Response to consultation on draft RTS concerning the assessment of appropriateness of risk weights and minimum LGD values
Go back
Macroeconomic key variables are troublesome in adjusting the loss expectations upwards or downwards because it would probably require an on-going evaluation by the regulator whether the reasoning for minimum LGD values still holds.
It is too early to consider climate related risks in the determination of loss expectation: data on these types of risks is still limited and international/national climate related policies are still being negotiated.
We are thus in an opinion that data and information should be gathered more, and comprehensive impact study made before there may be any conclusions how climate related risks should be taken into account and what is the right regulative response to it.
1. What is the respondents' view on the types of factors to be considered (cf Article 1) during the determination of the loss expectation for the appropriateness assessment of risk weights under the SA?
The uncertainty about loss expectation of immovable properties comes especially through the risk associated with the collateral. All factors related to the characteristics of the immovable property markets and the riskiness of the exposures need to be considered for exposures secured by mortgages on residential property or commercial immovable property. In addition, the location of the collateral and national laws, for example loans to housing companies which are addressed to the owners of the flats, affect the riskiness and loss expectation.Macroeconomic key variables are troublesome in adjusting the loss expectations upwards or downwards because it would probably require an on-going evaluation by the regulator whether the reasoning for minimum LGD values still holds.
2. What is the respondents’ view of the option of considering climate related risk in the determination of the loss expectation where the relevant authority was in a position to perform an appropriateness assessment to one or more parts of the territory of the Member State? What would for the respondent be the benefits and the challenges (costs) of such option?
It is unclear to which extent climate related risk would affect institution specific risk weights. Climate risks may affect the institution’s portfolios in complex ways, or they even may not have any effect to a particular portfolio at all.It is too early to consider climate related risks in the determination of loss expectation: data on these types of risks is still limited and international/national climate related policies are still being negotiated.
We are thus in an opinion that data and information should be gathered more, and comprehensive impact study made before there may be any conclusions how climate related risks should be taken into account and what is the right regulative response to it.