Cayman's financial regulator holds no record of how many borrowers are behind on personal loans, and says that assessing whether individual households can repay what they owe is a matter for the banks.

The Cayman Islands Monetary Authority (CIMA), which licenses and supervises the islands' banks, said in a 16 September 2026 response to a Freedom of Information request from The Caymanian Journal (TCJ) that it does not hold figures for the number of household borrowers, loans in arrears, non-performing personal loans or the average unsecured debt per borrower. James Elliott, CIMA's Information Manager, wrote: "Unfortunately, the Authority does not hold the other categories of records requested within Item 3, and, to our knowledge, neither does any other public authority."

The Economics and Statistics Office (ESO), the Government's statistics agency, told TCJ on 16 October 2026 that it holds no such data either. Its Director, Adolphus Laidlow, said questions on debt had been left out of the ESO's own Household Budget Survey: "This data was not on our surveys questionnaire as previously households generally refused to submit those data citing 'the sensitive and personal nature of the question'." Asked whether indebtedness statistics are on the ESO's work programme, he said no, adding that the subject "falls under the ambit of CIMA as the regulator in the administering Cayman Islands Banking Act". Christina Trumbach, Communications Manager at the Ministry of Finance and Economic Development, which the ESO sits within, said: "The Ministry of Finance & Economic Development is not aware of any public authority that records or holds data on personal and/or household debt."

Invited to respond to the ESO's statements, CIMA said in a written reply on 29 October that it monitors household indebtedness through aggregate banking data, but that producing economy-wide debt-to-income or debt-service ratios "requires household income statistics derived from national accounts, the compilation of which falls outside CIMA's statutory mandate". It added: "Borrower-level indebtedness and repayment capacity are assessed by individual banks as part of their credit underwriting and risk management processes."

The same FOI response released a quarterly record of credit card activity that CIMA said it has kept since 2018, which the Authority later revised after TCJ queried two of its entries. On the revised figures, transactions totalled US$785.5 million in 2025, the highest annual figure in the series and 11.9% more than the US$701.9 million recorded in 2024, according to TCJ's totals of the quarterly figures.

Why the gap matters

The missing figures are the ones that would show whether higher borrowing costs are hurting households. CIMA's own Financial Stability Report says non-mortgage credit is "typically more sensitive to changes in interest rates and household income", and that a continued rise could make household balance sheets "more vulnerable to income shocks, higher debt servicing costs, or weaker labour market conditions". Since 2021 the prime lending rate on Cayman-dollar loans has more than doubled, from 3.25% to an average of 8.17% in 2024, on the ESO's figures.

What CIMA measures instead is the end of the process: the foreclosure rate and the share of bank loans classed as non-performing. Neither shows how many households are falling behind on a car loan, a credit card or a consolidation loan before a bank acts, or how much unsecured debt the typical borrower carries. The ESO says households would not answer its survey and that the subject sits with the regulator. CIMA says it does not collect borrower-level data and that the banks assess each borrower's capacity to repay. The result is that no public body can say how many Cayman households are in difficulty with their debts, or whether Caymanians carry more unsecured debt than other residents, since CIMA also holds no breakdown between Caymanian and non-Caymanian borrowers.

What the regulator holds and what it does not

The Freedom of Information Act (2021 Revision) gives anyone the right to ask a public authority for the records it holds. TCJ asked CIMA by email on 17 August 2026 for its records from 2015 onwards of household lending, unsecured consumer debt by category, loans in arrears, write-offs, the split between Caymanian and non-Caymanian borrowers, and any calculation of average unsecured debt per borrower or household. Unsecured debt is borrowing with no asset, such as a house or car, pledged against it.

Mr Elliott granted the request in full. For total household lending, loan definitions and the split between resident and non-resident borrowers, he directed TCJ to figures already published on the CIMA and ESO websites and to the annual reports of the CICSA Co-operative Credit Union, the civil service credit union, citing section 9(d) of the Act, under which information already in the public domain need not be disclosed. Section 9 provides that a public authority is not required to comply with a request where "the information requested is already in the public domain".

On the remaining items, CIMA said it does not hold the records. That covers the number of borrowers or accounts, arrears and non-performing loans by lending category, write-offs and impairment provisions, any breakdown between Caymanian and non-Caymanian borrowers, and any average or median figure for unsecured debt per borrower, adult or household.

Statistics office points to the regulator

TCJ put the same questions to the Ministry on 15 October 2026. The Ministry passed them to the ESO, and Mr Laidlow replied on 16 October, first pointing to the office's published totals for credit to households and then, to further questions the same day, setting out what the ESO does not hold.

