From thebeginning of the business, Vietcombank has significantly contributed to the stability and growth of national economy, played an important role as a key foreign trade bank of Viet
INTRODUCTION
Problem statement
Vietnam's ongoing economic development, especially after the 2008–2012 financial crisis, has coincided with rapid evolution in the commercial banking sector, which has emerged as a primary channel for channeling capital into the economy In the open market, credit provision remains the core function of banks, with interest income from lending forming the central source of bank revenues A key finding from KPMG's Vietnam Banking Survey 2013 shows that loans and advances to customers account for more than 50% of banking assets, and revenues from credit activities constitute roughly half to two-thirds of total bank revenues.
Commercial banks expand their operations by diversifying products, customers, and market niches, but this growth brings inherent risks: credit risk, market risk, and operational risk (Golin & Delhaize, 2013) Among these threats, credit risk is the primary concern, accounting for the largest share and the most complex interconnections with other risk types When credit risk materializes, it can lead to substantial financial losses and damage to a bank’s reputation, undermining public trust in the banking system Because of its broad and cascading links, credit risk can act as a catalyst for broader financial or social crises.
Bad debt is the leading indicator of credit risk, with a high level signaling a bank’s limited ability to control credit risk At Vietcombank’s conference on the six-month 2015 financial results, Chairman Thanh Nghiem voiced concern about credit quality and the bad-debt situation Although credit growth approached 7%, it was 6.52% higher than the average, while gross bad debt increased by 1.012 billion VND compared with the end of 2014 During the author’s internship at Vietcombank, this issue was repeatedly raised in every meeting, sparking curiosity to understand the underlying causes and to outline a workable model for credit risk management.
Research objectives and questions
This study analyzes Vietcombank's current position in credit activities, credit risk, and credit risk management, with the ultimate goal of drawing clear answers to two research questions that guide risk assessment and strategic decision-making in the bank's lending operations.
• What do credit growth and bad debt of Vietcombank reflect?
• Is it possible to build up an effective model of credit risk management for Vietcombank?
Research methodology
Employing a qualitative analysis approach, this study investigates the credit risk issues at Vietcombank and proposes a decision‑making model to underpin loan approval Primary data were drawn from Vietcombank’s official website and annual reports, with additional corroboration from reliable newspaper articles and reports by reputable financial institutions An interview with a credit expert in Vietcombank’s Bad Debt Handling Department further extends understanding of the bank’s credit activities, risk assessment practices, and debt management Taken together, these insights support a model that provides a solid basis for lending decisions and risk control.
Research structure
The study comprises four chapters: it begins with an introduction that presents the research background, objectives, and the methodologies employed; the second chapter constructs the theoretical framework for credit risk in the banking sector and explains how commercial banks typically manage credit risk, with a focus on the Vietnamese banking industry; the third chapter analyzes Vietcombank’s credit activities over 2012–2014 and the first half of 2015, highlighting issues of rapid credit growth and high bad debt; the final chapters propose a practical working credit risk management framework and finish with a concise conclusion that summarizes the key findings.
THEORETICAL FRAMEWORK
Commercial banks in Vietnam
Commercial banks differ from other banks by the range of services they provide to the economy They are defined as profit-driven institutions that handle money and credit; they accept public deposits for safety and then lend those funds to individuals or organizations in need (Leaf, 1927; Gobat, 2012) In the United States, a commercial bank is an entity that accepts federally insured deposits, pays interest on those deposits, and simultaneously extends both residential and commercial loans while underwriting securities such as U.S Treasuries, commercial paper, and bonds (Getter, 2016) In many Asian markets, commercial banks offer a broader mix of services, including traditional lending and deposit-taking, as well as investment banking, insurance, and asset management (Laeven, 2005).
• Accepting deposits from fund savers
(current account deposits, fixed deposits, and saving account deposits)
• Making loans and advances in form of cash credit, demand loans, overdraft, and short-term loans
• Investment: in securities such as
Government securities, other approved securities, and other securities.
• Discounting bills of exchange or bundles
• Agency functions: transferring funds, collecting funds, making payments of tax, insurance and bills as per the direction of customers, purchasing and selling securities, collecting dividends, etc.
• Performing general utility services such as locker facility and underwriting securities.
Although definitions of commercial banks differ across countries, they are typically categorized into two main functions: primary functions and secondary functions (Nguyen, 2016) The activities that fall within each function group are described below, showing how commercial banks organize their operations into these two categories.
Table 1: Commercial banks’ primary and secondary functions (Academic Collective, 2016)
Commercial banks play a significant role in both the national banking system and the broader economy Olokoyo (2011) suggests that they mobilize and allocate the largest pools of savings and capital, contributing to economic growth and development Their importance is evident in three dimensions: information processing, risk sharing, and money creation (Mehta & Fung).
Commercial banks collect information from both depositors and borrowers to assess financial health and monitor capital flows associated with lending activities When extending loans, banks share risk with depositors in case borrowers default, aligning the interests of savers and borrowers (Martin et al., 2018) Banks also enable the money supply through credit creation, a process driven by primary deposits (money from savers) and secondary deposits governed by reserve requirements (Academic Collective, 2016) Through these functions, commercial banks provide substantial support to government efforts to manage and generate money supply for expenditures across social, economic, and political programs (Mehta & Fung, 2008).
2.1.2 Operation of commercial banks in Vietnam
Vietnam’s commercial banking sector can be categorized into wholesale and retail banks, though most institutions offer both types of services (Hull, 2010) Wholesale banks focus on corporate lending, while retail banks target individuals and small businesses as their primary customers Among foreign banks operating in Vietnam, ANZ Banking Group—recently acquired by Shinhan Bank—stands out as the only bank primarily targeting retail banking, whereas most foreign banks emphasize commercial and wholesale activities by funding foreign direct investment (FDI) projects rather than domestic private-sector enterprises (Vuong, 2010).
Vietnam's commercial banks are categorized into three ownership types—state-owned commercial banks (SOCBs), joint-stock commercial banks (JSCBs), and wholly foreign-owned banks (WFOBs)—a tripartite framework highlighted by Tran et al (2015) that shapes governance, strategic direction, and market dynamics across the Vietnamese banking sector as of 2018.
