oversight

Washington Mutual Bank, Seattle, WA, Washington Mutual Bank Submitted 609 Late Endorsement Loans with Unacceptable Payment Histories

Published by the Department of Housing and Urban Development, Office of Inspector General on 2005-07-05.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                               Issue Date
                                                                    July 5, 2005
                                                               Audit Report Number
                                                                    2005-SE-1006




TO:        Brian D. Montgomery, Assistant Secretary for Housing - Federal Housing
              Commissioner, H




FROM:      Joan S. Hobbs, Regional Inspector General for Audit, Region X, 0AGA

SUBJECT: Washington Mutual Bank, Seattle, WA, Washington Mutual Bank Submitted
         609 Late Endorsement Loans with Unacceptable Payment Histories



                                  HIGHLIGHTS

 What We Audited and Why

            We audited late endorsement payment histories at Washington Mutual Bank
            (Washington Mutual), Seattle, Washington. We selected Washington Mutual
            because of its high number of late single-family loan submissions for Federal
            Housing Administration insurance during calendar years 2002 and 2003. Our
            objective was to determine whether Washington Mutual’s late requests for
            endorsement complied with the U.S. Department of Housing and Urban
            Development’s (HUD) payment history requirements.


 What We Found


             From March 2002 to October 2004, Washington Mutual improperly submitted
             609 loans to HUD, totaling more than $69 million, for insurance endorsement
             when the borrowers had delinquent payments within six months before the
            submission date. This occurred because Washington Mutual did not have
            adequate controls to ensure that its employees followed HUD’s requirements
            regarding late requests for insurance endorsement. However, in response to
            Federal Housing Administration Quality Assurance Division findings,
            Washington Mutual began planning and implementing improvements to its
            organization, procedures, and controls in July 2003 and achieved a reduction in
            late endorsement submissions during 2004.

What We Recommend


           We recommend that HUD take appropriate administrative action up to and
           including recovery of losses on $1,091,214 in paid claims and indemnification of
           loans with a total mortgage value of $18,695,819. These loans were not current
           when submitted for endorsement (see appendix A). We also recommend that
           HUD take appropriate administrative action against Washington Mutual for
           violating the requirements in effect at the time when it submitted loans without
           proper six-month payment histories.

Auditee’s Response


           We provided Washington Mutual a draft report on May 12, 2005, and held an exit
           conference with Washington Mutual officials on May 26, 2005. Washington
           Mutual provided written comments on June 10, 2005. The written comments
           generally agreed with our report findings, but disagreed as to their significance.
           Washington Mutual disagreed with the extent of recommended indemnifications
           citing recent changes in HUD’s late submission requirements and the materiality
           of the internal control weakness for late endorsements. Upon evaluating the
           written comments, we adjusted our recommendations to reflect HUD’s recent
           change in the late submission requirements. The complete text of the auditee’s
           response, along with our evaluation of that response, can be found in appendix B
           of this report.




                                            2
                            TABLE OF CONTENTS

Background and Objectives                                                      4

Results of Audit
      Finding 1: Washington Mutual Submitted 609 Late Endorsement Loans with   5
      Unacceptable Payment Histories

Scope and Methodology                                                          9

Internal Controls                                                              11

Appendixes
   A. Schedule of Questioned Costs and Funds to Be Put to Better Use           12
   B. Auditee Comments and OIG’s Evaluation                                    14




                                            3
                    BACKGROUND AND OBJECTIVES

The National Housing Act, as amended, established the Federal Housing Administration, an
organizational unit within the U.S. Department of Housing and Urban Development (HUD).
The Federal Housing Administration provides insurance to private lenders against loss on
mortgages financing homes. The basic home mortgage insurance program is authorized under
title II, section 203(b), of the National Housing Act and governed by regulations in 24 Code of
Federal Regulations 203.

Through the direct endorsement process, the lender underwrites and closes the mortgage loan
without prior HUD review or approval. The purpose of late request for endorsement procedures
is to ensure that the degree of risk to HUD is no greater than existed at the time of closing,
before the mortgage may be endorsed. A request for insurance endorsement is considered late
and triggers additional documentation whenever the binder is received by the appropriate HUD
home ownership center more than 60 days after mortgage loan settlement or funds
disbursement, whichever is later. The Federal Housing Administration believes that this is
sufficient time for the mortgage lender to assemble the binder, obtain any final documents or
signatures, and ship the binder to the appropriate center for endorsement.

