The State is an accomplice in the draining of capital. Half of all loans granted by First Investment Bank (FIB) are non-performing or total loss.

“There is no bank in Bulgaria with capital shortage. State funds will not be used to increase capital buffers of any bank. The banking system is stable. “

These generally summarize the main “talking points” in the official statement of Dimitar Radev, Governor of the central bank – Bulgarian National Bank (BNB) – made on the occasion of the completed stress tests of local banks.

All media echoed Radev’s statement in an attempt to comfort and cradle the public interest in one of the thorniest topics in the discussion about the state of some domestic banks.

Nevertheless, Bivol is presenting to the public other findings, hidden and kept strictly secret until now

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Internal report of BNB on FIB

First Investment Bank (FIBANK) does not have enough capital, but has massive bad loans; it is misleading BNB about them and is trying to cover them up with various accounting tricks of the trade. There is a concentration of loans to connected parties and individuals gravitating around the owners (majority shareholders) of the Bank. A “bank in the bank” is established in Cyprus, which is not monitored by risk management. There are huge exposures to offshore companies with untraceable property. These facts have been repeatedly identified by BNB, but have not been disclosed either in Bulgaria or to the European Central Bank.

The shocking findings are presented in the Report of the Supervision Inspection at the BNB Banking Supervision Department from 2012 under order №РД 22-0301/February 16, 2012. After the establishment of the scandalous facts, the report has been concealed and similar inspections have not been conducted afterwards until the liquidity crisis and the granting of State aid to the bank in 2014. The fact that stricter supervisory measures against the Bank have not been undertaken is another problem.

When is BNB telling the truth and when is it lying?


Moreover, it seems that in June 2014 the Bulgarian government deliberately lied to the European Commission that FIB is a viable bank in order to obtain permission to provide State aid in the amount of 1.2 billion levs. Bivol has already sent the full report to Directorate-General (DG) for Competition of the European Commission and has asked questions whether this report has been submitted before or after the granting of State aid and whether it has been taken into account. We did not receive a reply by the time of the publication of this article, but delays in the otherwise “quick” replies of European officials could be attributed to the summer vacation period.

The existence of this report is in full contradiction with the current enthusiastic statements of Dimitar Radev as it remains unclear when and how the huge problems identified in FIB were overcome and whether they have not worsened over the years. In a series of investigations in recent years, Bivol proved independently some of the violations established by BNB inspectors.

About two years ago, we even asked the central bank to check our revelations without actually even suspecting that the leadership of the regulator was well aware of the tragic situation. BNB took a solid defensive stance in favor of FIB, which makes the State institution an accomplice in disguising the blatant processes of capital draining. BNB’s hypocritical behavior and the failure of the regulator to fulfill its statutory responsibilities and to respond adequately to Bivol’s tipoffs can be found here, here, here and here.

The secret report of “Banking Supervision”, obtained by Bivol, is an objective analytical document with sufficient scope and it is another proof that the problems with Bulgarian banking supervision are political, and not of technical or regulatory nature.

It must be further noted that despite the dramatic situation there is no clear set of recommendations and mandatory measures to heal the Bank. Hence, it can be concluded that BNB has the capacity to solve problems, but did not want to undertake serious measures to remove them. On the contrary – it concealed quite deliberately the horrific facts.

The report repeatedly mentions that FIB has not implemented recommendations from previous inspections. However, no escalation of supervisory measures has followed. No doubt has been cast on the vicious practice of conditional loans, but only on the fact that they were not entered as off-balance sheet obligations. It has been clear that the Bank planned an expansion of assets and despite the presence of these problems, the expansion has still been allowed. In fact, its appropriateness has not even been questioned.

The parallel with the collapsed Corporate Commercial Bank (CCB) is inevitable. The only difference is that with the help of a benevolent “Banking Supervision” and with obvious political intervention, CCB exploded in the summer of 2014, while FIB was credited with funds from the State budget and companies connected to controversial media mogul and lawmaker Delyan Peevski transferred their loans precisely there.