• 100% or majority-owned by the Government (or SBV)
• Traditional customers are state- owned enterprises (SOEs) and non-SOEs
• More diversified shareholding structure than SOCBs since they are listed on the stock market
• Focusing on making loans to Small & medium enterprises (SMEs) and retail banking
MB Bank, SCB, EIB, VIB, SHB
• Present in Vietnam since early 1990s after the country opened the doors for foreign business.
• Strictly complying with Vietnamese laws.
Vietnam’s banking sector comprises four state-owned commercial banks (SOCBs), 31 joint-stock banks (JSCBs), and eight wholly foreign-owned banks (WFOBs) Foreign lenders such as HSBC, Shinhan Bank, Standard Chartered, and Woori Bank operate in Vietnam, contributing to the market’s depth and international connectivity All banks in Vietnam are supervised and regulated by the State Bank of Vietnam (SBV), the central bank, which sets prudential standards, licensing requirements, and ongoing oversight to maintain financial stability and support sustainable growth and trade.
2018) The characteristics of each type of commercial banks are summarized in the table below:
Table 2: Types of commercial banks by ownership (Tran et al., 2015)
Within Vietnam’s three main types of commercial banks, state-owned banks (SOCBs) still dominate the sector, holding more than 44% of total assets Joint-stock banks (JSCBs) account for about 42%, while foreign banks hold roughly 11% of assets, according to Tran et al (2015).
Vietnamese banking sector by assets
Figure 1: Vietnamese banking sector by assets (Tran et al., 2015)
Despite the smallest number of players, state-owned commercial banks (SOCBs) still dominate Vietnam’s banking sector with the largest market share The four SOCBs—Agribank, Vietnam Joint Stock Commercial Bank for Industry and Trade (Vietinbank), Bank for Investment and Development of Vietnam (BIDV), and Joint Stock Commercial Bank for Foreign Trade of Vietnam (Vietcombank)—are the country’s leading banks, according to the State Bank of Vietnam (2016).
Credit risk in Vietnamese banking system
Credit risk is intrinsically linked to the core functions of commercial banks—taking deposits from savers and making loans to individuals and organizations—and, because of these activities, banks face a wider range of risks than other financial institutions, with credit risk as the major threat According to Van Greuning & Bratanović (2009), approximately two-thirds of a commercial bank’s balance sheet is tied to risk management activities Credit risk often stems from lending activities such as loans to individuals and organizations, financial guarantees, letters of credit, investment portfolios, and the acceptance of credits (Bandyopadhyay, 2016) Nevertheless, the dominant sources of credit risk are loans to individuals and corporates, which account for about half to three-fourths of total bank assets (Papin, 2014).
Credit risk in literature is defined in multiple ways by economists, policymakers, and researchers It is often described as the probability that a bank’s assets, particularly loans, will decline in value or become worthless The Basel Committee on Banking Supervision defines credit risk as the potential that a borrower may fail to meet obligations on agreed terms with the bank Sironi and Resti describe credit risk as the possibility that an unexpected change in a counterparty’s creditworthiness may produce an unexpected change in the market value of the related credit exposure Koch and MacDonald relate credit risk to the quality of individual assets and the likelihood of default, implying potential variation in net income and in the market value of equity from nonpayment or delayed payment of principal and interest Credit risk is also considered a main driver of cash flow problems and bank liquidity stress In Vietnam, the State Bank defines credit risk as the possibility of losses when borrowers reject repayment or fail to execute their commitments.
Credit risk occurs when borrowers—individuals or businesses—cannot repay loans, leading to financial losses on a bank's balance sheet Such losses reduce net income and can undermine profitability and liquidity, especially during large depositor withdrawals Nevertheless, lending activities attract banks because loan interest rates typically exceed deposit rates, delivering higher returns As a result, commercial banks are unlikely to abandon lending as a core service despite the associated risks.
Credit risk is a component of financial risk and can be broken down into two primary sub-risks: transaction risk and portfolio concentration risk (Figure 4) Both of these risks may originate from issuers or counterparties, shaping the potential for default or adverse credit events and the effects of exposure concentration on overall portfolio losses.
Figure 2: Types of credit risk at commercial banks
Transaction risk in lending arises during loan disbursement and credit administration when banks violate their credit policies, according to the Comptroller of the Currency (1998) This risk is linked to the adequacy of information systems and internal controls, the quality of operating procedures, and the capability and integrity of bank employees Put simply, it can occur when staff are reluctant or fail to assess borrowers' creditworthiness and to select creditworthy clients It may also reflect a lack of hedging strategies for credit defaults or an inability to detect and resolve bad debt problems when they occur (Spjut).
2018 research indicates that banks face higher transaction and credit risk when their information systems fail to provide sufficient data to identify borrowers’ entities, facilities, or financial statements; as a result, lending to a company on the verge of bankruptcy significantly increases the likelihood of financial losses for the bank.
Portfolio concentration risk arises when a bank's lending portfolio cannot be perfectly diversified because a large share of exposures is tied to a small group of clients (Grippa & Gornicka, 2016) When lending is concentrated on a few borrowers, diversification benefits erode, increasing the potential for instability in banks and the broader banking system Historical examples include exposures to large borrowers such as Enron and WorldCom, which contributed to the financial problems of several U.S banks in the early 2000s, and the global financial crisis, which followed housing-market turmoil and concentrated mortgage portfolios that led to numerous bank failures (Grippa & Gornicka, 2016).
Analysis indicates that commercial banks cannot eliminate credit risk because lending activities remain a major source of income Consequently, credit risk management centers on minimizing exposure to credit risk and preventing large losses By implementing robust risk assessment, monitoring, and mitigation strategies, banks can protect profitability and financial stability while sustaining prudent lending growth.
2.2.3 Credit risk and bad debt
Credit risk is closely tied to bad debt, which is the main source of credit risk for banks Bad debt is debt that cannot be collected from debtors and therefore becomes worthless to creditors The higher the bad debt, the greater the trouble for banks, affecting profitability and their ability to meet obligations to depositors Another major source of credit risk for banks is non-performing loans (NPLs), defined as loans whose payments are overdue by more than one year and have no repayment Because bad debt and NPLs are key risk factors, they can be measured to assess a bank's credit risk The primary metrics used are the bad debt ratio and the NPL ratio, which quantify the extent of credit risk in a bank's loan portfolio.
