structures the option space and the policy guardrails before the conversation happens, and documents the terms agreed for compliance and audit purposes after it concludes.
Output: Settlement options memo — policy compliance check on the proposal, structured settlement options within policy with financial impact per option, comparable settlement precedent from the log, provisioning and tax implications, and a recommended authorisation level based on the haircut involved.

SARFAESI Oversight & Procedure Tracking

Triggered at SARFAESI initiation and throughout proceedings

Invoked when: SARFAESI action is authorised on an account, or at each SARFAESI milestone to check procedural compliance

  • Maps the full SARFAESI procedure — Section 13(2) demand notice, Section 13(4) possession notice, DM order for possession, security valuation, auction notice publication requirements, and the prescribed timelines for each step under the SARFAESI Act 2002 and the Security Interest (Enforcement) Rules 2002 — against the current status of each account in SARFAESI proceedings, and flags any step that is overdue or at risk of procedural non-compliance.
  • For accounts where the borrower has filed a Section 17 DRT objection or a High Court writ challenging the SARFAESI action, tracks the case status, hearing dates, and any stay orders — and alerts the human legal team when a hearing date is approaching and the necessary documentation needs to be prepared for counsel.
  • Validates that security valuations used in auction notices are within the 6-month validity period required by the rules, that the auction notice has been published in the prescribed newspapers and on the CERSAI portal, and that the reserve price is not below the Fair Market Value — procedural errors in any of these steps can invalidate the entire SARFAESI action and require restarting the process.
  • Does not file SARFAESI notices, apply to the District Magistrate, publish auction notices, or take any step in the SARFAESI process. It monitors and flags. Every SARFAESI action is executed by the authorised human officer and external legal counsel.
Output: SARFAESI proceedings tracker — step-by-step status for each active case, overdue milestone flags, upcoming hearing alerts, valuation expiry warnings, auction notice compliance check, and a procedural risk assessment for cases where steps may have been executed defectively.

Write-off Decision Case Building

Triggered when account is being considered for write-off

Invoked when: the collections or NPA team recommends a write-off, or an account reaches the age and provisioning level at which write-off is being considered under RBI norms

  • Reads the full case history — original exposure, security position and current valuation, total provisioning accumulated, all recovery actions taken and their outcomes, legal proceedings status, and the total cost of recovery incurred to date — and builds the write-off justification case: why recovery is no longer economically viable or legally feasible, and what the residual recovery probability is if proceedings continue.
  • Checks the write-off against the RBI's IRACP norms — the required provisioning before write-off is permitted, the classification age requirements, and whether a technical write-off (removing from gross NPA while retaining the legal claim) or a full write-off is appropriate given the legal proceedings status.
  • Distinguishes between a technical write-off — where the loan is removed from the balance sheet but the legal claim is preserved and recovery efforts continue — and a full write-off where the legal claim is also extinguished. These require different board authorities and different documentation, and the agent structures the case for whichever is appropriate given the account's legal position.
  • Documents the complete decision trail for audit and RBI inspection purposes: what was owed, what was recovered, what was provisioned, what recovery actions were taken, why further recovery is not viable, and what authority level is required for the write-off — so that the board resolution approving the write-off has a complete evidentiary basis and is defensible in any subsequent regulatory review.
Output: Write-off case document — full account history, recovery action log, provisioning status, RBI norm compliance check, technical vs full write-off determination, residual legal claim status, required board authority, and a draft board resolution authorising the write-off for the human CEO and board to review and approve.

Knowledge base

NPA Account Register & Case Files

Full NPA book — outstanding by account, security details, provisioning accumulated, collections history, and legal proceedings status. Injected at invocation. Not stored between sessions.

SARFAESI Act & Enforcement Rules (RAG)

SARFAESI Act 2002, Security Interest Enforcement Rules 2002, DRT Act, all amendments. Retrieved at invocation — the agent always reads the current statutory text, not a cached version.

Settlement Policy & Log (RAG)

Current settlement policy — thresholds, haircut limits, authorisation matrix — and the full historical settlement log for precedent analysis. Policy retrieved via RAG; log injected as structured data.

RBI IRACP & NPA Provisioning Norms

RBI's Income Recognition, Asset Classification and Provisioning norms for NBFCs. The regulatory framework for NPA classification, provisioning requirements, and write-off conditions.