Washington Mutual Bank (Washington Mutual) has an administrative office in Seattle,
Washington and is a supervised direct endorsement lender approved to originate Federal
Housing Administration-insured single-family loans. In a series of acquisitions beginning in
2001, Washington Mutual acquired two federal savings banks that had mortgage lending
operations: Bank United and The Dime Savings Bank of New York, FSB, which owned North
American Mortgage Company. Washington Mutual also acquired three other mortgage
companies: PNC Mortgage Corporation of America, Fleet Mortgage Corporation, and
HomeSide Lending, Incorporated. From 2000 to 2003, Washington Mutual’s total home
lending and refinancing for conventional and insured mortgages increased from $51.5 billion to
$384.2 billion; it decreased to $212.4 billion in 2004.

During the period from March 2002 to October 2004, Washington Mutual submitted 64,905
Federal Housing Administration loans worth $7.4 billion with closing dates from January 2002
through June 2004 to HUD for insurance.

Our objective was to determine whether Washington Mutual’s late requests for endorsement
complied with HUD’s payment history requirements. The audit steps were designed to detect
endorsed loans for which the borrowers made late payments before the lender submitted the
loan to HUD for insurance endorsement. Washington Mutual provided significant resources
and valuable assistance in support of this audit.




                                               4
                              RESULTS OF AUDIT

Finding 1: Washington Mutual Submitted 609 Late Endorsement Loans
with Unacceptable Payment Histories
From March 2002 to October 2004, Washington Mutual improperly submitted 609 loans,
totaling more than $69 million, as late requests for insurance endorsement to HUD when the
borrowers had mortgage payment delinquencies within six months before the submission date.
This occurred because Washington Mutual did not have adequate controls to ensure its
employees followed HUD’s requirements regarding late requests for insurance endorsement.
Consequently, the inappropriately submitted loans increased the risk to the Federal Housing
Administration insurance fund.



 HUD Requirements



             For our audit period, HUD Handbook 4165.1, REV 1, required that loans submitted
             for insurance endorsement more than 60 days after closing meet certain late request
             standards. The standards included ensuring that the borrower has made, within the
             calendar month due, all loan payments up to the time of submission or at a
             minimum, made six consecutive monthly payments within the calendar month due.
             They also required that the current month’s payment be received when submitting
             loans after the 15th of the month. These rules were further clarified by HUD
             Mortgagee Letter 2004-14.

 Improperly Submitted Loans


             After obtaining and reconciling the electronic records from HUD and Washington
             Mutual, we tested for the presence of unacceptable payment histories on loans
             submitted as late requests for insurance endorsement. Our automated analysis of
             the payment histories provided by Washington Mutual and endorsement data from
             HUD’s systems showed that for the 37,648 loans with late endorsement requests
             tested, Washington Mutual submitted 1,011 loans with questionable payment
             histories.

             Washington Mutual reviewed the 1,011 payment histories and provided
             reasonable explanations for 402 transactions. Washington Mutual agreed that the
             remaining 609 loans were submitted as late endorsement requests even though the
             borrowers had unacceptable payment histories before submission.



                                              5
           Late endorsement loans with unacceptable payment histories present a higher risk
           to the Federal Housing Administration insurance fund in comparison to other
           loans. Of the 609 loans submitted with unacceptable payment histories, 126
           (20.69 percent) have defaulted since insurance endorsement, compared to
           approximately 4 percent for all Washington Mutual loans.

                                                 Number               Number
                                                 of                   of
                                                 defaults             claims
                                                 as of                as of
                                     Number      March    Default     March      Claims
                                     of loans    2005     rate        2005       rate
          All loans during audit
          period                     2,825,498 201,473     7.13%      29,056     1.03%
          Originated or sponsored
          by Washington Mutual
          from Jan. 1, 2002,
          through June 30, 2004      64,905      2770      4.27%      373        0.57%
          Late endorsement loans
          tested                     37,648      1494      3.97%      205        0.54%
          Late endorsement loans
          with unacceptable
          payment histories          609         126       20.69%     17         2.79%

           As of May 2005, 50 of the 609 loans have been paid in full and no longer
           represent a risk to the Federal Housing Administration insurance fund. Of the
           remaining 559 loans, 18 have proceeded to claims, and 541 are still insured and
           pose a risk to the Federal Housing Administration insurance fund.


