A bank lets an agent decide renewals of SME facilities up to €250,000 under mandate LC-04.1. On 20 October the third referral in thirty days for the same reason, accounts fifteen months old read from a register feed, narrows the mandate to recommend. The latest accounts of that borrower show a covenant breach. A renewal permitted at 14:05 is in the night’s booking batch, 380 renewals bunch at the month end, and the first and second line disagree about when the mandate comes back. The room decides what happens next.
The credit case of the control plane map: facility 5208 and the referral of facility 5216, accounts FY2024/25 against FY2025/26, mandate LC-04, rule R-04, and the loop that narrows on the third referral. The dossier adds the renewal in the batch, the breach in the third file, and the month end.
The bank reviews 40,000 SME facilities a year; about 17,600 renewals pass through the agent, some 70 a working day, and twice that in the last week of a month. Under LC-04.1 the agent decides renewals at the same or a lower limit and asks the core banking system to book; bookings run in a batch at 22:00, and the renewal letter goes out the next morning. Rule R-04 narrows the mandate to recommend after three referrals for one reason in thirty days, and at once if a renewal is found booked on a breached covenant. The agent reads the borrowers’ accounts from a register feed refreshed in January and July; the clients deliver their accounts to the credit file under their information undertaking.
| Claim | Source | Owner | Valid |
|---|---|---|---|
| B-4530’s debt service cover for the year to 30.06.2026 is 0.9 | accounts FY2025/26, delivered 30.09.2026 | the credit data team | from 30.09.2026 |
| B-4530’s debt service cover for the year to 30.06.2025 is 1.4 | accounts FY2024/25, register feed | the credit data team | to 29.09.2026, superseded |
| A renewal is decided on the latest accounts at the date of decision | credit policy v8 §3.2 | credit risk | in force |
| The agent may decide a renewal only with no covenant breach | mandate LC-04 conditions | Head of SME Lending | in force |
| A covenant breach is tested when the annual accounts arrive | credit policy v8 §5.1 | credit risk | in force |
The accounts the borrower delivers are the binding source for its figures. The claims are what the agent may use, each traced to its line; where the feed and the credit file disagree, the credit file wins, and the claim is corrected.
The core banking system holds the credential to book. The agent cannot book; it can only ask, through the check.
“Our line was renewed on 10 October, and we are grateful. But our relationship manager mentioned that the first review used last year’s accounts, although we delivered this year’s on 30 September as our agreement requires. Was our renewal decided by a system, on which figures, and by whom? We are about to ask for an increase, and we would like to know how that will be looked at.”
The fourteen fields of the record line (part three, slide 9), filled for this act; Exhibit E on page 4 continues the record on the day of the dossier.
| Field | What it holds | Facility 5208 · the clean act |
|---|---|---|
| Before the act · what the check read | ||
| when | the second the check decided, and the second the act committed | decided 08.10.2026 07:52:14 · committed 22:00:07, the booking batch |
| the agent and its identity | which agent, acting for whom, under its own identity, and how long its credential lived | credit-agent-03, acting for SME Lending · its own identity · token issued 07:40:05, valid 15 minutes, renewed once |
| the release | the release id, each model by version and hash, the prompt set, the validation report | v1.8 · tier-1 model 2026.07.1 (a17f5c) · tier-2 model 2026.05.2 (e9a3b7) · prompt set credit-renew 1.8 · validated by model risk, MRV-052, 25.08.2026 |
| the basis | each claim the act relied on, its version, and its standing at that second on both axes: evidential warrant, and authority | The borrower’s latest accounts are FY2025/26, the year to 30.06.2026 · the credit file · delivered 30.09.2026 under the information undertaking · read because the register feed holds no filing for B-4417 · warrant validated · current · uncontradicted · authority: the borrower, under the facility agreement · the credit data teamB-4417 rates 5 of 10, debt service cover 1.6 · the approved rating model, version 4.2 · run 07:46 · warrant validated · a model approved by model risk · authority: credit risk, the model ownerA renewal of up to €250,000 at a rating of 6 or better may be decided within the mandate · credit policy v8 §5.3 · warrant foundational · in force · authority: the credit committee |
| the mandate version | the mandate in force at that second, with its level and its limit | LC-04.1 · since 01.09.2026 · decide renewals · €250,000 a facility · €250m a month across the deployment |
| the control standard | the control standard version and the rule set the check applied | CS-4 v2026.2 · rule set RS-LC-04 r6 |
| the consequence tier | the tier the act was classified into, and the version of the taxonomy that classified it | material · taxonomy CT-2026.1 · €180,000 for twelve months, a contract with legal effect, counts toward the group limit |
| At the act · what the check decided | ||
| the check’s decision | permit, refer, or block, how many of the six inputs held, and the reason code | PERMIT · six of six · reason code OK · eight policy checks of eight |
| the exact act | what was done, to whom, for how much, under which id, once | renew facility 5208 · €180,000 to 31.10.2027 · pricing, security, and covenants unchanged · F5208-R1 · once |
| the permit | its id and what it was bound to: the mandate version, the release, the basis version, the exact act; and how long it held | PR-5208-1 · bound to LC-04.1, release v1.8, accounts FY2025/26 and the rating run of 07:46, €180,000 on F5208 to 31.10.2027 · valid for the next booking batch |
| After the act · what came back | ||
| the receipt | what the receiving system returned, and the reconciliation against it: one permit, one act, one receipt | K-5208 · limit booked 22:00:07 · renewal letter L-5208 issued 09.10 · acknowledged by the core banking system · reconciled against the facility ledger: one permit, one booking, one receipt |
| the human decision | where a person decided: who, under which authority, what they confirmed, and when | none needed |
| the cost | what the decision cost in tokens, and in a person’s time where one was needed | €1.53 in tokens · no officer time |
| retention | how long the record, the manifest, and the permits are kept, and personal data inside them by its purpose | the record, the manifest, and the permits: ten years from the end of the facility, the period the bank sets for credit decisions of this tier (illustrative) · personal data by purpose and retention rule · a corrected fact is a new, linked entry |
control standard CS-4, version 2026.2 · rule set RS-LC-04 r6: refer any rating override, any covenant breach, any increase, any mismatch of basis · CT-2026.1 · the bank’s consequence taxonomy · proposed by the CRO with compliance and SME Lending, set by the board, 06.2026 · ids and figures invented
The fourteen fields of the record line (part three, slide 9), filled for this act; Exhibit E on page 4 continues the record on the day of the dossier. The agent’s line and the person’s are marked R1 and R2.
