# CBN and Bank of Ghana Credit File Assessment Controls

This evidence note consolidates selected official Nigerian and Ghanaian prudential sources for the fictional Credit File Advisor demonstration. It does not replace a bank's approved credit policy or professional credit judgement.

## Section 1 — Board-approved comprehensive credit policy

The CBN Prudential Guidelines require banks to prepare a comprehensive credit policy approved by the Board. The policy should cover loan administration, disbursement and an appropriate monitoring mechanism and should be reviewed at least every three years.

Primary source: Central Bank of Nigeria, Prudential Guidelines for Deposit Money Banks in Nigeria, 2010, section 3.1. https://www.cbn.gov.ng/OUT/2010/PUBLICATIONS/BSD/PRUDENTIAL%20GUIDELINES%2030%20JUNE%202010%20FINAL%20%20_3_.PDF

## Section 2 — Financial ratios and soundness indicators

The CBN Prudential Guidelines require a process for computing financial ratios and financial soundness indicators to check financial health. Benchmarks should be set, actual results compared with benchmarks at least quarterly, and reports presented to the Board or an appropriate Board committee for deliberation and remedial action.

Primary source: Central Bank of Nigeria, Prudential Guidelines for Deposit Money Banks in Nigeria, 2010, section 13.0.

## Section 3 — Single-obligor and large exposure controls

The CBN Prudential Guidelines state that total outstanding exposure to a single person or group of related borrowers should not exceed 20 percent of shareholders' funds unimpaired by losses. A large exposure is credit to a customer or related group of at least 10 percent of shareholders' funds unimpaired by losses. The applicable current limit must be confirmed before use.

Primary source: Central Bank of Nigeria, Prudential Guidelines for Deposit Money Banks in Nigeria, 2010, section 3.2.

## Section 4 — Credit concentration risk

Banks should maintain effective policies, systems and controls to identify, measure, monitor and control credit-risk concentrations, including significant counterparty exposures, common sectors or regions, dependence on the same activity or commodity, and concentration in collateral or credit protection.

Primary source: Central Bank of Nigeria, Prudential Guidelines for Deposit Money Banks in Nigeria, 2010, section 3.3.

## Section 5 — Credit information and repayment capacity

The CBN Credit Risk Management System supports credit appraisal through accurate borrower information. Banks use borrower information to appraise repayment capacity and reduce lending to customers unable to repay or with non-performing facilities elsewhere. The CRMS captures qualifying credits reported by banks; current reporting thresholds and procedures must be verified operationally.

Primary source: Central Bank of Nigeria, Credit Risk Management System overview. https://www.cbn.gov.ng/supervision/crms.html

## Section 6 — Bank of Ghana risk governance

The Bank of Ghana Risk Management Directive applies to banks and specified deposit-taking institutions licensed under Act 930 and requires risk management proportionate to the institution's size, business mix and complexity. Credit decisions should operate within the institution's risk governance, policies, limits and escalation framework.

Primary source: Bank of Ghana, Risk Management Directive. https://www.bog.gov.gh/notice/risk-management-directive/

## Section 7 — Structured credit memo control

For the fictional demonstration, a structured credit memo should distinguish source facts, calculated ratios, assumptions, missing information, policy tests, mitigants and the human credit decision. Informal business records should be reconciled to bank statements and independently verified where possible. This is a demonstration control derived from Sections 1–6, not a quoted regulatory requirement.