The Household Budget Survey is the ESO's periodic survey of what Cayman households earn and spend. Mr Laidlow said: "The ESO is not in possession of any data that can indicate the number of households or individual with unsecured debt and or loans in arrears or average or median debt."

Household indebtedness statistics, such as debt-to-income or debt-service ratios, are not on the ESO's work programme now or in coming years, he said, because the subject "falls under the ambit of CIMA as the regulator in the administering Cayman Islands Banking Act". The Ministry's Communications Manager, Christina Trumbach, gave the Ministry's own answer on 16 October: it knows of no public authority that records or holds personal or household debt data. Asked for comment on the growth in credit card transactions and non-mortgage borrowing, the Ministry said it had none, and noted that CIMA falls under the Ministry of Financial Services and Commerce rather than the Ministry of Finance.

The regulator's answer

TCJ invited CIMA's response to the ESO's statements on 16 October. Yvette Cacho, Public Relations Executive in CIMA's Communications Division, acknowledged the request on 17 October, asked for a few additional days to coordinate internally, and sent the Authority's written answers on 29 October.

On whether producing household indebtedness statistics falls to the regulator, CIMA said: "The Authority monitors household indebtedness through aggregate banking data, including outstanding household credit and non-performing loans. However, producing economy-wide debt-to-income and debt-service ratios requires household income statistics derived from national accounts, the compilation of which falls outside CIMA's statutory mandate, alongside comprehensive aggregate debt repayment data." The national accounts, which measure the economy's output and income, are compiled by the ESO.

Mr Laidlow had said that the ESO's "Miscellaneous" line for household credit is drawn from CIMA's Domestic Banking Activity survey, that the line "is not detailed on the form" and that he was "unsure if credit cards are included". CIMA's answer was that the survey "currently collects the number and value of credit card transactions in its Payments and Settlements section", and that outstanding card balances "are reported under 'Loans: Household - Consumer Loans / Overdrafts' in the item 'Miscellaneous: Other'". It added: "Information on outstanding credit card balances alone cannot be separately distinguished from other items reported in that category."

Asked about the growth in card transactions in the light of its Financial Stability Report's call for continued monitoring of non-mortgage borrowing, CIMA said that borrowing "increased between 2020 and 2026" but that "the rise was only slightly above the average inflation rate for the same period". It continued: "Hence, while CIMA continuously monitors aggregate credit growth, including household non-mortgage loan categories, our indicators do not currently point to an excessive growth trend. This observation aligns with the overall trend tracked by the credit-to-GDP indicator, supporting our assessment that household credit exposure risk remains low, as stated in the report. Nevertheless, CIMA will continue to monitor further developments closely."

TCJ also sought comment on 16 October from the Ministry of Financial Services and Commerce, the Cayman Islands Bankers' Association and the CICSA Co-operative Credit Union. None had replied by 7 November.

Record card spending

The credit card table runs from the second quarter of 2018 to the first quarter of 2026 and records, for each quarter, the total value of transactions, the number of transactions and the number of cards. CIMA issued a revised version of it on 19 October after TCJ queried two entries, saying "various updates have been made to the table" and that the remaining figures were unchanged; the figures in this report are taken from the revised table. CIMA said that only Category A retail banks report the card data, and that all amounts are in U.S. dollars.

The 2025 total is 22.2% above the US$642.9 million recorded in 2019, the last full year before the pandemic. The table does not show the balances left unpaid on those cards, and CIMA has confirmed that it holds no separate figure for credit card debt outstanding.

The series shows a pandemic dip and a sharp recovery. Transactions fell from US$642.9 million in 2019 to US$520.1 million in 2020, a drop of 19.1%, and to US$481.7 million in 2021. That is the lowest annual total in the seven full years recorded. They then rose by 18.9% to US$572.7 million in 2022, by 14.1% to US$653.3 million in 2023 and by 7.4% to US$701.9 million in 2024, before the 11.9% rise in 2025. The percentages are TCJ's, calculated from CIMA's revised quarterly figures.

What the published figures show

The ESO table CIMA pointed to, drawn from CIMA data, puts domestic banks' credit to households at CI$2,551.3 million at the end of 2024, up from CI$1,882.6 million at the end of 2016, a rise of 35.5% calculated by TCJ. Of the 2024 total, CI$2,248.8 million was lending on domestic property, CI$70.4 million was motor vehicle lending, CI$2.5 million was education and technology lending, and CI$229.7 million was classed as miscellaneous, which the ESO defines as consolidated debt, insurance, medical and travel borrowing.