• Bad debt ratio = Bad debts/ Gross customer loans
• Non- performing loans (NPL) ratio = Non- performing loans/ Gross customer loans
Credit risk in commercial banks can be assessed using the bad debt ratio and the non-performing loan (NPL) ratio, yet the level of NPLs is also shaped by internal and external factors For example, Akter & Roy (2017) argue that banks charging relatively higher lending rates and extending excessive loans tend to have higher NPL levels Consequently, policymakers aiming to manage bank credit risk should consider both internal practices and external conditions that drive NPLs and bad debts.
2.2.4 Importance of credit risk management at banks
Credit risk significantly affects a bank's profitability and its ability to repay depositors, making robust credit risk management essential By keeping credit exposure within clearly defined, acceptable parameters, banks can maximize their risk-adjusted return and strengthen overall financial stability.
Credit risk management helps commercial banks balance profitability with an appropriate level of credit risk, supporting the soundness of both individual banks and the overall banking system (Bank for International Settlements, 2000) The actual level of credit risk depends on several factors, including the borrower type (individuals or organizations), counterparty structure, loan purpose, and loan maturity (short-, medium-, or long-term) (Joseph, 2013) Borrowers can be individuals, households, or corporate entities, and loans can fund personal consumption, education, business activities, or investments To accurately assess credit risk in lending, banks must consider all these factors in their risk evaluation and management processes Using risk assessment techniques to determine the risk level of each loan and borrower is central to effective credit risk management and the minimization of risk across the bank's loan portfolio (Boffey & Robson, 1995; Konovalova et al., 2016).
2.2.5 Current situation of credit at Vietnamese commercial banks
A study conducted by Muhamet & Arbana (2016) shows that 98% of bank failures come from banks’ incidents related to poor asset quality due to factors such as poor loan policies, a non compliance with policies and guidelines and a poor supervision The authors highlight that they are factors of a poor credit culture Colquitt (2007) defines bank’s credit culture as “the attitude, style, perception and behavior that will be exhibited by the bank and is largely determined by the attitude of management towards credit risk and could actually be in conflict with the policies of the bank” Simply, credit culture refers to the relationship between banks and their customers Credit culture allows banks to connect and associate credit risk objectives, credit policies with credit strategy According to Barr & McWhorter (1992), a good credit culture starts from the top down to the bottom of banks through communication, meaning that all people at banks from top management to officers fully understand the lending policies and lending process Credit culture is able to strengthen the credit risk management of not only individual bank but also the whole banking system because of the interbank market by which the single credit culture of each bank can be unified and supported to each other (Guseva & Rona-Tas, 2014).
The process of developing a strong credit culture is presented in Figure 5:
Figure 3: Credit culture establishment process (McKinley & Barrickman, 1994)
1 Asset quality; long-term consistent
2 Immediate earnings, stock price 2 Immediate-performance driven
3 Market share, market domination, loan growth, volume
Corporate priorities are determines based on various elements such as banks’ objectives, strategy, customers base, bank size, and types of ownership Strischek (2002) argues that no matter which priorities are determined, the successful credit risk management must ensure the profitability, asset quality, and growth of banks Based on priorities, there are four types of credit culture, including values driven, immediate-performance driven, production driven, and unfocused driven culture (Strischek, 2002).
Table 3: Matching corporate priorities and credit cultures (Strischek, 2017)
Figure 6 shows four distinct credit cultures: value‑driven, immediate‑performance driven, market‑share (product) driven, and unfocused Value‑driven credit culture emphasizes long‑term, consistent performance and a strong credit environment shaped by few policy exceptions and clear top‑down communication from senior management to frontline staff Immediate‑performance driven culture prioritizes profitability while preserving credit quality in strong economic periods and pursuing riskier investments when loan demand is weak Market‑share or product‑driven culture centers on loan volume and growth, which can push banks to meet targets at the expense of lending policy, requiring a tight loan‑approval process with limited empowerment Unfocused credit culture lacks clear priorities, leading to frequent management changes and confusion from shifting objectives, making it the least preferred option.
Credit risk and credit risk management in Vietnamese banking sector
2.3.1 Key players in credit market
As of July 2018, Vietnam’s banking sector consisted of four state-owned banks (SOCBs), 31 joint-stock banks (JSCBs), and eight wholly foreign-owned banks (WFOBs), all supervised by the State Bank of Vietnam (SBV), the country’s central bank Among the commercial banks, the four SOCBs were VietinBank, Vietcombank, BIDV (Bank for Investment and Development of Vietnam), and Agribank (Vietnam Bank for Agriculture and Rural Development).
Development of Vietnam (BIDV), and Joint Stock Commercial Bank for Foreign Trade of
Vietnam (Vietcombank), dominates Vietnamese credit market (Figure 7)
Total assets and credit portfolio of three Vietnamese biggest commercial banks at 30 June 2017 (billion VND)
Figure 4: Total assets and credit portfolio of three Vietnamese biggest commercial banks at 30 June 2017
In 2017, Vietnam’s three largest banks posted an average credit portfolio growth of about 15%, supported by a simultaneous uptick in the bad debt ratio Yet, when compared with 2014/2015, their bad debt levels showed clear improvement, with BIDV’s NPL moving from 2.3% to 1.93%, Vietcombank’s from 2.97% to 1.51%, and Vietinbank’s from 1.5% to 1.17%.
Figure 5: Bad debt ratio of Vietnamese commercial banks (Vietnambiz, 2017)
Vietnam's largest banks are increasingly prioritizing a healthy credit environment and tighter management of the bad debt ratio To safeguard financial soundness, credit risk management has attracted greater attention, with positive indicators showing improvements in the bad debt ratio and continued credit growth.
Credit risk assessment and management prove most effective when sources of credit risk are accurately identified Akter and Roy (2017) argue that bank credit risk largely stems from both internal and external environments Internal factors encompass specific determinants such as management inefficiencies within commercial banks, insider lending, poor credit management, unbalanced sector lending, and speculative lending (Naceur & Omran, 2011) External factors can be grouped into three categories: general macroeconomic factors (e.g., inflation, unemployment rate), directional factors (e.g., GDP, GDP per capita), and market conditions factors (e.g., interest rates and stock market indices) (Figlewski et al., 2012) The credit risk management process enables commercial banks to identify, measure, mitigate, prevent, or reduce the potential negative impact of credit risk.
