Submission #35

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

We agree on the ITS as a way to foster consistency across transactions, as they are inspired by principles of proportionality and fairness

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.

We mostly agree on the data structure. Please refer to Annex II for further comments

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.

We mostly agree on the data structure. Please refer to Annex II for further comments

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.

We mostly agree on the data structure. Please refer to Annex II for further comments

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?

We do not agree on the approach to merge data about collateral guarantee and real estate asset in a single tape. Please refer to Annex II for further comments

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?

We do not agree on the data model approach related with collateral. We suggest to insert a new relationship template to link collateral protection with asset (Real Estate or other asset subject to transcript or registration procedure). Please refer on Sheet 3. Data Model Proposal

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. We agree on the data glossary structure and content

8. What are the respondents’ views on the content of instructions? We consider instructions sufficently clear and complete

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

We agree on the use of the "No data options" on non-mandatory fields whether data have never be collected by the seller and cannot be collected in future or are collected but are not available in any reporting system. In case of data collected and loaded, even if in non-central reporting system, the seller should carry out any attempt in order to provide those informations

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)?

We consider the provided EBA documentation consistent with the Directive mandate. The drafting of technical specifications may be a prerogative of other actors (i.e. Marketplaces, Due Diligence Platforms, etc..)

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.

We mostly agree on the defined approach to the proportionality. Please refer to Annex II for further comments

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? We agree on the size of the threshold, given the consistency with AnaCredit

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

We belive in the growth of use of digital platforms, aligned with relevant regulation on GDPR, Data Governance Principles and on market best practices, which ensures NDA signing between parties, data protection and secure virtual data room availability

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