The table has no separate line for credit cards or personal loans. Mr Laidlow said the figures come from CIMA's Domestic Banking Activity survey of the banks, and added: "Above is the DBA survey that collects data from the banks, miscellaneous is not detailed on the form and I am unsure if credit cards are included." CIMA has since confirmed that card balances sit within that miscellaneous category and cannot be separated from it.

The ESO's Annual Economic Report 2024 says household credit rose 4.5% during 2024, with motor vehicle loans up 15.4% and miscellaneous lending up 7.5%.

Nine years of household credit

The ESO's table runs from 2016 to 2024 and shows credit to households at domestic banks rising in every year but one. It stood at CI$1,882.6 million in 2016, CI$1,992.5 million in 2017, CI$2,063.1 million in 2018 and CI$2,068.8 million in 2019. It reached CI$2,139.1 million in 2020, CI$2,293.1 million in 2021 and CI$2,448.4 million in 2022, dipped to CI$2,442.0 million in 2023 and rose to CI$2,551.3 million in 2024.

Lending that is not secured on property came to CI$302.6 million in 2024, by TCJ's addition of the three non-property lines. Motor vehicle lending rose from CI$45.8 million in 2016 to CI$70.4 million in 2024. Education and technology lending fell from CI$5.9 million to CI$2.5 million over the same period. Miscellaneous lending, the line that the ESO says covers consolidated debt, insurance, medical and travel borrowing, was CI$230.0 million in 2016 and CI$229.7 million in 2024, having fallen as low as CI$188.4 million in 2020.

Borrowing costs

The ESO's interest rate tables, also sourced from CIMA, show how much dearer that borrowing has become. The average prime lending rate for Cayman-dollar loans was 3.25% in both 2020 and 2021. It averaged 5.37% in 2022, 8.06% in 2023 and 8.17% in 2024. The weighted average rate charged on all Cayman-dollar loans, which includes mortgages, personal loans and business lending, followed the same path: 5.88% in 2021, 6.94% in 2022 and 9.01% in 2023, with the four quarters of 2024 ranging from 9.09% to 9.76%.

CIMA rates household credit risk as low

In its Financial Stability Report 2024-2025, published on its website after the FOI response was issued, CIMA wrote: "Household credit remained a low financial stability risk in 2025, although developments in non-mortgage borrowing and the upward movement in the household credit-to-GDP gap warrant continued monitoring." Non-performing loans stood at 1.5% of gross loans at the Category A retail banks that serve the local market, the report said.

On the borrowing that is not secured on homes, the report said: "At the same time, non-mortgage borrowing increased after a period of relative stability, driven by motor vehicle loans and other loans and overdrafts. While still a smaller share of total exposure, these forms of credit are typically more sensitive to changes in interest rates and household income. A continued increase in these segments could therefore make household balance sheets more vulnerable to income shocks, higher debt servicing costs, or weaker labour market conditions. However, the foreclosure rate remained below 1% in 2025, broadly unchanged from 2024, suggesting that repayment stress has remained contained."

CIMA's early warning measure

The Financial Stability Report tracks household borrowing against the size of the economy. On that measure it wrote: "The household credit-to-GDP gap widened during 2025 but remained below the lower early warning threshold, suggesting that cyclical household credit vulnerabilities stayed contained." The gap turned positive during the year and reached about 1.5% in December 2025, the report said, below the 2% threshold at which CIMA would read a clear signal of excessive build-up.

The report also set out what it will watch. It said: "From a financial stability perspective, monitoring should focus on whether the increase in the gap persists over several quarters and whether it is accompanied by faster growth in non-mortgage credit, a higher foreclosure rate, or broader lending-rate pressures that may affect household debt servicing capacity."

On the banks themselves, the report said the capital adequacy ratio stood at 30.9% for Category A retail banks and that non-performing loans were 0.5% of gross loans across all banks, against 1.5% at the retail banks. It added: "NPL levels remain low and broadly consistent with recent historical norms. Nevertheless, they continue to be proactively managed, as adverse macro-financial developments and jurisdiction-specific shocks could lead to a deterioration in credit quality."

CIMA said in its FOI response that the 2025 edition of its Banking Statistical Digest would be released by the end of September 2026. The 2024 edition was the latest shown on the Authority's digest page on 7 November 2026.