Test arrears aging, restructures, write-offs, collateral evidence, and board credit pack consistency.

• Reconcile loan book to GL totals
• Sample 75 facilities across stage, product, and county
• Trace arrears cures and roll-forward movements

Assess stage transfer criteria, SICR triggers, PD/LGD/EAD lineage, overlays, and ECL adequacy.

• Compare staging to days-past-due and hardship flags
• Review macro overlay approval trail
• Back-test PD bands and cure rates

Review suspicious transaction typologies for M-Pesa tills, group accounts, mule indicators, and sanctions screening.

• Inspect high-velocity wallet clusters
• Sample CDD/EDD refreshes
• Review STR decision logs

Assess complaint intake, root-cause coding, SLA aging, redress approvals, and board reporting.

• Sample complaints over 30 days old
• Tie refunds to event log
• Review branch and digital escalation channels