HUD Changed its Late Loan
Submission Requirements

           On May 17, 2005, after the completion of our audit, HUD issued Mortgagee
           Letter 2005-23. This Mortgagee Letter changed HUD’s requirements for loans
           submitted late for endorsement and only requires lenders to certify that the most
           recent payment that came due was made within the month that the loan was
           submitted. The Mortgagee Letter eliminates the requirement that loans submitted
           late are not eligible for endorsement until six consecutive payments have been
           made prior to and/or within the calendar month due. According to the Mortgagee
           Letter, “FHA believes its risk at insurance endorsement is based by the status of
           the mortgage at the time of endorsement and is, therefore, eliminating this
           requirement in the late endorsement request.”




                                           6
           Of the 559 loans reported above, 179 were not current at the time they were
           submitted to HUD for insurance endorsement and would not have met the new
           requirements.

           We provided HUD officials and Washington Mutual with spreadsheets
           identifying the loans improperly submitted to HUD as late requests for
           endorsement. We have not included the detailed spreadsheets in this report but
           can provide them upon request.


Controls Needed Improvement


           Washington Mutual submitted loans with unacceptable payment histories because
           it did not have a control environment sufficient to ensure that its employees
           followed HUD’s submission requirements for late endorsements and was not
           adequately prepared to handle a rapid increase in its single-family lending
           business.

           A July 2003 Washington Mutual internal audit report acknowledged weaknesses
           and recommended improvements to controls over government lending and
           insurance. As a result, Washington Mutual began reorganizing and developing
           new controls over its mortgage lending activities. Washington Mutual currently
           operates two national post closing operations centers in Florence, South Carolina,
           and Jacksonville, Florida. Since the reorganizations, these centers perform
           servicing functions as well as certain post closing activities more commonly
           associated with originating, including obtaining Federal Housing Administration
           insurance endorsements.

           Current controls contain new processes to track the status of loans from closing to
           insurance endorsement. Washington Mutual added to its operating instructions
           quality control steps that test Federal Housing Administration requirements within
           the process centers and also centrally by its servicing risk oversight organization.
           These steps include specific attention to the payment history issue; however, they
           do not address the requirement that the current month’s payment be received
           when submitting after the 15th of the month. Washington Mutual agreed to
           incorporate this additional requirement into its operating instructions and quality
           control checklists used to check for six months of acceptable payment history.

           Washington Mutual also acknowledged that it was not prepared to handle the
           sudden increase in mortgage volume that occurred in 2002. The increase in
           mortgage volume was due to decreasing interest rates, resulting in an increase in
           refinance activity. The problem was intensified by the growth of Washington
           Mutual’s mortgage business from numerous acquisitions of other mortgage
           lenders.




                                            7
          During our audit timeframe of January 2002 to June 2004, Washington Mutual
          submitted late requests for endorsement for 71 percent of its Federal Housing
          Administration-insured loans. By the end of 2004, Washington Mutual had
          reduced the percentage of late requests to fewer than 10 percent for new Federal
          Housing Administration-insured loans.

Recommendations


          We recommend that the Assistant Secretary for Housing - Federal Housing
          Commissioner

          1A. Take appropriate administrative action against Washington Mutual up to and
          including recovery of losses on $1,091,214 in paid claims and indemnification of
          179 loans, totaling $ 18,695,819, that were not current when submitted for
          endorsement (see appendix A).

          1B. Take appropriate administrative action against Washington Mutual for
          violating the requirements in effect at the time when it submitted 380 loans
          without proper six month payment histories.




                                           8
                        SCOPE AND METHODOLOGY

 Our review covered the period from January 1, 2002, through June 30, 2004, and was modified
 as needed to achieve our objectives.

 To accomplish our objectives, we reviewed (1) relevant statutory, regulatory, and HUD
 handbook requirements; (2) lender and HUD electronic loan records for 64,905 Federal
 Housing Administration loans, including 93 Federal Housing Administration loan files; and (3)
 the lender’s internal controls relating to loan origination. In addition, we interviewed the
 lender’s post closing operations and corporate staff as well as HUD personnel.

