UPDATE: It seems that an a possible update has made it so "Loan Down" is required for the achievement. Being the case it is VERY important that you concentrate on getting it first, as it is missable
This achievement seems to be more of a 'unlocked all other achievements' type deal rather than an in-game tracker.
I did all of my 100% mode runs on easy, then got all the misc achievements. Finally I beat the game on Normal, then Hard. This is when the achievement unlocked for me.
You can check the achievement progress periodicallly through the achievement tab to see which achievements are counting towards the progression.