Question 1: What are the respondents’ views on the scope of application of the guidelines?
N/A
Question 2: What are the respondents view of the proposed threshold of 5 % NPL ratio?
N/A
Question 3: Do you see any significant obstacles to the implementation date and if so, what are they?
N/A
Question 4: Does section 4.3.2 capture all relevant options available for credit institutions to implement their NPE strategy?
N/A
Question 5: Do you see any significant obstacles to the operationalisation of the NPE strategy as described in chapter 5?
N/A
Question 6: Does the viability assessment of forbearance measures capture all relevant aspects?
N/A
Question 7: What are the respondents view on the proposed requirements for recognition of non-performing and performing/non-performing forborne exposures?
See attached letter.
Question 8: What are respondents view on the requirements on timeliness of impairments and write-offs of NPEs?
See attached letter.
Question 9: Do you have any significant objection against the proposed threshold for property-specific valuation (EUR 300,000)?
N/A
Question 10: Do the requirements for valuation of movable property collateral capture all relevant aspects?