Mortgage measures, exemptions and arrears define credit work at an Irish retail bank, and analysts need training to supervise agents inside them. The essentials: knowing each agent's depth, reading verdicts, checking every income and register figure at source, and owning credit decisions and exemptions. The Central Bank of Ireland, the EU AI Act and GDPR frame it.
What fills a credit analyst's week at an Irish retail bank?
Mortgages dominate: first-time buyers, movers, switchers and buy-to-let, many arriving through brokers. Analysts also assess personal loans, car finance and overdrafts. Each mortgage file is tested against the bank's policy and the Central Bank's mortgage measures, which limit lending relative to income and property value and allow banks a limited allowance of exceptions each year.
That allowance makes exemption decisions scarce and scrutinised. Analysts check the Central Credit Register, income and savings history, gifts from family, and the valuation. Separately, arrears teams work through a structured process for borrowers in difficulty. Every decision must stand up to internal audit and supervisory review.
Which tasks can agents prepare, and to what depth?
Each step gets its own depth, earned on the bank's own past mortgage files, measures tests included, and capped by the role's ceiling.
| Task | Depth | What the analyst checks |
|---|---|---|
| Pulling the Central Credit Register and bank history | 1: reads and lists | Completeness and currency |
| Income, savings and repayment capacity summary | 2: drafts with sources | Savings pattern and any gifts |
| Mortgage measures test | 2: drafts the ratios | Whether an exemption is needed |
| Broker and customer correspondence | 2: drafts from the decision | Accuracy and tone |
| Drawdown of funds | 4, held | Released by named people after approval |
An agent never allocates an exemption. It can show that a file would need one; the decision to spend part of a scarce allowance belongs to credit management.
What should analysts never delegate?
The full list is in what credit analysts should never let an agent do. For an Irish bank, four items stand out. The credit decision itself. Any exemption from the mortgage measures. Judgements about gifted deposits, where the source and conditions of the gift matter. And anything involving borrowers in arrears, where the process requires engagement, fairness and documented consideration of the borrower's circumstances.
These stay with people because they require judgement and because the bank must name who decided. That makes analysts the real control in an agent deployment, not a cost line waiting to be cut.
What do analysts need to learn?
The starting point is in what credit analysts should learn before working with agents. In practice, five skills:
- Reading verdicts. Allowed, held, refused or withheld, and which of five bounds decided: role scope, certificate, sources, the bank's limits or the platform guardrails.
- Checking provenance. The Central Credit Register and the bank's own ledger are strong sources; a gift letter is declared; an emailed payslip is external.
- Tracing a figure. Take the repayment capacity figure and follow it to its source lines.
- Banking corrections. When the agent mistreats a variable bonus, the fix goes into its sources; teaching credit analysts to bank corrections shows how.
- Knowing the lifecycle. An agent's certificate lapses after 90 days, and a run that clears no depth drops it to depth 1 the same day.
Which Irish and EU rules apply?
The Central Bank of Ireland supervises banks' conduct and prudential soundness, sets the mortgage measures, operates the Central Credit Register and expects fair treatment of borrowers, including in arrears. Significant banks are also supervised by ECB banking supervision, and the EBA's expectations on loan origination call for sound, documented creditworthiness assessment. DORA applies from 17 January 2025, covering ICT risk management and ICT third-party risk, which reaches the technology that prepares credit files.
The EU AI Act lists creditworthiness assessment of natural persons in Annex III as high-risk. Deployers must meet Article 26, including human oversight by competent people and keeping logs, and Article 14 sets out what that oversight must enable. Article 4 requires measures to ensure sufficient AI literacy. GDPR applies through the Data Protection Commission: Article 22 restricts solely automated decisions with significant effects, and Article 35 requires a data protection impact assessment where risk is high.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
The first 90 days
Phase one, weeks 1 to 4. Literacy for analysts, credit managers and arrears staff: depth, verdicts, provenance, the record and what Article 14 oversight means for their own work. Use anonymised Irish files, including a gifted deposit and a switcher.
Phase two, weeks 5 to 8. Analysts review agent-drafted affordability and measures tests on live files. Weekly calibration on a shared set, with disagreements written down. Credit managers check that no draft ever implied an exemption had been granted.
Phase three, weeks 9 to 12. Credit authority follows a current certificate. Rehearse a certificate lapse. Reconstruct three decisions from the record as a supervisor would. Pryme Intelligence Academy's Operator certificate, with its practicum of real review decisions, is one way to evidence competence. An AI agent training plan template for credit analysts records it per person, and the guide to AI agent skills by role shows how arrears and broker teams fit.
Questions people ask
Can an agent tell a broker the file needs an exemption?
It can draft that the file falls outside the measures. Whether an exemption is offered is a credit management decision, and the message should say so.
Does Article 22 apply if the analyst always reviews?
Not if the review is meaningful and the analyst can change the outcome. Record a reason for each decision to show it.
Do arrears teams need the same training as analysts?
They need the same literacy, plus case-specific skills on engaging borrowers in difficulty. Agents can draft arrears letters, but decisions on arrangements stay with trained staff.