| Field | What it holds | Facility 5216 · the referral |
|---|---|---|
| Before the act · what the check read | ||
| when | the second the check decided, and the second the act committed | R1 referred 08.10.2026 08:07:40R2 decided 08.10.2026 15:40:12 · booked 10.10 in the 22:00 batch · letter issued 12.10 |
| the agent and its identity | which agent, acting for whom, under its own identity, and how long its credential lived | R1 credit-agent-03, acting for SME Lending · its own identity · token valid 15 minutesR2 credit officer C-031, SME Lending · her own login · lending authority €500,000 |
| the release | the release id, each model by version and hash, the prompt set, the validation report | R1 v1.8 · tier-1 model 2026.07.1 (a17f5c) · tier-2 model 2026.05.2 (e9a3b7) · prompt set credit-renew 1.8R2 none · a person’s decision in the credit system |
| the basis | each claim the act relied on, its version, and its standing at that second on both axes: evidential warrant, and authority | The borrower’s latest accounts are FY2024/25 · declared: the register feed, refreshed 07.2026 · superseded in the credit file since 30.09.2026 · warrant fails on currency · contradicted by the credit file · authority: the register · the credit data teamThe borrower’s latest accounts are FY2025/26 · applicable: the credit file · delivered 30.09.2026 · spread by C-031 at 15:10 · warrant validated · current · authority: the borrower, under the facility agreement · the credit data teamB-4423 rates 6 of 10, debt service cover 1.5 on FY2025/26 · the approved rating model, version 4.2 · run 15:12 · warrant validated · authority: credit risk, the model owner |
| the mandate version | the mandate in force at that second, with its level and its limit | R1 LC-04.1 · decide renewals · €250,000R2 the officer’s lending authority · €500,000 · the delegated lending authorities |
| the control standard | the control standard version and the rule set the check applied | CS-4 v2026.2 · rule set RS-LC-04 r6 |
| the consequence tier | the tier the act was classified into, and the version of the taxonomy that classified it | material · taxonomy CT-2026.1 |
| At the act · what the check decided | ||
| the check’s decision | permit, refer, or block, how many of the six inputs held, and the reason code | R1 REFER · five of six · reason code BASIS-01: declared FY2024/25, latest FY2025/26 for B-4423 · owner: SME credit officersR2 PERMIT · the officer’s decision · eight policy checks of eight |
| the exact act | what was done, to whom, for how much, under which id, once | R1 proposed: renew facility 5216 · €180,000 to 31.10.2027 · F5216-R1 · not executedR2 renew facility 5216 · €180,000 to 31.10.2027 · F5216-R2 · once |
| the permit | its id and what it was bound to: the mandate version, the release, the basis version, the exact act; and how long it held | R1 none · the proposal went to the officers’ queue with the reasonR2 PR-5216-2 · bound to the officer’s authority, accounts FY2025/26 and the rating run of 15:12, €180,000 on F5216 · valid for the first booking batch after the renewal documents are signed |
| After the act · what came back | ||
| the receipt | what the receiving system returned, and the reconciliation against it: one permit, one act, one receipt | R1 noneR2 K-5216 · limit booked 10.10 22:00 · renewal letter L-5216 issued 12.10 · acknowledged by the core banking system · reconciled |
| the human decision | where a person decided: who, under which authority, what they confirmed, and when | R1 none yet · referred to a person with the reasonR2 credit officer C-031 spread FY2025/26, ran the rating, and renewed at €180,000 at 15:40 |
| the cost | what the decision cost in tokens, and in a person’s time where one was needed | R1 €1.53 in tokensR2 €60.00 of an officer’s time |
| retention | how long the record, the manifest, and the permits are kept, and personal data inside them by its purpose | the record, the manifest, and the permits: ten years from the end of the facility, the period the bank sets for credit decisions of this tier (illustrative) · personal data by purpose and retention rule · a corrected fact is a new, linked entry |
ids and figures invented; the control standard and the taxonomy are on the page before