 We relied on computer-processed data provided by Washington Mutual and data contained in
 HUD’s Single Family Data Warehouse. We conducted tests to ensure that the data were
 sufficiently reliable to be used in meeting our objectives.

 To determine our sample of loans for electronic review, we selected all loans submitted by
 Washington Mutual for Federal Housing Administration insurance that were submitted 66 or
 more days after closing. By means of HUD’s Single Family Data Warehouse system, we
 identified 64,905 loans submitted by Washington Mutual having a closing date from January
 2002 through June 2004. The following table shows the adjustments made to the initial 64,905
 loans:

                                                                Original
                                                   Number       mortgage
                                                   of loans     amounts
                   Originated or sponsored by
                   Washington Mutual from Jan.
                   2002 through June 2004           64,905 $7,416,603,694
                   Submitted less than 66 days
                   after closing                    18,709    2,115,694,881

                   Paid in full                      7,866    1,016,975,776
                   New construction loans, late
                   endorsement requirements
                   not applicable                      652       85,769,909
                   Loans with no electronic
                   payment histories available          30        2,815,501
                   Late endorsement loans
                   tested                           37,648 $4,195,347,627
                   Late endorsement loans with
                   unacceptable payment
                   histories                           609       69,270,511

To test the remaining 37,648 loans for proper submission, we derived a submission date from the
dates in HUD’s systems. We considered the submission date to be the date HUD received the


                                               9
loan for insurance endorsement. However, if HUD rejected the loan and returned it to
Washington Mutual for correction of deficiencies, we used the date Washington Mutual
resubmitted the loan to HUD for review. If HUD’s data did not contain the date Washington
Mutual resubmitted the loan for endorsement, we used the endorsement date as the submission
date.

Our tests also required the use of the loan closing dates to identify those loans submitted to HUD
66 days or more after the loan closed. We compared the closing dates provided by Washington
Mutual to those in HUD’s Single Family Data Warehouse and found that some loans had a
variance of a few days. We selected 30 files with a variance and determined that while the
Single Family Data Warehouse uses the settlement date, Washington Mutual used the later of
settlement or funding date, which complies with the latest HUD guidance defined in HUD
Handbook 4000.2, REV 3, section 5-1, and clarified in Mortgagee Letter 2004-14. We reviewed
the Federal Housing Administration loan files for those loans close to the 66-day cutoff to ensure
the variance did not impact our report.

We performed our audit work from November 8, 2004, through April 5, 2005. We conducted
fieldwork at Washington Mutual’s corporate offices in Seattle, Washington.

We performed our review in accordance with generally accepted government auditing standards.




                                               10
                             INTERNAL CONTROLS

Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:

   •   Effectiveness and efficiency of operations,
   •   Reliability of financial reporting, and
   •   Compliance with applicable laws and regulations.

Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.



 Relevant Internal Controls
              We determined the following internal controls were relevant to our audit objectives:

              •       Loan origination process – Policies and procedures that management has in
                      place to reasonably ensure that the loan origination process complies with
                      HUD program requirements.

              •       Quality control plan – Policies and procedures that management has in place
                      to reasonably ensure implementation of HUD quality control requirements
                      pertaining to loan origination.

              We assessed the relevant controls identified above.

              A significant weakness exists if management controls do not provide reasonable
              assurance that the process for planning, organizing, directing, and controlling
              program operations will meet the organization’s objectives.


 Significant Weaknesses


              Based on our review, we believe the following item is a significant weakness:

              •       Washington Mutual did not have adequate controls to prevent or detect
                      payment history inadequacies in its Federal Housing Administration
                      insurance applications. During our audit, we observed corrective actions
                      that greatly reduced the number of late endorsement requests during 2004
                      (finding 1).


                                               11
                                     APPENDIXES

Appendix A

               SCHEDULE OF QUESTIONED COSTS
              AND FUNDS TO BE PUT TO BETTER USE

 Recommendation           Ineligible 1/    Unsupported      Unreasonable or      Funds to be put
        number                                      2/       unnecessary 3/       to better use 4/
      1A                $183,602            $907,612                              $18,695,819


1/   Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
     that the auditor believes are not allowable by law; contract; or federal, state, or local
     polices or regulations. The amount shown includes loss mitigation incentive payments
     and net claims. A net claim is the total claim paid by HUD including loss mitigation
     incentives, less any proceeds from HUD’s sale of the insured property.

