Response to consultation on Implementing Technical Standards on NPL transaction data templates

Go back

1. Do the respondents agree that these draft ITS fits for the purpose of the underlying directive?

AMCO is of the opinion that this ITS fits the purpose of the directive.

2. What are the respondents’ views on the content of Template 1? Please provide any specific comment you may have on the data fields in the dedicated columns of the data glossary (Annex II to the draft ITS) added for your feedback.

Generally for all data fields it seems that for exposure below 25000 or greater must be considered the single exposure and not the sum of the exposures of the same counterparty. The latter would be the favourite. Furthermore field 1.02 i.e NACE code should be mandatory

8. What are the respondents’ views on the content of instructions?

AMCO believes that the content of the instructions are clear and complete

9. Do the respondents agree on the use of the ‘No data options’ as set out in the instructions?

AMCO agrees with the approach

10. What are respondents’ views on whether the proposed set of templates, data glossary and instructions are enough to achieve the data standardisation in the NPL transactions on secondary markets, or there may be a need for some further technical specifications or tools to support digital processing or efficient processing or use of technology (e.g., by means of the EBA Data Point Model or XBRL taxonomy)?

In the view of AMCO a process finalized to assess the data quality should be included

11. What are the respondents' views on the approach to the proportionality, including differentiating mandatory data fields around the threshold? Please provide any specific comment you may have on the data fields in the dedicated columns of the data glossary (Annex II to the draft ITS) added for your feedback.

AMCO agrees with the approach

12. Do the respondents agree with the proposed calibration of 25 000 euros threshold in line with AnaCredit Regulation? If not, what alternative threshold should be introduced, and why?

AMCO agrees with the threshold of 25000 carrying amount which should consider the total amount to the same customer and not the single esposure

13. What are the respondents' views on the operational procedures, confidentiality and data governance requirements set out in the draft ITS?

AMCO agrees with the approach

Upload here the Annex II with your comments to the date fields

Name of the organization

AMCO