Origination teams gather KYC, income proofs, and collateral documents while risk waits on incomplete data. Scorecards age as borrower behaviour and macro conditions shift. Watchlist reviews are periodic rather than continuous. Collections learns about trouble after delinquency has already started.
Data is uneven across products — retail, SME, and merchant lending look different. Alternative signals exist but raise fairness and privacy questions. Analysts override scores without logging reasons, destroying the feedback loop. Model risk management asks for documentation the delivery team never built.
Losses and provisions hurt, but so does over-tightening that rejects good borrowers. Leadership wants AI credit scoring without noticing that application data quality, adverse action processes, and challenger models are immature.
Credit risk owns models and policy; origination owns file completeness; collections owns early warning actions; compliance owns fair lending and disclosure. Anti-patterns include auto-declining without human review paths, using opaque vendor scores with no local validation, and ignoring Bangladesh Bank or local regulatory expectations on model governance.
AI loan default prediction should improve ranking and early warning with explainable drivers, fit inside credit policy, and leave approve/decline/condition decisions with accountable officers — never silent autopilot lending.