In my opinion, so long as the borrower does not dispute that he owes money to the bank, it may not be termed as “fraud”. I believe there is a good enough reason to revisit the definition of “fraud” in the banking context. Fixing of staff accountability 21. Another area demanding urgent attention of banks is fixing of staff accountability.
However, it was clear to all that there was a 1/3  BIS central bankers' speeches  price to pay for this, in terms of tighter credit: at least temporarily, during the transition to the new standards. An overall prudential stance measure would capture this policy tightening; a narrower perspective misses it.