Credit risk management in Vietnamese commercial banks can be centralized or decentralized In a centralized system, credit risk is managed by a single organizational unit that takes direct responsibility for supervising the entire risk-management process, typically headed by a Chief Risk Officer (Aksel, 2017) In contrast, a decentralized system places decision-making influence on those closest to the risk, characterized by high participation and a lower level of hierarchical authority (Lindè & Wallgren, 2012; Andrews et al., 2009) Decentralization may suit smaller banks by saving time and costs, but Alonso et al (2008) argue that banks are increasingly favoring centralized structures to improve coordination and regulatory compliance, and a clear hierarchy can help avoid internal conflicts and boost productivity (Andrews et al., 2009).
In case of Vietnam, commercial banks are encouraged to conduct centralized credit risk management based on market conditions and the unique characteristics of Vietnamese banking system:
• Head office: a department of credit management headed by Chief Risk Officer.
• Bank branches: Specific team of sales, credit analysis and operation which work together in credit approval process.
RISK MANAGEMENT OF JOINT STOCK COMMERCIAL BANK FOR
Overview of Vietcombank
Vietcombank (Joint Stock Commercial Bank for Foreign Trade of Vietnam, VCB) was founded in 1963 as the Foreign Exchange Bureau of the State Bank of Vietnam and has since grown into one of Vietnam’s four largest banks, alongside VietinBank, BIDV, and Agribank Listed on the Vietnamese stock exchange since 2009, it has more than five decades of history, offering a broad product portfolio and customer-focused services while emphasizing sustainable development and responsible employment practices The bank has earned numerous national and international honors, including being named among the Top 1,000 Leading Asian Brands by Nielsen Market Research Company and Campaign Asia Magazine, receiving the Best Commercial Bank in Vietnam award from the Asian Banker Summit, and ranking as the Top 500 Strongest Bank in the Asia-Pacific (first in Vietnam and 62nd overall) by The Asian Banker.
Loan loss reserve coverage (Provision/NPL) 91.07% 86.29% 94.43% 120.63
CreditCost 1.47% 1.37% 1.53% 1.71% 1.51% 1.23% for Employees”, showing bank’s outstanding efforts to improve benefits and working environment for employees.
Since its inception, Vietcombank has played a pivotal role in stabilizing and fostering Vietnam’s national economy and has established itself as a leading foreign-trade bank with influence that extends to regional and international financial communities By the end of 2015, the bank operated more than 400 branches, including overseas locations, and an extensive ATM network with over 2,100 machines and 49,000 points of sale nationwide Vietcombank also maintains relationships with approximately 1,800 banks across 155 countries Compared with other local banks, Vietcombank leverages advanced technologies to diversify its product portfolio, offering Digital Lab, Internet Banking, VCB Money, SMS Banking, and Phone Banking to make banking easier and more convenient for customers.
Non-interest income∕θperating Incomeθperating Incomeperating Income 27.5ắ 30.5% 32.0% 27.1% 25.5% 25.
Pre-Provision Operating Profit/EqUity 25.8% 22.1% 24.4% 29.2% 32.1% 34.
Table 4: Vietcombank’s financial figures from 2012 to 2017 (Vietcombank, 2018)
Vietcombank's growth has been driven by two core activities: deposits and lending Between 2012 and 2017, customer deposits grew by nearly 20%, reaching VND 708.5 billion, while lending rose by 17.9% compared with the previous period, reflecting a robust expansion in both funding and credit.
2016, reaching approximately VND 543.4 billion The ratio of loans to deposits has been reduced yearly, associated with continually decrease in non-performing loan ratio from 2.4% in
2012 to 1.14% in 2017, showing banks’ effort to control credit risk and avoid bad debt.
Vietcombank's profit margin mirrors the current income trajectory of Vietnamese commercial banks, with net interest income from traditional deposit-taking and lending gradually declining from 2.99% in 2012 to 2.66% in 2017 Meanwhile, non-interest income from fees and commissions grew significantly, averaging about 25% (Vietcombank, 2018) This shift indicates Vietcombank's greater emphasis on non-traditional activities such as securities trading and foreign exchange, reflecting a broader trend in both Vietnam and the global banking sector away from traditional banking toward fee-for-service models that diversify into securities trading, derivatives and foreign exchange (Baek et al., 2015).
Capital mobilization from economy 3.1.3 Business strategy Increased by 15%
Vietnam’s openness to international business since the late 20th century has created significant opportunities for local commercial banks like Vietcombank to expand their scale and reach At the same time, government policies enabling foreign entry pose challenges as numerous international banks enter the Vietnam market, intensifying competition in the banking sector As a result, local banks face pressure to continuously improve their services and products to meet evolving customer expectations and stay competitive.
Vietcombank's main objective is to become the best commercial bank in Vietnam by 2020 and to rank among Asia's 100 largest financial institutions as well as among the world's 300 largest financial corporations (Vietcombank, 2018).
• Rank 1 st in retail banking and 2 nd in wholesale banking by maintaining and developing local market while still select and develop international market.
• Best bank in term of profit
• Best bank in term of customer satisfaction
• Best bank in term of human resource quality
• Best bank in risk managementThe specific strategic target of Vietcombank in 2018 is presented in Figure:
Credit outstanding balance Increase by 15%
Profit before tax VND 13.3 trillion
Table 5: Vietcombank’s strategic target for 2018
Current credit performance
Lending activities of Vietcombank can be broken down based on different customers, including individuals, small & medium enterprise (SMEs), and corporations According to Vietcombank
(2018), more than half of Vietcombank’s loans are made to corporations, followed by individuals with 32.7% and SMEs with 9% (Figure 11)
Figure 6: Vietcombank’s loan breakdown by customers
VCB has observed a shift in loan distribution toward the retail segment, with individuals becoming a key growth driver alongside corporate borrowers The bank is actively increasing personal lending as part of its retail banking strategy, reflecting the impact of Vietnam’s large population and solid economic growth on demand for consumer credit According to Weldon et al (2015), only about one-fifth of Vietnam's population holds a bank account and roughly 3% has a credit card, underscoring the substantial growth potential of retail banking for Vietcombank and the wider Vietnamese market.
In fact, retail banking has been concerned by VCB since 2016, by 2017, the bank’s credit section grew by 17% against 2016, making it the leading role in the credit market.
Credit risk
3.3.1 Bad debt and non-performing loans
Credit risk in banking is closely linked to bad debt, the main driver of credit risk for banks Vietcombank (VCB) reports a steady improvement in its bad debt ratio, with the non-performing loan (NPL) ratio falling from 2.4% in 2012 to 1.14% in 2017, a level that remains lower than peers such as BIDV at 1.93% in 2017 For 2018, the bank aims to maintain this low bad debt level, targeting an NPL ratio not higher than 1.5%.
