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.

AMCO believes that the simplification performed on the templates and the relationship between the different templates create a framework which could be more easily achieved by market players

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

AMCO believes that the deletion of the above fields is not detrimental to the efficiency of the templates.

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.

AMCO believe that the proposed dataset captures the relevant information on counterparty. The only enrichment which should be considered is a minimum dataset of information related to the exposure and performance of the counterparty with other lenders. Such information would be available from the local Credit Bureaux/Credit Register. Furthermore, for the counterparties under legal procedure AMCO believes that a data field related to the eventual “cash in court amount” should be included for the pro rata amount related to the credit in the portfolio.

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.

With regards to the proposed amendments of the counterparty template, AMCO agrees on the elimination of the proposed data fields. With respect to the Critical reclassified as non-critical AMCO is of the opinion that field “Description of legal procedure type” should remain critical. As for the fields “Non-critical reclassified as critical” AMCO would not classify critical the “Annual revenue”, “Annual ebit” and “Eligibility for deposit to offset” in so far it is believed these are information neither always updated nor simple to collect. Therefore, as also highlighted later in the response, in these cases the no-data option could be used in case of non-critical fields which are difficult to fill.

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)?

While the aim of the information is understood, AMCO believes that the information at origination are often not available and in any case of marginal use.

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

This information should be required for those counterparties who have the obligation to produce the financial statement (i.e. Corporates going concern)

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

This information should be required for those counterparties who have the obligation to produce the financial statement (i.e. Corporates going concern)

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

AMCO agrees with the proposed structure.

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.

AMCO agrees on the need of contractual agreement information as far as the exposures are below 90 day
past due

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

AMCO agrees with the approach and usefulness of forbearance information in NPL transactions.

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.

AMCO is of the opinion that the set on information required captures the relevant needed information. AMCO believe that the Product Type, should be kept in order to be able to describe the type of exposure when this is not covered by the Specialised Product field

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.

AMCO agrees with the proposed structure. No additional data should be excluded from the template.

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

AMCO agrees with the approach to the data fields related to lease in so far it is understood that all detailed information on the collateral are addressed in the specified table that are fundamental for a proper valuation of this specific category

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.

AMCO is of the opinion that the fields “Sale agreed date”, “first auction date”, “Court auction reserve” and “price for first auction” should be maintained even though not critical. Furthermore AMCO is of the opinion to maintain critical the following fields “enforcement description”, “geographic region of property”, “land area (M2)”, “latest estimated rental value”, “current market status”, “on market price” and “collateral repossessed date”

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.

AMCO is of the opinion that no further data fields should be excluded from the template

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

AMCO would welcome a field describing the type of guarantor i.e Central Government, Local Authority, Corporate, Financial Institution, Private Individuals, Other. For the financial collateral AMCO would suggest to include a field with the type of security i.e Cash, Government Bonds, ABS, Corporate Bonds (listed or not listed), equities etc.

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

AMCO agrees with the proposed approach

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.

AMCO is of the opinion to maintain critical the data field “Cash recoveries”

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

AMCO believes that the data dictionary and fields descriptions have been structured in way that allows participant to have a tool for immediate consultation

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.

Comments on critical vs non critical provided earlier in each section

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

AMCO is of the opinion that the fields “Annual Income” (index 1,09) and “Income Self-Certified” (index 1,11) should be flagged 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.

AMCO agrees with excluding no data options on fields classified as critical. No data options should be provided for non critical fields.

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.

AMCO does not agree with limiting to the critical fields as a measure to achieve proportionality. The type of portfolio instead of the size should drive complexity and this is already reflected in the template. Rather it could be considered that for very small portfolio and non-critical fields the no data option could be allowed.

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?

AMCO does not believe in a proportionality based on monetary terms

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?

AMCO does not believe in the proportionality principle

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.

AMCO believes that the asset class split is appropriate.

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.

AMCO believes that the way the templates are set up will facilitate also single name transactions

Name of the organization

Asset Management Company S.p.A