NPL Strategy Officer AI

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

• –Reads the full account file — original approval, 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 — member-state collateral enforcement under national law (with EU overlays such as the Financial Collateral Arrangements Directive 2002/47/EC and the NPL Directive 2021/2167/EU where applicable), national civil enforcement courts (thresholds vary by member state), civil suit (for unsecured or below-threshold cases), and EU Insolvency Regulation proceedings (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.

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 applicable member state corporate tax law for bad debt deductibility.
• –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.

Invoked when: member-state collateral enforcement action is authorised on an account, or at each member-state collateral enforcement milestone to check procedural compliance

• –Maps the full member-state collateral enforcement procedure — pre-enforcement demand, enforcement order or attachment, security valuation, public sale or auction notice and publication requirements, and prescribed timelines under national collateral and insolvency law (with EU FCA Directive 2002/47/EC and NPL Directive 2021/2167/EU overlays where relevant) — against the current status of each account in enforcement proceedings, and flags any step that is overdue or at risk of procedural non-compliance.
• –For accounts where the borrower has filed a national court challenge or appellate review of the enforcement 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 sale notices are within the policy validity window, that required notices have been published per national law and land or company charges registries, and that the reserve price is not below fair market value — procedural errors in any of these steps can invalidate the entire enforcement action and require restarting the process.
• –Does not file enforcement notices, obtain court orders, publish sale notices, or take any step in the enforcement process. It monitors and flags. Every enforcement action is executed by the authorised human officer and external legal counsel.

Invoked when: the collections or NPL team recommends a write-off, or an account reaches the age and provisioning level at which write-off is being considered under ECB / EBA 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 ECB / EBA's EBA NPL classification standards — the required provisioning before write-off is permitted, the classification age requirements, and whether a technical write-off (removing from gross NPL 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 ECB / EBA 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.