Under Decision No 493/2005/QD-NHNN issued by SBV in 2005, Vietcombank classifies its loans into five categories: current (1), special mention (2), sub-standard (3), doubtful (4), and loss (5) SBV requires all commercial banks to establish specific provisions for credit risk In Decision No 02/2013/TT-NHNN (2013), SBV defines that the specific allowance for credit risk is calculated based on loan grading and the corresponding allowance rate applied to the principal outstanding as at 30 November less the allowed value of collateral The allowance rates for groups 1 to 5 are 0%, 5%, 20%, 50%, and 100%, respectively Among these groups, loans in groups 3 and 4 are potentially non-performing, while loans in group 5 are uncollectible and therefore worthless to Vietcombank.
Vietcombank’s loan group has significantly changed over years The latest statistics show that in
In 2017, about 98% of Vietcombank’s loans fell into Group 1, signaling a highly collectible loan portfolio with minimal signs of bad debt (Vietcombank, 2018) Credit quality improved notably, with Group 2 debt reduced by 35% compared with 2016 Despite strong market performance, Vietcombank maintained substantial provisions for credit losses to hedge default risk The 2017 PACL reached VND 8.1 trillion, and the PACL/bad debt ratio stood at 130.7%, well above the 98% level recorded in 2014 (Vietcombank, 2018) These figures demonstrate Vietcombank’s robust capacity to absorb defaults Among national commercial banks, Vietcombank is the only one fully prepared for credit risk management and was named the “best bank for credit management” by the Asian Banker Summit in 2016.
Effective bad debt management is essential to the soundness and health of any bank Bad debts typically arise in Groups 3, 4, and 5, and Vietcombank treats this as a priority Vietcombank understands that managing bad debt frees billions of VND for reinvestment, strengthens a healthy credit environment, and boosts its financial capability in the international market The bank addresses bad debt from two sources: its own credit policies and support from SBV To maximize recovery, Vietcombank implements a range of policies through the debt-handling department at the head office and across branches, aiming to recover as much bad debt as possible before turning to government interventions as a last resort.
3.3.2 Potential factors causing credit risk
Vietcombank (VCB) stands out for the fastest credit growth and the lowest bad debt ratio in its sector According to the latest statistics on VCB's bad debt ratio, the bank's non-performing loan (NPL) ratio declined from 2.4% in 2012 to 1.14% in 2017, a level that remains relatively low when compared with peers such as BIDV, which reported an NPL ratio of 1.93% in 2017 Looking ahead to 2018, Vietcombank is expected to maintain this low bad debt ratio, with projections indicating the NPL ratio will not exceed 1.5%.
Vietcombank (2018) notes that despite positive results, credit risk sources must be considered since bad debt and non-performing loans persist Credit risk originates from both internal and external environments Internally, determinants include management inefficiencies, insider lending, unbalanced sectoral lending, and speculative lending (Naceur & Omran, 2011) Externally, macroeconomic factors (inflation, unemployment), directional indicators (GDP, GDP per capita), and market conditions (interest rates, stock market index) shape risk (Figlewski et al., 2012) For example, from 2008 to 2010, SBV issued monetary policies to steer the economy out of the global downturn, with GDP growing from 6% to about 7.5% and bank sector credit expansion rising from 22% to nearly 40% (KPMG, 2017) Three years later, credit growth fell to around 12% and the bad debt rate rose abnormally; the SBV governor attributed this to a deflationary period after inflation, which reduced consumption and investment and delayed production, causing some firms to struggle with loan repayment or bankruptcy By 2014, the level of problem loans decreased considerably across banks while credit activity remained sustainable, aided by the effective operation of the VAMC under SBV Internal factors of Vietcombank's credit risk have been identified.
Staff incompetence in credit knowledge undermines Vietcombank's credit operations, as daily credit staff lack a solid understanding of the bank's credit culture, leading to inadequate evaluation and processing of loan applications and misjudgment of customers This gap results in the assignment of unsuitable loan amounts, interest rates, and loan maturities, compromising risk assessment and loan performance.
The matter of staff morality in banking centers on the bank’s credit policy, which requires every credit employee to secure a designated amount of loans from existing or potential customers each month Staff also earn commissions for every loan they originate, linking compensation to loan volume This setup raises questions about ethical lending practices and whether monthly quotas and commissions could encourage prioritizing numbers over loan quality or risk management, underscoring the need for strong controls and ethical guidelines to ensure responsible lending.
At the bank, there is a de facto “silent rule” that if an employee cannot meet the loan quota, their job may be at risk Staff face difficulty not only in finding customers in need of loans but also in ensuring the credit quality of the loans granted to those borrowers Under pressure to hit targets, some may bypass or neglect compliance steps in the loan granting process to speed up applications This creates a serious challenge for the bank as it tries to address these cases while maintaining lending standards and regulatory compliance.
Loosening top-management oversight shifts the final loan-approval decision to staff, so if managers are indifferent to reviewing those decisions, credit risk can rise; after disbursement, staff are expected to monitor borrowers for potential losses, but this ongoing surveillance is often neglected Strong managerial supervision helps ensure lending practices remain disciplined, keeps credit operations efficient, and mitigates moral hazard in both lending and debt collection.
At the quarter meeting, Mr Thanh raised the issue of whether Vietcombank's current credit risk management model can withstand rapid credit growth in a fast-changing banking industry, and whether there exists a more effective model tailored for Vietcombank These considerations open opportunities for Vietcombank's top managers to reevaluate credit programs and overall credit risk management The bank plans a large-scale restructuring of its credit risk management in the coming years, aligned with the 2014 annual report's vision to elevate the bank's capabilities to actively monitor and control all customer information and loan data.
Credit risk management
Following SBV guidance, Vietcombank has implemented a centralized CRM system that consolidates risk management, sales, and operations to minimize credit risk and maximize staff expertise Vietcombank's credit risk management structure comprises three hierarchical levels: the Risk Control Committee, the Credit Committee, and the Functional Departments at the head office and across branches.
The Risk Control Committee issues credit and CRM policies, while the Credit Committee oversees the overall implementation of credit programs and ensures legal and regulatory compliance in credit activities Functional departments implement these guidelines from the Risk Control Committee across three core functions: the Sales Department tailors credit products to attract customers; the Operations Department completes all loan documentation in accordance with the law before transferring files to Credit Risk Management to ensure the assessed credit risk aligns with the bank’s risk appetite; for outstanding credit applications, final decisions are made at the head office by the Credit Committee.