BNB’s report confirms Bivol’s investigations

In late 2014 and early 2015, Bivol conducted a series of own investigations into FIB’s loans, which led to conclusions similar to those in the report. We had no access to credit files, however, based on public information about the conditional loans and our experience in journalistic investigations, we reached the conclusion that the Bank is being drained by its owners. The crime is committed through dummies in Cyprus and other offshore destinations, while loans to oligarchs, close to people in power, are non-performing.

Unlike banking supervisors, we were able to identify the individuals behind offshore companies who received loans in the amount of over 1.2 billion levs. Therefore, the biggest investor in the Bulgarian economy proved to be a destitute and unemployed Cypriot, named Georgios Georgiou, who is closely related to FIB’s majority shareholders, Tseko Minev and Ivaylo Mutafchiev. This evidence was described in a signal to prosecutors and so far there is no denouement. The most recent information is that the signal is being checked by the National Security Agency (DANS).

The full “cover up” for FIB and the refusal of all institutions to work on the irrefutable evidence we presented, is probably due to the fact that after CCB was eliminated, this is the Bank that “shelters” loans of companies associated with Delyan Peevski. These loans are also non-performing and amount to at least 250 million levs, showed a recent investigation of our media.

Huge “bad” exposures

The main part of the report focuses on credit risk, where major irregularities have been established – the granting of loans and the management of the credit risk are carried out in violations of the Credit Institutions Act and the regulations of BNB. The report lists nearly 30 such violations, mainly classifying exposures from “loss” or “non-performing loans” in the group of “regular” loans. Here, the recommendations specifically state that the equity of the Bank is not sufficient and should be increased.

Based on a sample of one third of the loans, the inspection found that non-performing receivables are substantially more than entered. The bank posted only 5.76% as substandard loans, while the figure projected by the inspection is 21.72%. The actual amount would be much larger when taking into account the remaining two third of the portfolio that has not been reviewed. This can be found between the lines, but not explicitly stated, probably because it is difficult to admit that

50% of all loans granted by FIB are non-performing or total loss

The “Violations of Regulations” part lists several major groups of companies with such loans, all connected to notorious Bulgarian moguls like Hristo Kovachki, Vasil Bozhkov, Grisha Ganchev and companies associated with the Bank’s owners Tseko Minev and Ivaylo Mutafchiev. All of them are not servicing their loans, but this a strongly guarded secret. BNB has known all along about the colossal violations. Therefore, it is safe to conclude that this is a criminal robbery scheme actively protected by the State.

In fact, the report reveals that the money of depositors in FIB is being methodically robbed by the owners of the Bank and by emblematic oligarchs. All this is well known, but was concealed by BNB and the first government of Prime Minister, Boyko Borisov. The crime is ongoing until time comes again for taxpayers to pay from their own pockets.

How many reports on FIB are actually hidden? What did BNB say about the reports? Which companies are borrowers under the unsecured exposures of FIB, according to BNB?

/To be continued/

BULGARIAN NATIONAL BANK (BNB)

BANKING SUPERVISION DEPARTMENT

REPORT OF THE SUPERVISION INSPECTION

Bank FIB (First Investment Bank)

Grounds: Order №РД 22-0301/February 16, 2012

Reporting Period: December 31, 2011

Composition:

Duration:

Coordinated with:

Contact person:

  1. The report has been prepared in two identical copies, one for each side and represents a professional secret.

TABLE OF CONTENTS

  1. Purpose, scope and sources of information, page 3
  2. General conclusions of the inspection, page 4
  3. Violations of regulations, page 5
  4. Recommendations of the inspection, page 8
  5. Violations established by previous inspections, page 10
  6. Recommendations of previous inspections, page 11
  7. Credit risk. Concentration risk, page 13
  8. Liquidity risk, page 22
  9. Sensitivity to markets, page 24
  10. Operational Risk, page 26
  11. Ability to generate profit, page 28
  12. Capital and core capital, page 30
  13. Internal Audit, page 32
  14. Signatures of inspectors, page 33

OBJECTIVES AND SCOPE OF THE INSPECTION

Supervisory inspection to assess credit, market, operational and liquidity risk, profitability, capital adequacy (core capital) and other issues related to the activities of the Bank.

