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Covenant Desk

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Methods and sources

How Covenant Desk reads, checks and grades a credit file.

Each method below says what it does in an SME or property credit workflow, how it runs in your deployment, the safeguards around it, and the published research behind it.

Three rules

AI proposes. People confirm. Rules grade.

Every number in a Covenant Desk credit file traces to a source a person confirmed. The grade comes from rules your credit team can read, and the decision from a named credit officer with the authority to make it, with the AI preparing the file. These rules follow the expectations of explainability, human oversight and auditability in the HKMA's High-level Principles on Artificial Intelligence, Taiwan's FSC guidelines for AI in the financial industry and the MAS FEAT principles; meeting your own obligations under them remains your institution's assessment.

Each method carries one or more labels: In the platform Configured for your bank Available

01

Document reading with arithmetic checks

In the platformConfigured for your bank

What it does

Audited accounts, management accounts and bank statements are read into a standard spread. Each proposed figure carries the line it came from. The spread is then checked against its own accounting identities: where a stated subtotal or total disagrees with the sum of its parts, the check is shown before anyone relies on the figure. Bank inflows over twelve months are reconciled with declared revenue.

In your deployment

Text-based PDFs are read on the server. Scanned pages and phone photos are read by layout-aware OCR that handles English and Traditional Chinese on the same page, tested on your own document types during the implementation.

Safeguards

Extraction prepares the data and a person confirms every value, so every check runs on figures a named person has accepted.

Sources

  1. Huang, Lv, Cui, Lu and Wei. LayoutLMv3: Pre-training for Document AI with Unified Text and Image Masking. ACM Multimedia, 2022.
  2. PaddlePaddle team. PaddleOCR 3.0 Technical Report (PP-OCRv5, PP-StructureV3). 2025.
  3. Smock, Pesala and Abraham. PubTables-1M: Towards comprehensive table extraction from unstructured documents. CVPR, 2022.
02

Cash-flow evidence

In the platformAvailable

What it does

Monthly inflows, outflows and balances from the company's bank statements are analysed beside the financial statements, so the analyst sees whether the business the accounts describe is the business the bank account shows.

In your deployment

Account behaviour changes months before annual accounts are published. Transaction-level categorisation of mixed Chinese and English narratives, and monitoring of facility usage after drawdown, are part of the same analysis.

Safeguards

Categorisation accuracy is measured for each deployment before it is used in a grade, so every derived ratio rests on tested categories.

Sources

  1. Norden and Weber. Credit Line Usage, Checking Account Activity, and Default Risk of Bank Borrowers. Review of Financial Studies 23(10), 2010.
  2. Gambacorta, Huang, Qiu and Wang. How do machine learning and non-traditional data affect credit scoring? BIS Working Paper 834, 2019.
  3. FinRegLab. The Use of Cash-Flow Data in Underwriting Credit: Empirical Research Findings. 2019.
03

Scoring you can read

In the platformConfigured for your bank

What it does

The SME scorecard is a versioned set of explicit rules over ratios, cash flow, security and conduct, with reason codes. A missing input is shown as unassessed rather than filled with a guess, and a file that cannot be graded cannot be approved.

In your deployment

Your thresholds, weights and grade bands are loaded in your deployment. Calibration against your own loan history is part of the pilot, with any statistical challenger model constrained so each factor moves risk in the economically sensible direction and explained factor by factor.

Safeguards

Validation of any calibrated model belongs to your model-risk function, and we supply the evidence it needs.

Sources

  1. Rudin. Stop explaining black box machine learning models for high stakes decisions and use interpretable models instead. Nature Machine Intelligence, 2019.
  2. Lundberg and Lee. A Unified Approach to Interpreting Model Predictions. NeurIPS, 2017.
  3. Hong Kong Monetary Authority. High-level Principles on Artificial Intelligence. 1 November 2019.
04

Early warning

In the platformAvailable

What it does

Covenants are recorded on the facility and tested when a user runs them, with breaches and waivers logged against the case.

In your deployment

A discrete-time hazard model runs over account behaviour, ratio drift between periods and registry events, ranking performing loans by risk of deterioration so relationship managers review the few files that need it, each with its reasons.

Safeguards

An early-warning signal triages files for your credit officers; a grade or a limit changes only when a named person changes it.

