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Overall, the template covers the most basic variables needed for running an NPL valuation. That said, some additional variables would be good to add to complement these basic variables. In addition, further clarification on some of the items would be required so as to have a more precise understanding of the data. This would lead to more accurate pricing of NPL portfolios.
Template 1 provides enough data related to the counterparties involved; the data provided is more extensive than usual. However, we do disagree with the usage of the proportional threshold of 25k EUR (please see further details under question 11).
Our first comment refers, as in the previous point, to the use of the proportional threshold of 25K EUR. Any information in this template flagged as “Mandatory” should be provided regardless of the loan size.

Regarding template 3 itself, the key information missing, in our view, relates to the split between the principal amount outstanding and the unpaid interest. In this template, we have a combined “Outstanding nominal amount” (field 3.12), but we should ideally have separate fields for principal and interest, instead of a combined one, especially considering that in some jurisdictions this is a requirement for sending the cases to legal.

It would also be important to clarify if this outstanding nominal amount reported in the data tape includes or excludes potential “Debt forgiveness amounts” (field 3.45).

Additionally, in terms of a “Forbearance measure”, for example, the Overindebtness procedure (BDF) in France or the Cambialis in Italy, it would be important to include additional fields that describe properly the terms of the payment plans agreed upon with the debtors, such as instalment amounts, payment frequency, balloon payments, the start date of the plan, the end date of the plan, etc. So, we recommend extending this information by separate fields.

Also, we noticed that most of the legal information is at the counterparty or collateral level and not at the level of the loan itself and we believe that this loan information is crucial for pricing.

Below is a suggestion for additional fields that we believe would be important to add for the sake of completeness:

• Termination date (Mandatory)
• Current Principal amount (Mandatory)
• Current Interest amount (Mandatory)
• Number of external agencies that have worked the loan (Non-mandatory)
• The legal status of the loan (Mandatory)
• Date of legal actions (Mandatory)
• All information described in the paragraph above related to the Forbearance measures (the start date of the plan, end date of the plan, payment frequency, instalments amounts, etc.) where applicable.

We believe that most of the relevant information is well covered, however, we found that some additional information should be added in order to run a proper valuation.

Apart from the highest lien rank in favour of the seller, it would be important to know if there are other lien ranks that are in its favour. Likewise, it would be important to have information about which loan belongs to each lien to be able to calculate properly the waterfall.

Therefore, our suggestion would be to add to this template the relation between Loan, Collateral and Lien (1:1:1 relation).

In the event that the collateral has already been sold/executed through a court proceeding, fields are lacking about the “Cash in court amount” pending to be distributed. This is crucial information.

Also, we noticed that some fields that are flagged as “Not Mandatory” should, in our view, be mandatory where necessary. For example: “Collateral Repossessed Date” and “Next Auction Date”.

This list of fields would be important to include:

• For REOs Land registry identification number (mandatory)
• Cash in court (mandatory).
Historical payment information is by far the most relevant information for NPLs valuation. We believe that the current format suggested in Template 5 is not the best way of providing this data.

In our view, buyers should have full access to this historical collection at best from the default date and at least from the last 12 months prior to the cut-off date. The data should be provided in as granular a way as possible, on loan level and in monthly payments.

Consequently, our suggestion on the best way of populating this information would be in a few columns containing the following information:

• Loans ID (mandatory)
• Payment date (mandatory)
• Payment amount (mandatory)
• Payment type (liquidation, direct debit, salary seizure, etc.) (mandatory)
Overall, we agree with the structure of Template 2, with the caveat of the relationship between Loans IDs and Collateral IDs, as per our comment under question 4.
No comments about the structure of the data glossary.
No comments about the contents of the instructions.
We agree on the use of the “No data options”. This adds clarity.
We believe that it is enough and no further specification should be added.
We strongly disagree with this approach. All mandatory data fields should be populated independently of the size of the loan. It is important to consider that most of the consumer unsecured NPL transaction relates to portfolios with an average size well below this threshold of €25,000. We also disagree with the proposal of having some mandatory fields for loans above €25,000 and the same field for loans below € 25,000 non-mandatory. Again, the fields stated as mandatory should be mandatory independently of the size of the loan.
As stated in the previous point, we disagree with this threshold and we believe that data should be available independently of the size of the loan, considering that the source of data should be exactly the same for loans below or above such threshold.
Overall, we agree with the proposed operational procedures and confidentiality.