7)
active enforcement to client accounts kept in the Bank, if the oldest active enforcement order persists for
more than 90 days and the total amount of active titles exceeds PLN 100 thousand; PLN for customers of
the corporate sales network or PLN 500 thousand for strategic clients,
8)
unsettled claims under guarantees granted by the Bank (lack of customer funds), if the customer's overdue
liability to the Bank due to the payment of the guarantee by the Bank persists for more than 45 days from
the date of payment of the guarantee claim,
9)
termination of a loan agreement with another bank of significant value,
•
a material breach of contractual terms by the customer, which may have a negative impact on future cash
flows from a given financial asset (if there has been a material breach of contractual terms, but the Bank, after
identifying and assessing the causes and effects of such breach, accepted them (temporarily or permanently)
or changed, such an event is not treated as a trigger for impairment),
•
unknown whereabouts of the client, resulting in a lack of representation in contacts with the Bank and
undisclosed assets of the client,
•
crisis of the sector in which the client operates, combined with the borrower's weak position in a given sector,
•
restructuring of the loan receivable for non-commercial reasons related to significant financial difficulties of
the client, resulting in a change to the existing terms of the contract, full or partial refinancing of the exposure
at risk, which would not have occurred if the client had not experienced these financial difficulties (including
forbearance) and loss of the net present value of cash flows is equal to or less than 1%,
•
credit fraud of the debtor towards the Bank or another ING Group entity,
•
the exposure has received a forbearance 2 or more times in the last 5 years,
•
a significant deterioration of the client's rating resulting in its reclassification to a risk class of at least 17 with
a simultaneous drop by at least 4 classes.
The Bank has also determined the following additional triggers for impairment for leveraged transactions (i.e.
transactions with a high level of debt relative to operating profit):
•
a significant breach of an important financial clause or failure to return to the state from before the breach,
especially when the customer simultaneously requests a repayment facility,
•
forbearance refinancing of the existing borrower with an increased level of financial leverage (IBD / EBITDA, i.e.
interest bearing debt / earnings before interest, taxes, depreciation and amortization, total liabilities / profit
before deduction of interest on interest-bearing liabilities, taxes and depreciation) compared to leverage levels
at the time of funding or previous refinancing,
•
refinancing of the exposure with the repayment of the entire mobilised capital at the end of the loan period in
the event of financial difficulties of the client and with a low probability of refinancing by another bank under
current market conditions,
•
the base case and stress case scenarios indicate the lack of sufficient and stable cash flows to service the debt
in accordance with the adopted schedule;
and the following additional triggers for the revenue-generating real estate financing transactions:
•
LTV (Loan to Value) > 90% and this is not a temporary situation,
•
historical DSCR (debt service cover ratio) ratio < 1.0 or ICR (interest coverage ratio) < 1.0 (depending on which
indicator is used for transaction risk assessments) for two consecutive annual accounting periods and cash
flows generated by the real estate are, in the opinion of experts, insufficient to repay and service the loan in
accordance with the adopted schedule.
The triggers for impairment for
retail credit exposures
and
credit exposures to entrepreneurs
include:
•
failure to meet a minimum of three debt repayment arrangements within the current period of arrears,
•
a natural person who has issued a surety in the Bank for significant obligations of their company is in default
or a natural person is a debtor of the Bank and their company is in a state of default,
•
the business client is related to the same group of debtors (legally or economically) in which one of the
debtors is defaulted,
•
no intention or possibility of repayment – in the Bank 's opinion, the debtor does not want to pay off the
obligation or is unable to pay; the inability to repay the liability occurs when the debtor's sources of income
are insufficient to repay the instalments due, e.g.:
−
for an individual client: loss of job, termination of social benefits payments, divorce, serious illness, death of
the debtor, obtaining information on untimely servicing of a debt of significant value in another bank (over
90 days overdue) or commencement of enforcement / debt collection activities by another bank,
−
for a business client: (anticipated) cash shortfall, (anticipated) high or sudden increase in leverage,
(anticipated) breach of financial clauses, (anticipated) deterioration in a market where the debtor's position
is weak,
•
approving a forbearance to the customer that is not able to repay its financial obligations under a loan
agreement with the Bank due to existing or anticipated financial difficulties,
•
credit fraud of the debtor towards the Bank – reasonable suspicion of extortion of a loan, i.e. an obligation
whose credit documentation or the established facts indicate that it was granted as a result of deliberate