Submission #17

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Financial Markets Law Committee

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

Dear Sirs

Please see attached a letter which we have uploaded in response to this consultation.

Yours faithfully,

Becky Jacombs
FMLC Senior Researcher

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. N/A

3. What are the respondents’ views on the content of Template 3? 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. N/A

4. What are the respondents’ views on the content of Template 4? 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. N/A

5. What are the respondents’ views on the content of Template 5? 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? N/A

6. Do the respondents agree on the structure of Template 2 to represent the relationship across the templates? If not, do you have any other suggestion of structure? N/A

7. Do the respondents agree on the structure and the content of the data glossary? 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. N/A

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

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

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)? N/A

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. N/A

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? N/A

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

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

Upload here any other file FMLC Letter - Response to the EBA Consultation on Implementing Technical Standards on NPL transaction data templates.pdf

Name of the organization Financial Markets Law Committee