Sources of information

  • Documents and records prepared and presented by the Bank, according to the letter of required information;
  • Credit files as a sample of the loan portfolio;
  • Conversations and meetings with executive directors, directors of departments and employees of the Bank;
  • Additional information and documents required by the inspection;
  • Financial statements, statements under the regulations of the BNB, as well as periodic reports and reports prepared in the course of the ongoing supervision of the Bank;
  • Other;

GENERAL CONCLUSIONS

  • The credit risk is underestimated as its real reporting and provisioning could worsen the main indicators of risk assessment. The capital position of the bank is under very high pressure from the poor quality of the loan portfolio, the high concentrations, the large amount of exposures to entities gravitating around the majority owners (shareholders) and drawbacks in the systems for management of the undertaken risks. In view of the above and the intended by the bank asset increase, it is necessary to increase the equity. There is a need of improvement of the internal analysis of the capital adequacy and ensuring higher capital to meet the requirements under the second pillar.
  • The systems for identification, analysis and management of the credit risk and the concentration risk need considerable improvement. Concentrations of exposures to several large groups of corporate clients with various indications of connectivity exert pressure on the capital. Much of the credit portfolio is formed by loans to companies with offshore property, which hinders the identification of connectivity, respectively, increases the risk for the institution. The Bank continues to allow violations of regulatory requirements for classification of risk exposures – a significant portion of its receivables is not adequately assessed and provisioned. Various techniques to delay the manifestation of credit risk are being applied and they improve the performance levels of asset quality, reduce the impairment charges and the amount of specific provisions. The level of provisioning is one of the lowest in the banking system and does not correspond to the quality of the loan portfolio. Risk related to retail exposures is underestimated and credits are actively restructured in order improve the quality of this portfolio.
  • The condition and the management of the liquidity are at an acceptable level. Despite the good liquidity indicators, the liquidity position could end being under pressure if there is a slight reduction of deposits due to the established practice for permanent deferral of payments for much of the exposures. There is a trend to maintain much of the liquid assets in the form of receivables from banks non-residents and foreign securities. The opportunities for external financing are very limited.
  • The Bank’s exposure to market risk is low. The institution’s rules and procedures for control and management of market risk are adequate to the volume and scope of its activities.
  • The Bank has high sensitivity to operational risk. Despite the measures taken to contain it, the quality of management of this risk needs to be improved.
  • The capability of the bank to generate profit is overvalued, given the low level of provisioning and the significant share of due but unpaid interest.
  • The activity of the internal audit unit needs improvement mainly in implementing the regulatory framework of the bank’s assessment of credit / concentration risk and the necessary equity.
  • The Bank is exposed to relatively high reputational risk.
  • The management commits significant breaches of the regulatory framework.

VIOLATIONS OF REGULATIONS

Article 44, Paragraph 5 of the Credit Institutions Act (CIA), Article 2 and Article 7 of Regulation №7 – exposure to Burgas Shipyards and connected parties exceeds 25% of the equity of the Bank;

The Bank incorrectly reported exposure to Burgas Shipyards in the report under Regulation №7. Under Article 8, Paragraph 5 of Regulation №7 of BNB, the implementation of Paragraph 2 of the same Article is applicable only in cases when the guarantor meets the requirements of Chapter Six of “Credit Risk Mitigation” of Regulation № 8 of BNB. In this case, the Burgas Shipyards cannot be deemed an eligible guarantor as they don’t fulfill the requirement of Article 143, Paragraph 7 applicable to legal entities-guarantors, requiring a minimum credit rating of A+ in order to be recognized as providers of credit protection. For this reason, the hypothesis of Article 8, Paragraph 2, is inapplicable to the aggregate of original borrowers covered by the “conditional” loan (including Burgas Shipyards). The proper reporting should treat all exposures under the “conditional” loan as connected parties and they should be presented in the report under Regulation №7 with their balance value;

