Situ LMS · Officer

Read model gaps

3 source gaps

Schedule: Loan schedule read is unavailable.
Status timeline: Loan status timeline read is unavailable.
Restructure simulation did not return a proposed schedule.

Restructure options

blocked by gap

Term extension

blocked

No proposed schedule returned

Simulation reason was not returned.

Payment holiday

blocked

Requires borrower affordability and status evidence

Current schedule unavailable.

Rate or fee concession

blocked

Interest delta Ksh 0

Requires approval route and borrower disclosure before acceptance.

Balance write-down

blocked

Principal delta Ksh 0

Committee route is required when principal compromise exceeds policy caps.

Impact analysis

simulation Unavailable

Metric	Current	Restructured	Delta
Principal	Ksh 0	Unavailable	+Ksh 0
Interest	Ksh 0	Unavailable	+Ksh 0
Fees	Ksh 0	Unavailable	+Ksh 0
Total repayable	Ksh 0	Unavailable	+Ksh 0
Term change	0	+0	+0
DSR change	0.00	+0.00	+0.00

Classification and regulatory context

DCP 2022 · IFRS 9 · CRB Regs 2020 · Banking Act §44A

Contract change type

Restructure — in-contract modification (existing loan ID retained)

Refinance distinction

Refinance = new disbursement + redemption of current obligation; triggers fresh KYC, new DCP TCC/APR disclosure, and a new loan ID — not this workflow

IFRS 9 stage at restructure

S1→S2 if significant credit-risk increase (SICR) present at modification date (e.g. >30 DPD, forbearance flag, income shock). S2→S1 only after 12 consecutive performing months (cure period per CBK DCP guidance).

ECL provision impact

Stage migration increases provision: lifetime ECL applies from S2 onwards. Disclose net remeasurement in credit-impairment note; update ECL model inputs with restructured cash flows.

CRB reporting (CRB Regs 2020)

Report account with status code "R" (Restructured). Account remains in CRB database; 30-day pre-listing notice is still mandatory on first listing. Code clears only after full cure.

In-duplum cap (Banking Act §44A)

Confirm accrued interest does not exceed outstanding principal at restructure date. If cap reached, interest accrual must cease until principal is reduced by repayment.

Approval workflow

Prepare packet

Borrower status

Unavailable

Current final due

Unavailable

Proposed final due

Unavailable

Approval route

Officer plus maker-checker

Submit restructure request

pending checker

Checker review

0 pending0 ready

No servicing requests have been submitted for this loan.

Proposed schedule preview

0 rows

No.	Due date	Principal	Interest	Total	Balance	Status
No proposed schedule rows were returned.

Restructure preview

Read model gaps

Restructure options

Term extension

Payment holiday

Rate or fee concession

Balance write-down

Impact analysis

Classification and regulatory context

Approval workflow

Submit restructure request

Checker review

Proposed schedule preview