Since 2003, Vietcombank has developed a credit rating model with consultancy from the World Bank and has continuously refined it to align with a customer-oriented approach In practice, the bank combines its internal rating system with independent rating assessments to inform loan decisions Independent ratings, provided by credit rating agencies, offer a supplementary source for assessing credit-worthiness but are limited to a small group of listed companies and tend to focus on the historical movements of stocks in the open market Given that Vietcombank’s major customer base consists of state-owned enterprises that are rarely listed, and with plans to expand growth in individual credit limits in the coming years, the advantages of relying on independent rating information are reduced Consequently, this section emphasizes Vietcombank’s internal rating model, designed by the Risk Control Committee with the purposes of strengthening risk assessment and guiding loan decisions.
Nguyen Van Tuan, Vice Managing Director of Vietcombank, said the bank focuses on overseeing shifts in customers’ creditworthiness and loan performance to optimize profitability Vietcombank has committed substantial resources to building an internal credit-scoring system designed to support and enhance its lending activities.
• Support in credit decisions: It helps to enhance the accuracy and effectiveness of the loan granting decisions, to provide supportive means for saving time, costs and reducing human errors.
• Management of credit risk: It is undeniably a tool to assess credit risk level of borrower.
Effective credit risk management starts by distinguishing good from bad customers and estimating each borrower's probability of default This is achieved by integrating credit policies, credit culture, and risk programs into the risk assessment, which helps set an acceptable risk level Decisions are then aligned with prudent banking practices, the institution's business strategy, and national banking regulations to ensure compliance and sustainable growth.
An effective model for customer service and management builds a solid base of customer information and supports data‑driven decision making When a borrower has a problematic loan, the model directs special attention to classifying the customer’s other loans in the portfolio to assess overall risk and guide targeted remediation At the same time, a good customer with a high rating score may receive favorable consideration in other trading transactions, reflecting their lower risk profile and trustworthy history This approach enhances risk visibility, improves service consistency, and helps optimize portfolio performance and profitability.
Foundations of bad debt provisions and allowances establish clear criteria for loan loss reserves, helping banks quantify the provisions needed to cover potential losses and prevent defaults Additionally, requiring high‑credit loans to be backed by valuable collateral assets reduces problem‑loan allowances, strengthening credit risk management and financial resilience.
• Support in managing information in groups and exporting the reports: Input data of credit rating system is diversified in customer’s operating activities and their credit portfolio.Vietcombank has incorporated high IT and credit rating model to better managing information and producing the reports scientifically
Credit risk level Loan classifica- tion
The internal credit rating model at Vietcombank has two scoring schemes for its customer targets of individuals/households and enterprises Both schemes though provide credit scores on the basis of non-financial and financial factors, there are different criteria used for assessment The credit scores range in the scale of 100 and Vietcombank rates its customer’s creditworthiness and classifies the loans accordingly
The model to score creditworthiness of individual/ household borrowers includes criteria of customer’s personal information and the relationship with the bank The final credit score is computed as:
Job πsksk Low Average I L-It ĨÕ
CSl payment At due date
Due date extensio n and paid
Past over- due or New cus- tomer
Individual credit score= 0.4* Final score of personal information + 0.6* Final score of relationship with bank
Table 7: VCB’s credit scoring for individual clients (Vo, 2015)
According to the bank's credit policy, individual credit rating activities must be conducted at least once every three months to ensure timely updates on potential changes in credit risk, enabling the bank to take proactive steps to mitigate adverse effects This approach also encompasses corporate client credit scoring, as outlined in section 3.4.3.2.
7 Current ratio Current asset Current liability
2 Quick ratio (Current asset- Inventory^ Current liability
1 Inventory turnover Cost of goods sold Average Inventory
Gross Revenue/ Average Account Receivables
5 Total asset turnover Gross Revenue/ Average total Assets
7 Debt to Asset ratio Total Debt/ Total Assets
7 Debt to Equity ratio Total Debt Total Equity
7 Overdue debt ratio Overdue debt Total bank debts
7 Return on Equity Earning before tax/ Total Equity
70 Return on Assets Earning before tax/ Total Assets
71 Gross margin Gross profit/ Total Revenues
72 Interest coverage ratio Eamings before Interest and Tax/ Interest pay- ments
(Earning before Tax + Depreciation!/ (Principle + Cost of debt)
T4 - Operating cash flow ratio Operating Cash flow/ Current Liabilities
Ti Net cash flow ratio Operating Cash Πow∕Salesow∕Sales
76 Cash to equity ratio Cash and cash equivalent/ Total Equity
Financial reporting data are sourced from the company’s financial statements, with the mandatory disclosures being the Profit and Loss statement and the Balance Sheet, while the Cash Flow statement is optional since Vietcombank’s information system can automatically derive it from the other two reports; all financial criteria in these statements must comply with the standards set by the Ministry of Finance, as specified in Decision 200/2014/TT-BTC.
2014) It makes it more convenient for the bank to collect the necessary financial figures by the
IT system There are 16 norms of financial criteria classified into five groups.
Table 8: VCB’s financial scoring group
• The leading bank in fully utilizing financial reports in scoring the credit risk
• A well-functioning IT system to calculate the credit scores
• Lacking a logically specific estimate of the bank’s capability to cope with problem loans.
• The non-financial criteria for Corporate
These criteria are designed to reflect every aspect of a company's financial performance There is no fixed weighted average for each criterion; Vietcombank determines the weights of the relevant ratios based on the borrower's business nature.
Non-financial information used to compute the debtor’s credit scores is qualitative analysis of
Management quality evaluates how effectively the company performs under its top managers, reflecting leadership and execution It also encompasses the strength of the internal control environment and the feasibility of future plans guided by the Board of Directors, collectively shaping sustainable performance.
Credibility in transactional relations can be assessed by analyzing a firm's historical loan repayment performance, transaction frequency, and the volume of deposits in its Vietcombank account These indicators—loan repayment history, the number and value of transactions, and deposit activity—help banks form a clearer picture of the firm's creditworthiness and reliability By integrating these data points, lenders gain insight into cash-flow stability and financial discipline, supporting more informed lending and partnership decisions with Vietcombank.