Article 44 of CIAI in connection with §1 the additional directives of CIA and Paragraph 2, Article 7 of Regulation №7 for the following exposures:

  1. Eco Farms Ltd is not included in the exposure of Gondol Ltd. (§1, item 4, letter “г” from CIA);
  2. BH & Via Properties Ltd. is not included in the exposure to V Estate Ltd. (§1, item 4, letter “д” from CIA);
  3. The exposures of lntercount Investments Limited Ltd., Sigmatura Ltd. and Santa Fe Trading Ltd. are not reported as connected parties § (1, item 4, letter “г” from CIA);
  4. Litex Nomere is not included in the exposure of Litex Property (§ 1, item 5 of CIA)
  5. Litex Nomere is not included in the exposure of the Burgas Sugar Factory (§ 1, item 5 of CIA);
  6. Elite Group 2003 Ltd. Is not included in the exposure of Coal Company Ltd (§1, item 5 of CIA);
  7. Eco Farms Ltd. should be included in the exposure of Sidegreave Investments Ltd. – Cyprus (§ 1, item 5 of the CIA);
  8. The loans of Argus Properties PLC should be reported with all their value in all exposures of connected parties, where they participate (Article 2, Paragraph 1, Article 3, Paragraph 1 and Article 7, Paragraph from Regulation №7 of BNB);

Article 45 of CIA – the exposure of Balkan Financial Services Ltd. does not include the loans of Svetoslav Stonov Moldovanski and Stanislav Bozhkov Ganev;

Article 3, Paragraph 2 of Regulation №9 of BNB:

  1. Loans to Bulgarian Maritime Company Ltd. should be reported in the same classification group with Intercount Investment Ltd. (“under supervision”, according to the inspection);
  2. Loans to Litex Commerce AD should be reported in the same classification group as the Burgas sugar factory and Litex Property (“under supervision”, according to the inspection);
  3. Loans to Libero and Vidya B 04 should be reported in the same classification group as Santa Fe Trading Ltd. (“non-performing”, according to the inspection);
  4. Loans to Elite Group Ltd. 2003 should be reported in the same classification group as Coal Company (“non-performing”, according to the inspection);
  5. The exposure of EAZ AD is incorrectly classified numerous times as “regular” instead of “non-performing” as carriers of a common risk with Tower Sofia;
  6. The loans of Megalink, Railway Infrastructure Holding Company should be reclassified as “loss” as carriers of a common risk with the National Transport Research Institute;
  7. 7. The exposure of Vasil Bozhkov is incorrectly classified as “regular” rather than “loss” in connection with Railway Infrastructure Holding Company;
  8. The exposure of the Plant for Concrete Structures and Products Ltd. is incorrectly classified as “regular” instead of “loss” in connection with Railway Infrastructure Holding Company;
  9. The loans of Build Overseas Trading Ltd. are reported by the Bank in two different classifications groups – “regular” and “under supervision”;
  10. The loans of Port Investment Development – Bulgaria 2 are reported by the Bank in two different classification groups “regular” and “loss”.