2/   Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
     or activity when we cannot determine eligibility at the time of audit. Unsupported costs
     require a decision by HUD program officials. This decision, in addition to obtaining
     supporting documentation, might involve a legal interpretation or clarification of
     departmental policies and procedures. The amount shown is for gross claims. A gross
     claim is the amount of the claim paid by HUD before any recovery from the sale of the
     property by HUD. At the time of the audit, HUD had not yet sold the properties.

3/   Unreasonable/unnecessary costs are those costs not generally recognized as ordinary,
     prudent, relevant, and/or necessary within established practices. Unreasonable costs
     exceed the costs that would be incurred by a prudent person in conducting a competitive
     business.

4/   “Funds to be put to better use” are quantifiable savings that are anticipated to occur if an
     Office of Inspector General (OIG) recommendation is implemented, resulting in reduced
     expenditures at a later time for the activities in question. This includes costs not incurred,
     deobligation of funds, withdrawal of interest, reductions in outlays, avoidance of
     unnecessary expenditures, loans and guarantees not made, and other savings. For this
     review, these funds consist of loans and guarantees not made because of indemnification.




                                              12
Breakdown of the Questioned Costs for 179 Loans (Recommendation 1A)

13 loans with claims that were not current when endorsed

                               Ineligible
                                                                      Funds to be put to
                                         Loss                             better use
                                      mitigation      Unsupported (loan amount on currently
Case number             Net claims    incentives      (gross claim)     insured loans)
       052-2472537                                       $179,279
       052-2850637                                         16,497
       091-3840740                                        128,319
       093-5703781                                        107,536
       105-1292493                                         95,298
       161-1980143                                        122,719
       221-3501664                                        144,041
       321-2189164        $71,593
       352-4572657              0
       381-6405040         33,056
       422-2514641         67,544
       492-6221004                                          27,919
       581-2395831                                          86,004
Total claims             $172,193                         $907,612



166 active loans including loans with loss mitigation payments that were not current when
submitted

                               Ineligible
                                                                       Funds to be put to
                                        Loss                                better use
                                     mitigation       Unsupported       (loan amount on
      Case number       Net claims   incentives       (gross claim) currently insured loans)
       011-4894943                        $750                                      $80,900
       092-9214003                          750                                      70,443
       137-1575710                          625                                      76,835
       137-2068450                          625                                     132,915
       161-1959939                          625                                      67,446
       352-4630533                          750                                     163,706
       422-2596045                          750                                      52,577
       491-8263572                        5,159                                     107,778
       581-2396531                          625                                      94,141
       581-2492156                          750                                      93,354
156 others - active *                                                           17,755,724
Total 166 active                            11,409                              18,695,819

* No claims or loss mitigation paid on these loans




                                                     13
Appendix B

        AUDITEE COMMENTS AND OIG’S EVALUATION


Ref to OIG Evaluation   Auditee Comments




                         14
Ref to OIG Evaluation   Auditee Comments




Comment 1




Comment 2




Comment 3




                         15
Ref to OIG Evaluation   Auditee Comments




                         16
Ref to OIG Evaluation   Auditee Comments




Comment 3




                         17
Ref to OIG Evaluation   Auditee Comments




Comment 2




                         18
Ref to OIG Evaluation   Auditee Comments




Comment 4




Comment 5




Comment 6




                         19
Ref to OIG Evaluation   Auditee Comments




Comment 6




Comment 4




                         20
Ref to OIG Evaluation   Auditee Comments




Comment 3




                         21
Ref to OIG Evaluation   Auditee Comments




                         22
Ref to OIG Evaluation   Auditee Comments




                         23
                         OIG Evaluation of Auditee Comments

Comment 1   HUD’s change in policy is not retroactive and was subsequent to when the 609
            loans were improperly submitted for insurance endorsement. As discussed in
            Finding 1, we removed loans that were current at the time of submission from our
            questioned costs. We maintain that these loans present a higher risk to the
            Federal Housing Administration insurance fund, as demonstrated in Comment 5
            below, and request appropriate administrative sanctions in Recommendation 1B.