External environment plays a significant role in credit evaluation Borrowers operating in a booming industry or with a well-known regional reputation may achieve higher credit scores due to perceived stability and growth potential Lenders also consider the competitive landscape, including the borrower’s position among rivals, since a stronger market stance can reflect resilience and long-term profitability.
3.4.4 VCB’s credit risk management SWOT analysis
• A fair model of quantitative and qualitative analysis
• The convenience to compare the credit risk of customers expert’s judgement
• Collateral assets are not considered in Individual Rating model
• Difficulty in scoring company working in many sectors
• The closer step to the international credit rating benchmark with the support from SBV
• Frauds from financial reports of corporate customers leads to the incorrect credit scores
Solutions to current credit risk issues
3.5.1 Comprehensive individual credit risk management approach
Since collateral assets are not assumed automatically in assessing a borrower's creditworthiness, the author recommends pairing the collateral asset rating with the borrower's credit rating to determine the final credit decision The approach uses three-group criteria to score collateral assets on a 300-point scale, and the resulting total score is categorized into credit letters A, B, or C A decision matrix then combines the letter for the credit rating with the collateral asset rating to guide the loan approval decision.
Table 10: Comprehensive individual credit risk management approach
Scores Collateral rating letter Analysis of collateral asset
Table 11: Categorization of collateral scoring
Credit quality is determined by the combination of the borrower's credit rating and the collateral rating, and this quality guides a bank's loan approvals according to its risk appetite and the prevailing economic conditions In a booming economy, banks may seize market opportunities by lending to borrowers with credit quality in the Excellent, Good, and even Average ranges During a recession, Vietcombank would likely tighten growth and emphasize healthy profits, restricting new lending to individual borrowers who demonstrate Excellent or Good creditworthiness.
3.5.2 Corporate credit risk management approach
One of the most significant issues in Vietcombank’s Corporate Credit Risk Management Model, as identified by the author, is the insufficient link between the final corporate credit rating and the bank’s capital provisioning for default losses This weak connection hinders a clear translation of credit risk assessments into adequate capital buffers to cover potential defaults The intended linkage aims to prevent Vietcombank from being unable to fulfill its obligations to depositors and other creditors in the face of severe credit risk Specifically, in scenarios of a single borrower default or widespread defaults, the critical question becomes whether the bank can honor depositor claims and other financial commitments with its available capital under distress.
In recent years, the SBV has aligned with international progress in credit risk management guided by the Basel Committee since 2010 It issued Circular 24/TT-GSNH5 (2014), mandating commercial banks to implement Basel II capital adequacy standards Vietcombank has been the pioneering bank, restructuring its operations to meet international standards and setting a benchmark for others to follow Yet the bank still faces challenges in clearly reconciling Basel II capital adequacy requirements with the actual level of credit risk within its corporate credit risk management framework.
It is suggested that VCB’s internal rating model be aligned with international regulation such as Basel Specifically, to safeguard the bank in the event of default, the credit risk management process will be structured to assess and monitor credit risk within a Basel‑compliant framework, integrating rigorous risk controls, accurate default provisioning, and proactive mitigation measures.
Vietcombank uses a rating model to assess corporate borrowers' creditworthiness and loan risk, then classifies each loan into one of five groups Based on the assigned group, the bank calculates allowances for impaired loans using the corresponding allowance rate This loan classification and allowance computation is carried out in strict accordance with the regulatory framework established by the State Bank of Vietnam (SBV).
Vietcombank assigns the risk weight of each loan according to Circular 13/TT-NHNN (2010), using the loan’s collateral asset to determine risk-weighted assets (RWA) and the corresponding capital charge With a 9% minimum CAR mandated for all commercial banks, the bank can readily compute the minimum capital requirement against its loans to sustain operations in the market.
Vietcombank’s entire loan-issuance process and the practice of maintaining a minimum 9% CAR are closely overseen by the company’s internal audit team to prevent major unexpected events The State Bank of Vietnam (SBV) acts as the supervisory authority, continuously examining Vietcombank’s compliance with credit policies (Decision 457/2005/QĐ-NHNN 2005), credit rating, provisions for bad debts, and loan classification (Decision 493/2005/QĐ-NHNN 2005) These supervisory activities assess the effectiveness of the internal audit function and may influence bank management to sustain the required CAR.
Vietcombank should operate under market discipline and transparency to ensure a level playing field in Vietnam’s banking market Public disclosure of capital adequacy related to credit risk, the bank’s risk profile, and its credit risk assessments provides a valuable data resource for the State Bank of Vietnam (SBV) to update, refine, and strengthen its risk regulations This published data helps enhance the quality of the banking sector and supports the market's competitiveness in regional and international markets.
To maintain the required 9% CAR for a 1 billion VND loan, Vietcombank must hold available capital above 180 million VND to absorb potential credit risk from Company A When the bank’s internal auditing team reviews all credit aspects of Company A to clarify the 9% CAR, SBV can, at any time, examine the bank’s compliant procedures to ensure no intervention is needed for capital adequacy Under Pillar 3, Vietcombank is obliged to disclose at year-end: (i) its capital structure—where the capital comes from and how many times the bank has raised capital to meet the 9% CAR; (ii) credit risk profiles—the average credit risk for each industrial sector in which its corporate customers operate; and (iii) assessment of credit risk—how the internal rating model works and any changes to the model in response to SBV’s updated regulatory framework The credit rating model operates in tandem with the three pillars of Basel II to produce the most reliable information, since each link in the chain significantly affects the others.
To effectively implement the proposed corporate credit risk management model, Vietcombank must balance credit growth with capital adequacy to support borrower risk As the bank expands operations, the rise in assets and risk-weighted assets (RWA) makes it essential to maintain a minimum 9% capital adequacy ratio (CAR) through an efficient mix of capital raising and capital deployment While capital raises can improve the CAR, there must be a solid business plan to utilize the funds to generate earnings; otherwise shareholders may pressure for timely dividend payments The bank should also invest in staff training and align strategy communication to enhance the quality of credit risk controls and the transparency of internal auditing Lastly, developing a sophisticated information system is vital to actively manage the customer database and enable robust information disclosure.