Article 5, in connection with Paragraph 8 of Regulation №9 of BNB – the Bank has incorrectly classified as “regular” the loans of Eliks Ltd., VMP Ltd. Mega El Ltd, Lead and Zinc Complex AD, Camilla Ltd., Alpha Brands Ltd., SSF Steel Shipping and Forwarding and the overdraft of Mine Company Ltd., which are occurred exposures resulting from the implementation of off-balance commitment;

Article 5, in connection with Paragraph 9 of Regulation №9 of BNB – the Bank has incorrectly classified the exposures of Sigmatura Ltd. and New Express Finance Ltd in the group “regular” instead of “under supervision”;

Article 5, in connection with Article 9, Paragraph 1 and Article 13 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Bolsa Ltd. and Intercount Investment Ltd. in the group “regular” ” instead of “under supervision”;

Article 5, in connection with Article 9, Paragraph 1 and Paragraph 2 and Article 13 of Regulation №9of BNB – December 31, 2011, the Bank has incorrectly classified the exposure of Litex Property Ltd. in the group “regular”” instead of “under supervision”;

Article 5, in connection with Article 9, Paragraph 2, Item 1 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures Road Engineering and Burgas Sugar Factory in the group “regular” ” instead of “under supervision”;

Article 5, in connection with Article 9, Paragraph 1, Item 3 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Maritsa TPP in the group “regular” ” instead of “under supervision”;

Article 5, in connection with Article 10, Paragraph 1, of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures of Santa Fe Trading Ltd., Coal Company Ltd. Mine Company Ltd in the group “regular” instead of “non-performing”;

Article 5, in connection with Article 10, Paragraph 1 and Article 8, Paragraph 3, of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Coal Mining Company Bobov Dol Ltd. in the group “regular” instead of “non-performing”;

Article 5, in connection with Article 10, Paragraph 1 and Article 13, Paragraph 3, of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures of KBS Petroleum (Middle East) Ltd., Leza Ltd, Road Construction AD in the group “regular” instead of “non-performing”;

Article 5, in connection with Article 10, Paragraph 1 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Chesteam in the group “regular” instead of “non-performing”;

Article 5, in connection with Article 10, Paragraph 1 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Outdoor Advertising Media in the group “regular” instead of “non-performing”;

Article 5, in connection with Article 10, Paragraph 1 and Article 3, Paragraph 2 (joint risk with Eco Farms Ltd.), of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures of Sidegreave Investment Ltd. in the group “under supervision” instead of “non-performing”;

Article 5, in connection with Article 10, Paragraph 1 and Article 2, Item 2 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures of Burgas Shipyards Ltd., Tower Sofia AD, Roads Holding AD, Eco Farms Ltd, Rubin AD Media in the group “regular” instead of “non-performing”;

Article 5, in connection with Article 11, Paragraph 1 and Paragraph 2, Item 2 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures of Argus Properties AD and DSP-1 AD in the group “regular” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 1 and Article 2, Item 2 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of V Estate Ltd. in the group “under supervision” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 1 and Paragraph 2, Item 2 and Paragraphs 3 and Article 3, Paragraph 2 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of BH Air & Via Properties in the group “regular” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 1 and Paragraph 2, Items 2 and 5 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposures of Steel Commodities AD, Intertrust Holding AD, Lean and Zinc Complex AD, SSF Steel Shipping and Forwarding AD  in the group “regular” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 1 and Paragraph 13 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Sirius Corporation in the group “regular” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 2 Item 3 and Paragraph 13 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of Gondol Ltd. and Regent Balkan Ltd. in the group “under supervision” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 2 Item 3 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified the exposure of ABC-2004 AD in the group “non-performing” instead of “loss”;

Article 5, in connection with Article 11, Paragraph 2 Item 1 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified in the group “regular” instead of “loss” the exposures of Nadezhda Zlatanova Pesheva and Dimo Plamenov Dimitrov;

Article 5, in connection with Article 11, Paragraph 2 Item 1 of Regulation №9 of BNB – by December 31, 2011, the Bank has incorrectly classified in the group “regular” instead of “loss” the exposures of the following individuals: Veliko Petrov, Kameliya Kostadinova, Matey Stefanov Markov, Angelina Orlinova Chausheva, Asen Vergilov Velizarov, Nikolay Tsvetanov Motkov and Maria Yordanova Tsoncheva;

