Response to discussion on the review of the NPL transaction data templates
Go back
Counterparty deceased; Insolvency Practitioner Appointed; Date of Appointment; Number of Current Judgements; Date of External Demand Issuance
They can be classified as non-critical.
This is because for back-book securitisations, i.e. securitisations of underlying exposures with a high seasoning, or re-securitisations, i.e. for transactions where the originator is an SPV, credit score data availability may be scares and not available.
Balance at Default, Cash Recoveries
On our view the following fields should be classified as non-critical:
Counterparty deceased; Insolvency Practitioner Appointed; Date of Appointment; Number of Current Judgements; Date of External Demand Issuance; Fixed Assets; Current Assets; Cash and Cash Equivalents; Total Assets; Total Liabilities; Total Debt; Annual Revenue; Annual EBIT; Loan Purpose
1. Do you agree with the proposed data structure and the relationship between templates? If not, please provide explanation.
Yes, it has a comprehensive structure.2. Do you agree with the deletion of data categories ‘NPL portfolio’ and ‘Swap’? If not, please provide explanation.
Yes.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.
The due diligence process would improve if the following data fields will not be excluded:Counterparty deceased; Insolvency Practitioner Appointed; Date of Appointment; Number of Current Judgements; Date of External Demand Issuance
They can be classified as non-critical.
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.
No.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)?
We agree that credit score-related data fields should be included, but they should be non-critical.This is because for back-book securitisations, i.e. securitisations of underlying exposures with a high seasoning, or re-securitisations, i.e. for transactions where the originator is an SPV, credit score data availability may be scares and not available.
6. Do you agree that data fields on corporate’s latest available financial statement amounts should be included in the template?
Yes, it will be helpful for the due diligence process, but it may not be available for back-book securitisations and re-securitisations. Hence our view is to classify those data fields as non-critical.7. Do you agree that data fields related to corporate counterparties’ assets and liabilities, market capitalisation should be included in the template?
Yes, it will be helpful for the due diligence process, but it may not be available for back-book securitisations and re-securitisations. Hence our view is to classify those data fields as non-critical.8. Do you agree with the proposed Template 2 of Annex I? If not, please provide explanation to your answer.
Yes.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.
Partially agree. The discriminant of >90 days past-due may not be sufficient, although it can be regarded as a good starting valuation point. A further discriminant may be the presence of an active loan repayment plan. Certain data, mainly related to the interest rate structure or amortisation plan may lose significance when there are no active repayment plans.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, but they should be classified as non-critical.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.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.
No.13. Do you agree with the data fields related to lease? Please provide data field-specific explanation to your answer.
Yes.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.
Yes.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.
No.16. Do you agree with the data fields on the characteristics of non-property collateral? Please provide data field-specific explanation to your answer.
Yes.17. Do you agree with the data fields related to the enforcement of collateral? Please provide data field-specific explanation to your answer.
Yes.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.
Yes.19. Do you agree with description of data fields presented in data dictionary?
Yes.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.
On our view the following fields should be classified as critical:Balance at Default, Cash Recoveries
On our view the following fields should be classified as non-critical:
Counterparty deceased; Insolvency Practitioner Appointed; Date of Appointment; Number of Current Judgements; Date of External Demand Issuance; Fixed Assets; Current Assets; Cash and Cash Equivalents; Total Assets; Total Liabilities; Total Debt; Annual Revenue; Annual EBIT; Loan Purpose