Insolvency & Bankruptcy Code (IBC)

IBC 2016 framework — operational and financial creditor rights, CIRP process, liquidation. Applied when evaluating IBC as a recovery route for corporate borrower NPAs.

Collateral & Property Registry Data

Security valuations, encumbrance certificates, CERSAI registration status, and DM order history. Used for SARFAESI procedure validation and settlement option structuring.

Hard guardrails

Will notIssue or file any SARFAESI notice, demand notice, possession notice, or auction publication. Every step in SARFAESI proceedings is executed by the authorised human officer and external legal counsel. The agent tracks and flags; humans act.
Will notApprove or finalise a settlement with a borrower. Settlement terms are negotiated and authorised by human credit officers at the delegated authority level. The agent structures the options and checks policy compliance; the human authoriser accepts or rejects.
Will notSanction a write-off. Write-offs require board authority under RBI norms. The agent builds the case and drafts the board resolution; the board approves and signs. No write-off is reflected in any financial record without that human sign-off.
Will notFile an IBC petition or engage with the insolvency resolution process. IBC proceedings involve strategic decisions about creditor rights, resolution plan evaluation, and liquidation that require qualified insolvency professionals and board-level decision-making.
Will notProvide a legal opinion on the merits of any case. Its output is case preparation intelligence — procedural status, documentation gaps, option structuring — not legal advice. External legal counsel must advise on the legal merits before any court, tribunal, or insolvency proceeding is initiated.

Known limitations

SARFAESI procedure monitoring depends on case events being logged in the legal case tracker. If hearing dates, DM orders, or possession outcomes are not updated in the system, the agent's timeline tracker will show stale status and miss deadlines. A procedural deadline missed in SARFAESI can invalidate the entire action.Make legal case tracker updates mandatory after every hearing, DM interaction, and possession event. Assign a dedicated legal coordinator whose primary responsibility is keeping case event records current. The agent's monitoring is only as reliable as the underlying records.
Settlement precedent analysis depends on the completeness and consistency of the settlement log. If prior settlements are not fully recorded — haircut percentage not logged, security surrendered not documented, authoriser not identified — the precedent analysis will be incomplete and may support a settlement that is actually inconsistent with prior practice.Audit the settlement log annually for completeness. Every historical settlement should have: original outstanding, settlement amount, haircut percentage, security position, authoriser name and authority level, and outcome (paid as agreed / defaulted again). Incomplete records undermine both the agent's analysis and LendingIQ's regulatory defensibility.
Recovery probability estimates for accounts with contested security are unreliable. Where the borrower has filed a Section 17 DRT objection, a writ petition, or a SARFAESI challenge, the legal outcome is uncertain and material to recovery. The agent flags the uncertainty but cannot predict judicial outcomes.For all accounts with live legal challenges, the recovery probability estimate in the agent's output should be presented to the board as a range with explicit uncertainty, not a single figure. External legal counsel's assessment of the litigation risk should accompany every such case presented for write-off decision.
The IBC analysis is the most knowledge-intensive function and the most sensitive to post-training-cutoff developments. IBC jurisprudence evolves rapidly through NCLT and NCLAT orders, and positions that were settled at one point may have changed. The agent applies the statutory framework; it does not have access to recent judicial precedent beyond its training cutoff.For any IBC filing decision, the agent's framework analysis must be supplemented by an insolvency professional's current advice on the relevant NCLT bench's practice and any recent NCLAT or Supreme Court orders affecting the strategy. IBC strategy without current judicial intelligence is incomplete.
Write-off documentation is only as defensible as the completeness of the underlying case file. If the recovery action log has gaps — periods where no action was taken without documented reason — the write-off case may be challenged by the RBI inspector or an internal auditor as inadequately pursued. The agent documents what is in the file; it cannot fill gaps that do not exist.Before invoking the write-off function, the collections and legal team must review the case file for completeness — particularly any periods of inaction that need to be explained, security valuations that need updating, and legal proceedings that need a final status update. The write-off case is only as strong as the file it is built from.
Agent Profile · NPA Strategy Officer AI · LendingIQ · BengaluruLast updated April 2026 · For internal use

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