How to set an approver rule for the credit team

Start from credit mandates, then layer the agent on top. The agent prepares the file and the recommendation; an analyst with mandate for that amount and product approves. Declines are always decided by a person, with the reasons the customer will receive. Limits above mandate go to a senior or committee. Mandate holds only while the approver's certificate is current.

What does the credit team's approver rule decide, and who owns it?

Credit teams already work to mandates: each analyst may approve up to a set exposure for set products. When an agent joins, it gathers the data, runs the policy checks, drafts the credit memo and proposes a decision. The approver rule decides which analyst may release that proposal, and what happens when the proposal is a decline. Our explainer on what an agent approver is covers the general role.

The head of credit owns the rule. Credit risk in the second line signs it off. The agent owner configures it. Our guide to AI agent skills by role sets out what a credit analyst should understand about agents before approving their work.

What are the steps?

1. Head of credit: lists the agent's actions by depth. Depth 1: reads applications, bureau data, bank statements and account history. Depth 2: drafts the credit memo, the decision rationale and the reasons letter. Depth 3: requests missing documents and updates the application. Depth 4: approves credit, sets or raises a limit.
2. Head of credit: maps depth 4 to existing mandates. The agent holds each approval for an analyst whose mandate covers the product and exposure.
3. Head of credit: holds every decline at depth 2. The analyst decides and approves the reasons the applicant will receive.
4. Head of credit: sends exposures above mandate to a senior analyst or credit committee, with the agent's memo as the paper.
5. Head of credit: ties each mandate to a current certificate. A lapsed certificate suspends the mandate for agent-prepared decisions.
6. Credit risk: signs off. Agent owner: configures and files.

Why do declines stay with an analyst?

A decline has a significant effect on the applicant, and in many markets the reasons must be specific and accurate. In the US, ECOA and Regulation B require specific reasons when credit is denied, including when a model is used. In the EU, creditworthiness assessment and credit scoring of natural persons is listed as high-risk under the AI Act. Data protection law in the EU and UK limits decisions based solely on automated processing with legal or similarly significant effects.

Whatever the market, a decline is the decision an applicant is most likely to challenge. The analyst who approves it should be able to explain it, which means reading the memo, checking the sources and owning the reasons. The agent's draft saves time; it does not carry responsibility.

Approvals are different but not lighter. An approval within mandate is held because it moves money, not because it is hard to judge. The analyst checks that the sources are sealed or signed, that income evidence is not just declared, and that the policy checks ran.

Which controls make the rule work, and what evidence do they leave?

Mandate matched to holds. Evidence: the approver authority matrix for the credit team, reconciled to the mandate register.

Every decline approved by a person. Evidence: a named analyst on every decline in the verdict record.

Reasons match the memo. Evidence: sampled declines where the reasons letter is compared with the memo.

Mandates lapse with certificates. Evidence: certificate status on each approval date.

Income evidence provenance. A payslip uploaded by the applicant is declared; data from an open banking feed may be signed. Evidence: provenance stamps on the memo.

What should you measure?

• Agent proposals overturned by analysts, by direction: approvals turned to declines and the reverse.
• Decline reasons challenged, and whether the challenge was upheld.
• Approvals above mandate. The target is none.
• Time from complete application to decision, by product.

Where does it usually go wrong?

Analysts approve the memo, not the decision. A well-written memo creates confidence. Sample approvals and ask analysts to explain one decision in their own words.

Mandates are borrowed across products. An analyst with a mandate for unsecured loans approves an agent-prepared overdraft limit. Map mandate to product, not just to amount.

The credit control rule is reused. Chasing business debt is not lending to people. Compare the approver rule for the credit control team and the credit control authority matrix.

IT changes to the scoring inputs are not routed to credit. A change to a data feed changes what the agent sees. See the approver rule for the IT team for how system changes should be approved.

Where the Academy fits

Pryme Intelligence Academy's Operator track trains analysts who review held decisions every day, with module tests set in lending. The Architect track is for the people who lead regulated, multi-agent deployments. A lender can make each analyst's mandate for agent-prepared decisions depend on a current Certified Pryme Operator certificate.