Loan officers at Irish retail banks will spend less time assembling files and more time judging drafts once agents arrive. They need training in how agents decide, how to test affordability and mortgage measure checks, and how to record corrections. Exceptions to the mortgage measures, declines, arrears decisions and drawdown stay with them, as EU and Irish rules expect.
What do loan officers at Irish retail banks spend their time on?
Mortgages, mostly. Each application is tested against the Central Bank's mortgage measures, which limit lending relative to income and to property value, with a limited share of each bank's lending allowed above those limits. Deciding which applicants get one of those exceptions is a real judgement call, and officers make it within the bank's policy and allocation.
Income has become more varied. Many applicants work for multinational firms and are paid partly in shares or bonuses; others are contractors or self-employed. The officer must decide how much of that income is reliable for a loan that will run for decades.
Arrears is the other major task. Borrowers in difficulty must be dealt with through a structured process with set steps and fair treatment, and officers propose and agree arrangements within it.
Where do agents help, and how far can they go?
| Use | Depth | What the officer keeps |
|---|---|---|
| Build the income picture from payslips, share statements and bank accounts | 1 | Deciding which income is reliable |
| Check the application against the mortgage measures and the bank's credit policy | 1 | Any exception decision |
| Draft the credit memo and recommendation | 2 | Approve, amend or decline |
| Check the central credit register result against the applicant's declared debts | 1 | Judging discrepancies |
| Draft an arrangement proposal for a borrower in arrears | 2 | Agreeing it with the borrower |
| Release funds at drawdown | 4 | Always |
Salary credits on the bank's own accounts are sealed. A share plan statement from an employer is signed if it comes from the employer's plan administrator directly, and declared if the applicant uploads it. Officers should see which it is at a glance, because it changes how much weight the income carries.
What must stay with the officer?
Exception decisions under the mortgage measures, declines and the reasons given, arrears arrangements, and drawdown. Each of these affects a borrower significantly and must be attributable to a person who can explain it. The fuller list is in what loan officers should never let an AI agent do.
The exception allocation is the clearest example. An agent can rank applicants by any criteria it is given; deciding which of several borderline buyers gets one of the bank's limited exceptions involves fairness and judgement that a bank should want a person to own. That is the point of why loan officers are the real control in an AI agent deployment.
What should officers learn?
Officers need to understand how a governed agent decides: the agent's depth and the depth each action needs, the four verdicts (allowed, held, refused, withheld), the five bounds that make up the minimum chain and how provenance is stamped on every fact.
They need review technique, set out in how loan officers review an AI agent's decisions: check the income treatment, the measure calculations, the register result and the reasons before approving.
They need to correct well. An officer who rejects a memo and writes why helps the bank improve the agent's brief and sources; see teaching loan officers to bank corrections.
And they need to know how certification works. The agent is certified on the bank's own past applications. Its certificate lapses after 90 days, and a lapse or 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 Irish banks, sets the mortgage measures, runs the central credit register and sets consumer protection rules that govern how lenders treat borrowers, including in arrears. The ECB supervises the largest banks directly. The Data Protection Commission enforces GDPR in Ireland.
The EU AI Act (Regulation (EU) 2024/1689) lists creditworthiness assessment and credit scoring of natural persons as high-risk in Annex III. Deployers must assign human oversight to people with the necessary competence, training and authority (Article 26) and make that oversight effective (Article 14). Article 4 requires AI literacy among staff.
GDPR Article 22 restricts decisions based solely on automated processing with legal or similarly significant effects, which includes mortgage declines. Article 35 may require a data protection impact assessment. DORA applies to the bank's ICT risk management and third-party arrangements, including the agent platform.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
How should the first 90 days run?
Month one. Officers, team leads, arrears staff and the credit risk owner take Foundations (about 4 hours), and the bank records completion for its AI literacy evidence. The agent builds income pictures at depth 1.
Month two. Officers take the Operator modules on how a governed agent decides, human review, teaching the agent and when something goes wrong. Credit memos and arrears proposals move to depth 2. A lead reviews every exception request the agent flagged.
Month three. Officers sit the Operator exam (40 questions in 60 minutes; 32 correct needed) and complete a two-week practicum on live applications. The bank limits approval of held decisions and drawdowns to certified officers and records this for its supervisor.
Copy the structure from the training plan template for loan officers. For other roles, see AI agent skills by role.
Questions people ask
Can an agent allocate mortgage measure exceptions?
It can identify applicants who would need one and draft the case. The allocation itself should be a person's decision under the bank's policy, because it involves fairness between applicants.
How should share-based income be treated?
That is a matter of bank policy. The agent can apply the policy and show its working; the officer decides on borderline cases and on whether the source is signed or only declared.
Are arrears staff part of this training?
Yes. They approve arrangements that the agent drafts, so they need the Operator track as much as the officers who approve new lending.