Sources

  1. Shumway. Forecasting Bankruptcy More Accurately: A Simple Hazard Model. Journal of Business 74(1), 2001.
  2. Norden and Weber. Credit Line Usage, Checking Account Activity, and Default Risk of Bank Borrowers. Review of Financial Studies 23(10), 2010.
05

Guarantor and director networks

In the platformAvailable

What it does

Directors, shareholders and guarantors are linked to every case, and the company is re-screened at the final facility letter and at booking.

In your deployment

Across cases, the same person often guarantees several borrowers. A network view shows a shared guarantor or director under stress on every exposure it touches, with explicit contagion rules and graph models alongside.

Safeguards

Published graph models for guarantee networks were trained on mainland Chinese bank data, so explicit rules lead and the graph models are tested on your own book before use.

Sources

  1. Cheng, Tu, Ma, Niu and Zhang. Risk Assessment for Networked-guarantee Loans Using High-order Graph Attention Representation. IJCAI, 2019.
06

Language models as drafters, not scorers

In the platformConfigured for your bank

What it does

A language model proposes figures from a document and drafts text. Identifiers are masked before any call, the model prepares figures and text, rules grade the case, and a person confirms every figure before rules use it.

In your deployment

Your bank chooses the model: one it already approves, or one hosted in your region.

Safeguards

Benchmarks show language models answering questions about financial filings wrongly when left to generate numbers. Numbers in our documents come from the confirmed data, not from the model.

Sources

  1. Islam, Kannappan, Kiela, Qian, Scherrer and Vidgen. FinanceBench: A New Benchmark for Financial Question Answering. 2023.
  2. Hong Kong Monetary Authority. High-level Principles on Artificial Intelligence. 1 November 2019.
  3. Lee and Li. Taiwan FSC Guidelines for the Application of AI in the Financial Industry (June 2024).
07

Property collateral

In the platformAvailable

What it does

Valuations, haircuts, loan-to-value and guarantees are recorded on each case, with an expected-loss estimate and exposure across the borrower group.

In your deployment

The platform adds loan-to-value re-marking from published price indices and a flag where a surveyor's valuation departs from the market by more than a set margin.

Safeguards

An automated estimate is a check on a valuation, alongside the surveyor valuation your policy requires.

Sources

  1. Rating and Valuation Department, Hong Kong. Property market statistics and price indices.
  2. OCC, Federal Reserve, FDIC, NCUA, CFPB and FHFA. Quality Control Standards for Automated Valuation Models, final rule. Federal Register, 2024.
08

Tamper-evident record

In the platform

What it does

Every financial and credit action is written to an append-only log in which each entry carries a cryptographic hash of the one before it. A changed or deleted entry breaks the chain, and the break can be shown.

In your deployment

Every assessment, schedule and credit memo is stamped with the engine version that produced it, so a number can be traced to the code that computed it.

Safeguards

Hash-chaining shows that a record changed, and access control and retention follow your policy.

Sources

  1. Crosby and Wallach. Efficient Data Structures for Tamper-Evident Logging. USENIX Security Symposium, 2009.
  2. Laurie, Langley and Kasper. RFC 6962: Certificate Transparency. IETF, 2013.

For your model-risk and audit teams

What we hand over with every deployment.

Vendors do not get models approved; banks do. Our job is to give your validators the evidence they need.

  1. 01

    Calculation reference

    Every formula with its day count, rounding and treatment of missing inputs.

  2. 02

    Recomputation workbook

    The spread and ratios in Excel, so your analysts recompute any figure and get the same answer.

  3. 03

    Engine and policy versions

    The version that produced each assessment, schedule and memo.

  4. 04

    AI processing record

    Which model was called, when, for which document, with what masking.

  5. 05

    Known limitations

    A written list of what each method does not do, kept current.

  6. 06

    Control mapping

    Our controls mapped to the rules your supervisor applies, for your own assessment.

Data

Why connected data matters for SME credit.

In an HKMA study of about 80,000 Hong Kong SME loans from 2022 to 2025, banks that used the Commercial Data Interchange more actively charged on average 36 basis points less and asked for fewer collateral items. Connecting your deployment to the CDI, your credit bureau and your core banking system is part of the implementation.

  1. Hong Kong Monetary Authority. Research Memorandum 01/2026 on the Commercial Data Interchange and SME loan terms.
  2. Hong Kong Monetary Authority. About the Commercial Data Interchange.

Test the methods on one of your own files.

Bring an SME or property file and your credit policy to a two-hour working session with your credit and IT leads.

Book a working session