Article 12 and Paragraph 1 of Regulation №9 of BNB – a collateral is incorrectly reported as “acceptable” or its size is incorrectly determined in the following exposures: Argus Properties AD, Entra Number One Ltd., Roads Holding AD (the unfavorable for the Bank treatment of “acceptable” collateral for “conditional” loans – explained detail in the credit risk section – is not reflected here);

Article 7 in connection with Article 12 of Regulation №9 of BNB – the Bank has not determined correctly the amount of specific provisions for credit risk for each exposure; with incorrect classification whose balance value exceeds the risk value of the exposure and / or accepted an incorrect value for the “acceptable” collateral for it;

Article 7 in connection with Article 12, Paragraph 1 of Regulation №9 of BNB – the size of the specific provisions for credit risk, classified by the Bank in the group “loss”, is incorrectly determined: Agromah, Meat Processing Plant Letnitsa, TVL Group, Kiril Mihalev Kirchev, Radoslav Petrov and others;

RECOMMENDATIONS OF THE INSPECTION

  1. Remove any violations of the regulatory framework.
  2. Pay greater attention to the outstanding recommendations of the previous inspection.

Credit Risk

  1. The “Risk Management” Directorate should be engaged with the ongoing monitoring of credit risk on the level of individual exposure so that the information supplied monthly by the business units to the Credit Committee on worsening exposures is checked and adjusted if necessary.  This would contribute to improving the processes of classification and provisioning, timely identification and reporting of risk and also limiting the omissions.
  2. For loans in the Cyprus branch and loans to entities registered abroad, there is need of a periodic risk assessment, to be provided to the management.
  3. To improve the process of reporting of “acceptable” collateral in the main application and the respective registries in order to avoid incorrect reporting of collateral not meeting the requirements for such (expired realization, etc.) as “acceptable”.
  4. In order to optimize the management of credit risk there is need to prepare a registry of “conditional” loans with a set of parameters so that it can be determined which balance and off-balance exposures are backed with the “conditional” loan; the allocation of the collateral of the “conditional” loan to the exposures secured by it; the unused part of the collateral of the “conditional” loan, etc..
  5. The unused part of the collateral of the “conditional” loan must be reported off-balance as credit commitment and be accordingly noted in supervisory reporting in accordance with regulations and the instructions that go with them.
  6. To analyze what is the cause of existing cases of incorrect classification and provisioning in some retail exposures while keeping in mind that the process should be automated. After the preparation of the analysis and determination of this cause – to undertake measures to remedy the problem.
  7. Restructured loans (including granted new loans to repay old arrears) of individuals should not be reported as “regular” while they are in a period of relief payment and should be classified at least in the group “under supervision”.

Liquidity Risk

  1. The Bank to audit and analyze in full, as a potential cash outflow, its off-balance commitments.
  2. To adopt more conservative assumptions for withdrawal of funds from depositors in various versions of a liquidity crisis, especially for the citizens’ resource.

Operational Risk

  1. To optimize the process of providing access to online banking in order to avoid possible losses.
  2. In carrying out a test of activity continuity to define the relevant assumptions, and to provide the result to the Bank’s management in an official report.
  3. To secure the possibility to work with customer data from the Cyprus branch in real time through the main program application.

Capability to Generate Profit

  1. Given the significant portion of accrued interest (for most of it, it is agreed that it will be paid with the maturity of the respective loans) and overdue interest in the income of the bank, what should follow is to evaluate the uncertainty of receiving the cash flow under this exposures and to undertake measures to minimize it.

Capital

  1. To increase equity, so that capital indicators are substantially above regulatory requirements.
  2. To improve the process of internal analysis of core capital (specific guidelines are described in the section on capital).

Internal Control

  1. To analyze to what extend it is appropriate to include handling and answering complaints in the operation of the unit, as it is a function uncharacteristic for it.

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