Hard Bucket Agent AI

Invoked when: NPL Strategy Officer authorises legal notice preparation for a specific account or account batch

• –Reads the account's full CRM history — outstanding principal and interest, all prior contact and payment attempts, any settlement discussions, and the loan agreement terms — and populates the appropriate legal notice template from the counsel-approved library: demand notice under general law, formal default or acceleration notice under applicable member-state mortgage and collateral law for secured loans above the applicable threshold, or Arbitration notice per the loan agreement's dispute resolution clause.
• –Produces a draft notice with all factual fields populated — borrower name and address as per KYC / AML, outstanding amount as per CBS, notice date, response deadline, and the consequence language approved by legal counsel for that notice type. The draft is explicitly watermarked "DRAFT — LEGAL COUNSEL REVIEW REQUIRED" and is not dispatched from within this agent.
• –Flags any factual inconsistencies in the draft that require resolution before dispatch: address discrepancies between the KYC / AML record and the loan agreement, outstanding amount disputes that are open in the CRM, or accounts where a restructuring application is pending — because dispatching a legal notice while a restructuring negotiation is live creates both legal and regulatory complications.
• –Does not practise law, interpret the enforceability of specific notice provisions, or advise on the litigation strategy. The draft populates facts into a counsel-approved template — the legal counsel who reviews the draft makes all substantive legal judgments about its content and enforceability.

Invoked when: borrower indicates willingness to settle, or the NPL Strategy Officer requests a settlement options analysis for a specific account

• –Reads the Board-approved settlement framework from the policy RAG — the permitted haircut bands by DPD vintage, outstanding amount band, and collateral coverage — and applies the framework to the specific account to produce a structured options brief: the minimum acceptable settlement amount at this DPD under the current policy, the recommended opening offer range, and the maximum allowable haircut that the NPL Officer can approve within delegated authority.
• –Presents the options in a structured brief for the NPL Strategy Officer or the human negotiator: Option A (minimum haircut, full principal recovery with waiver of penal charges), Option B (partial principal haircut within policy band with full penal waiver), and Option C (maximum policy haircut with one-time settlement structure). Each option shows the cash recovery, the provisioning release, and the NPV of recovery versus continued litigation — the financial analysis the NPL Officer needs to select an approach.
• –Does not negotiate with the borrower, make settlement offers, or approve any haircut. The settlement brief is an internal analysis document for the NPL Strategy Officer and the human negotiator. All borrower-facing settlement communication and all settlement approvals are human acts.

Invoked when: NPL Strategy Officer authorises recovery agency assignment for an account

• –Assembles the complete agency hand-off file: borrower identity and contact details (as per KYC / AML — not any informal contacts), loan agreement summary (approved amount, outstanding principal and interest, penal charges, security interest details), complete payment history since origination, CRM contact log summary, all prior recovery attempts and their outcomes, and the legal notice status (whether the applicable member-state formal default or acceleration notice has been served and the response or absence thereof).
• –Prepares the agency mandate document within the parameters authorised by the NPL Strategy Officer: the recovery target, the permitted contact methods (governed by the EBA Guidelines on arrears and forbearance (EBA/GL/2015/12), Consumer Credit Directive debt collection provisions, and applicable national consumer protection law — no third-party contact, no contact outside 8 AM–7 PM, no threatening behaviour), the reporting cadence required from the agency, and the escalation triggers that require the agency to refer back to LendingIQ rather than acting independently.
• –Documents the agency assignment in the CRM and Audit Trail Agent AI — the date of assignment, the agency identity, the mandate scope, and the authorising officer. EBA Guidelines on arrears and forbearance and national consumer protection requirements for recovery agents require that the engagement of an external recovery agent and the instructions given to them be documented and available for regulatory inspection.