Response to discussion on the review of the NPL transaction data templates

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1. Do you agree with the proposed data structure and the relationship between templates? If not, please provide explanation.

Please refer to the response of the Associazione Bancaria Italiana (ABI) for extensive comments.

2. Do you agree with the deletion of data categories ‘NPL portfolio’ and ‘Swap’? If not, please provide explanation.

Yes, we agree.

3. Do you think the suggested list of data fields capture all the relevant information on the counterparty needed for NPL valuation and financial due diligence? If not, please indicate which other data fields should be included and provide explanation for this.

Please refer to the ABI's response.

4. Do you think any specific data fields should be excluded from the template? If yes, please specify the data fields and give explanation to your answer.

Please see the attached file and the ABI's response for reference. We consider that some data fields do not reflect information exchanged by market players.

5. Do you agree that data fields on current external and internal credit scores and current external and internal credit scores at origination should be included in the template (for both private individual and corporate counterparties)?

No, they should be excluded.

6. Do you agree that data fields on corporate’s latest available financial statement amounts should be included in the template?

No, we believe that such data should be retrieved by investors.

7. Do you agree that data fields related to corporate counterparties’ assets and liabilities, market capitalisation should be included in the template?

No, we believe that such data should be retrieved by investors.

8. Do you agree with the proposed Template 2 of Annex I? If not, please provide explanation to your answer.

Please refer to the ABI's response.

9. Do you agree with the inclusion of the data fields related to interest rates and other information as per contractual agreement for the valuation and financial due diligence of NPLs, especially when they are not more than 90 days past due? Please provide data field-specific explanation to your answer.

We consider that only part of the data on interest rates can be useful for buyers in case of UTPs. We would keep such data as non-critical.

10. Do you agree with the inclusion of the data fields related to forbearance measures for the valuation and financial due diligence of NPLs?

Yes, we agree, as long as they are non-critical fields.

11. Do you think the suggested list of data fields capture all relevant information on financial instrument needed for NPL valuation and financial due diligence? If not, please indicate which other data fields should be included and provide explanation for this.

Yes, we do, please see the ABI's response for fields exclusions.

12. Do you think any specific data fields should be excluded from the template? If yes, please specify the data fields and give explanation to your answer.

Please see the ABI's response. Exclusions refer to information which are not usually exchanged by market players.

13. Do you agree with the data fields related to lease? Please provide data field-specific explanation to your answer.

Please see the ABI's response. Exclusions refer to information which are not usually exchanged by market players.

14. Do you think the suggested list of data fields capture all relevant information on collateral needed for NPL valuation and financial due diligence? If not, please indicate which other data fields should be included and provide explanation for this.

Please see the ABI's response for reference. Differently from what indicated in point 42 of the Discussion Paper, for Italy, mortgage amount and mortgage registration date are crucial information.

15. Do you think any specific data fields should be excluded from the template? If yes, please specify the data fields and give explanation to your answer.

Please see the ABI's response for a list of exclusions. Exclusions refer to information which are not usually exchanged by market players.

16. Do you agree with the data fields on the characteristics of non-property collateral? Please provide data field-specific explanation to your answer.

Please see the ABI’s response. Exclusions refer to information which are not usually exchanged by market players.

17. Do you agree with the data fields related to the enforcement of collateral? Please provide data field-specific explanation to your answer.

Please see the ABI's response. Exclusions refer to information which are not usually exchanged by market players.

18. Do you agree with the proposed Template 5 of Annex I for NPL valuation and financial due diligence? Please provide data field-specific explanation to your answer.

Please see the ABI's response for reference.

19. Do you agree with description of data fields presented in data dictionary?

Yes, we agree.

20. Do you agree with criticality (and non-criticality) of data fields presented in data dictionary? If not, please provide suggestions and explanations related to specific data fields.

No, please see the ABI's response and the attached file for reference.

21. Do you agree with confidentiality aspects of data fields? If not, please provide explanation.

Please refer to the ABI's response. We consider and treat under NDAs all information provided to investors as confidential.

22. Do you agree with excluding no data options for data fields? If not, please provide suggestions and explanations related to specific data fields.

No, we do not agree. We strongly advice to let the possibility of ‘no-data’ option open, please also refer to the ABI's response and the attached file.

23. Please provide your views on how proportionality considerations regarding the size of the exposures or portfolios being sold should be incorporated in the implementation of NPL data templates.

For extensive comments on proportionality, please refer to the ABI's response and the attached file.

24. Should there be a threshold (e.g. in monetary terms) for the application of the proportionality principle? If yes, then how should this be defined?

We consider that the threshold must be defined considering the average size of portfolio transactions in each local market. A threshold for a small country could be not applicable for a larger country.

25. Do you agree that the proposed approach takes into account, in an adequate way, the proportionality principle? If not, which additional elements should be considered?

For extensive comments on proportionality, please refer to the ABI's response and the attached file.

26. Please provide your views on the asset classes covered and whether any specific data fields, other than already foreseen, should be included in the templates for ensure full coverage of certain asset classes.

Please refer to the ABI's response.

27. In your view, is the structure and coverage of the templates adequate for both portfolio transactions and transactions where an individual exposure is traded? Please explain your answer.

Yes, we believe that, considering the exclusion fields proposed in the ABI's response, the structure is adequate for both portfolio transactions and single name. Please refer to the ABI response for extensive comments.

28. Please add any additional comments, remarks or observations you may wish to include in your feedback to the discussion paper.

For more extensive comments please refer to the attached file and to the ABI's response.

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Name of the organization

Intesa Sanpaolo Spa