Response to consultation on Guidelines on disclosure of non-performing and forborne exposures

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Question 1: Could you provide your views on whether adding an “of which” column to column ‘f’ of template 1 - “Credit quality of forborne exposures”, including the information on non-performing forborne exposures that are impaired (i.e. “of which impaired”) would be useful?

We consider that such an addition would overload the already granular template. The additional benefits for market participants would have to be justified.

Question 2: Could you provide your views on whether adding the columns with the breakdown of provisions for non-performing exposures by buckets of the number of days that the exposure has been past due to template 3 - “Credit quality of performing and non-performing exposures by aging of past due days” would be useful?

We already consider the level of granularity to be too high for a Pillar 3 report, so a further breakdown would not make sense in this respect. Rather, we advocate reducing the number of past due buckets or at least aligning them with the reporting requirements.

Question 3: Could you provide your views on whether the breakdown between “on balance sheet exposures” and “off balance sheet exposures” included in template 5 – “Quality of Non-performing exposures by geography” is useful?


Question 4: Could you provide your views on whether the information on loans and advances secured with immovable property with a loan-to-value higher than 60% and lower than 80% included in row 3 of template 7 – “Collateral valuation - Loans and advances at cost or amortised cost” is useful?


Question 5: Do you agree with the overall content of these guidelines and with the templates proposed? In case of disagreement, please outline alternatives that would help to achieve the purpose of the guidelines.

We urge limiting the EBA Guidelines in their entirety to institutions with an NPL ratio greater than 5%, because, in our view, even tremendously detailed and complex prudential requirements for disclosing NPLs will not achieve the actual goal of reducing the still excessive levels of NPLs in some EU Member States and of avoiding further risk accumulation.

Name of organisation

German Savings Banks Association