CONCLUSION AND RECOMMENDATIONS
Providing credit is a fundamental function of commercial banks that circulates capital in the macro-economic system, funds the operating activities of firms, and improves households’ living standards in the micro-economic sphere Credit activity also underpins bank profitability, as loans constitute a significant share of assets and generate substantial income Consequently, credit risk is a central concern for managers because customer defaults can trigger severe, unrecoverable losses and damage the bank’s reputation To strengthen loan quality, banks should implement an effective credit risk management model that actively prevents losses from credit activity Although the benefits of a robust risk management framework are clear, many banks struggle to find a model that fits their organizational structure and the markets in which they operate.
Since Vietnam opened its economy to the world, the banking sector has expanded rapidly, with new banks forming and broadening their geographic reach to serve a diverse range of customers This growth in credit has elevated credit risk, manifested in rising bad debt that edged above 3% in recent years The State Bank of Vietnam (SBV) has shown strong concern and implemented measures to bring bad debt down to below 3% by 2015 To facilitate risk reduction, the SBV established the Vietnam Asset Management Company (VAMC) to purchase bad debts from commercial banks, helping them clean up their financial statements and access SBV funding Through SBV support, many banks have been able to overcome financial distress.
Nevertheless, in the long run, the banks are in need of having better credit policies, building a functioning credit risk management model to minimize the impact of credit risks.
Vietcombank remains a competitive player in Vietnam’s banking sector, leveraging the country’s overall economic development to maintain a solid financial position and sustainable growth Yet, compared with key competitors, Vietcombank exhibits higher credit risk relative to its loan portfolio While credit growth outpaces peers, the bad debt burden—especially the non-performing loan (NPL) ratio—is considerably higher The aim of this research is to address two linked questions: the relationship between rapid credit growth and a high level of bad debt, and the feasibility of developing a practical model to effectively control credit risk at Vietcombank.
An examination of Vietcombank’s current credit activities and bad-debt management shows that rapid credit growth paired with a high bad-debt ratio signals weaknesses in credit quality The staff dimension matters as well: pressure to meet loan quotas can compromise underwriting when training is insufficient to ensure understanding and application of Vietcombank’s credit policies and culture Top management bears responsibility, since looser oversight can create loopholes in credit risk controls Together, these factors suggest it may be time for Vietcombank to reform its credit risk management framework to lower bad debt while maintaining sustainable credit growth.
This article examines how Vietcombank’s current credit risk management framework operates, focusing on its internal credit rating model that is split into two sub-models for individuals and corporate entities Both models rely on a combination of quantitative data and qualitative judgments to score borrowers and produce a credit rating letter that reflects their creditworthiness The analysis highlights key weaknesses: in the Individual model, collateral assets are not explicitly reflected, while in the Corporate model the link between credit risk and the bank’s capital adequacy is blurred, potentially affecting the bank’s ability to serve other customers if a particular company defaults These weaknesses are the main drivers behind the author’s recommendation for a more comprehensive credit risk management approach.
For individual credit risk management, collateral is rated relative to the loan value, and together with the credit rating, a matrix combines these assessments to decide whether to grant the loan In corporate credit risk management, collateral is still emphasized but from a different angle To move toward international standards, the SBV has encouraged Vietcombank to implement Basel II through a minimum capital requirement expressed as the capital adequacy ratio (CAR) to guard against credit risk This CAR represents the capital charge the bank must hold for loans, with collateral-based credit risk weighted by loan value, ensuring the bank has enough capital to absorb losses and protect existing customers The SBV sets a minimum CAR of 9% The proposed corporate credit risk management model is an integration of Basel II concepts with collateral-based risk assessment.
The corporate internal credit rating model, integrated with Basel II supervisory and regulatory standards, provides a rigorous evaluation of corporate borrowers In Vietnam, adjustments to the Basel II framework tailor the approach to the local banking landscape, enhancing Vietcombank’s protection by leveraging collateral assets in borrower defaults and reinforcing SBV's role in supervising and maintaining a competitive, orderly market Strong corporate credit risk management ensures that all credit activities and policies are transparent and fully compliant with SBV regulations.
To succeed, Vietcombank must align its capital adequacy strategy with a prudent combination of capital raising and efficient deployment to sustain a 9% CAR without overburdening shareholders with dividends It should also clearly communicate the credit risk management framework and related policies to employees to reduce fraud arising from policy misunderstanding Additionally, a substantial investment in information systems is essential to build a granular customer base that underpins a stronger credit-rating model By delivering these elements within a robust risk-management approach, Vietcombank can steadily pursue its goal of becoming a leading bank not only nationally but also regionally.
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Number of branches State-owned Commercial banks (SOCBs)
Vietnam Bank for Agriculture and Rural
Vietnam Joint Stock Commercial Bank of
Industry and Trade (Vietinbank) Listed 37,234 149
Joint Stock Commercial Bank for
Investment and Development of Vietnam
Joint Stock Commercial Bank for Foreign
Trade of Vietnam (VCB) Listed 26,650 500
Joint Stock Commercial Banks (JSCBs)
1 Asia Commercial Joint Stock Bank - ACB Listed 9,377 81
An Binh Commercial Joint Stock Bank -
3 Bao Viet Joint Stock commercial Bank Unlisted 3,150 12
Viet Capital Commercial Joint Stock Bank -
5 BAC A Commercial Joint Stock Bank - Bac Unlisted 5,000 22
Appendix: List of commercial banks in Vietnam categorized by ownership
LienViet Commercial Joint Stock Bank -
7 Public Vietnam Bank - PVcomBank Unlisted 9,000 33
DONG A Commercial Joint Stock Bank -
Southeast Asia Commercial Joint Stock
The Maritime Commercial Joint Stock Bank
Kien Long Commercial Joint Stock Bank -
Viet Nam Technological and Commercial
Joint Stock Bank - TECHCOMBANK Listed 8,878 62
Nam A Commercial Joint Stock Bank -
Orient Commercial Joint Stock Bank -
Military Commercial Joint Stock Bank -
National Citizen bank - NCB Unlisted 3,010 20
Sai Gon Commercial Joint Stock Bank -
9 Saigon Bank for Industry & Trade - SGB Unlisted 3,080 33
Saigon-Hanoi Commercial Joint Stock Bank
Saigon Thuong Tin Commercial Joint Stock
TienPhong Commercial Joint Stock Bank -
Viet A Commercial Joint Stock Bank -
Vietnam Commercial Joint Stock Bank for
Viet Nam Thuong Tin Commercial Joint
Petrolimex Group Commercial Joint Stock
Viet nam Export Import Commercial Joint
Ho Chi Minh city Development Joint Stock
Vietnam Joint Stock Commercial Bank of