Comment 2   The table in Finding 1 shows that, for our audit period, all of the Washington
            Mutual late endorsement loans defaulted at approximately the same rate as all of
            its Federal Housing Administration-insured loans. However, Washington
            Mutual’s late endorsement loans with unacceptable payment histories in the prior
            six months defaulted and proceeded into claims at a rate five times higher.

Comment 3   Our evaluation of internal controls is limited to late endorsement payment
            histories and cannot be extrapolated to other HUD requirements or the system of
            internal controls, taken as a whole. Our report discloses internal control
            weaknesses during our audit period that could be routinely detected through
            automated procedures.

            Using computer-based analytical tools, we were able to identify all loans
            submitted late with improper payment histories. Similarly, Washington Mutual
            could have incorporated computer algorithms into its loan payment history
            systems that would detect all loans without adequate payment histories.

            We acknowledge that Washington Mutual has taken the necessary steps to
            strengthen its controls over the late submission of loans for insurance and state so
            in both Finding 1 and in the Internal Controls section of this report.

Comment 4   We identified 50 loans that were paid in full and excluded from questioned costs
            in Appendix A. After reviewing Washington Mutual’s support, we determined
            that their list of 124 paid in full loans includes refinanced loans that still have
            active insurance.

            We provided Washington Mutual the opportunity to correct the figures in their
            response, but they declined. Washington Mutual replied that they believe the
            status of the original loan does not carry forward when it is refinanced since the
            original loan is legally extinguished. Because Washington Mutual declined to
            include refinanced loans, the remaining figures in their response are understated.

            HUD Handbook 4000.4 REV-1, CHG-2 Section 5-8 discusses indemnification
            agreements. It states in part, “These agreements essentially guarantee that the
            Department will not suffer a loss on the loans. The mortgagee agrees to abstain
            from filing a claim or to reimburse the Department if a subsequent holder files a



                                             24
            claim. The term of the agreement varies with the severity of the violation,
            typically they are effective for five years from the date of endorsement.”

            Examples of standard indemnification agreements include a paragraph explaining
            that the indemnification extends to streamline refinanced loans even if refinanced
            by another lender. A streamline refinance relies on the original loan’s
            underwriting and insurance. Therefore, Washington Mutual is still responsible for
            the original underwriting and insurance endorsement submission of these active,
            refinanced loans.

Comment 5   We identified 559 loans that are active according to HUD systems. Of these
            loans, 380 were current at the time of endorsement submission and would comply
            with the new HUD endorsement rules. However, these loans recorded
            significantly higher rates of default and claims than other loans, producing 50
            defaults and 4 claims, or 13.16 percent and 1.05 percent respectively.


                                                    Number              Number
                                                    of                  of
                                                    defaults            claims
                                                    as of               as of
                                         Number     March    Default    March       Claims
                                         of loans   2005     rate       2005        rate
            Late endorsement loans
            tested                       37,648     1494     3.97%      205         0.54%
            Loans that were current
            when submitted to HUD        380        50       13.16%     4           1.05%
            Current loans that later
            established 6 months of
            payment history              288        17       5.90%      1           0.35%
            Current loans that did not
            establish 6 months of
            payment history              92         33       35.87%     3           3.26%



Comment 6   We identified 179 loans that were not current at the time of endorsement
            submission and would not comply with current endorsement rules. These loans
            recorded 9 times as many defaults and 13 times as many claims compared to other
            loans tested. As shown below, even the loans that established a 6 month payment
            history defaulted 6 times more often and had 12 times the claim rate than the
            other loans tested. Therefore, we do not agree that these loans should not be
            indemnified because there is no basis to assume there is less risk for these loans.




                                               25
                                     Number             Number
                                     of                 of
                                     defaults           claims
                                     as of              as of
                          Number     March    Default   March    Claims
                          of loans   2005     rate      2005     rate
Late endorsement loans
tested                     37,648    1494     3.97%     205      0.54%
Non-current loans that
later established 6 months
of payment history         92        21       22.83%    6        6.52%
Non-current loans that
did not establish 6
months of payment
history                    87        43       49.43%    7        8.05%

Total non-current loans   179        64       35.75%    13       7.26%




                                26