Response to consultation on Implementing Technical Standards on NPL transaction data templates
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a) Original Creditor
b) Gender
c) Geographic Region of Residence
d) Income at the origination date
e) Probability of default
All of those points are needed for optimal assessment of Counterparty repayment ability.
Our comments for the data fields we have added in the dedicated columns of the data glossary.
a) Origination Amount
b) Termination Date of the Loan
c) Court Date
d) Execution Title Date
e) Execution Start Date
f) Execution Close Date
g) Type of Execution Title
h) Bailiff in case
All of those points are needed for optimal assessment of future payments on particular case.
Our comments for the data fields we have added in the dedicated columns of the data glossary.
a) Land and Mortgage registry number
In case of loans secured by mortgage we need a land and mortgage registry number in order to be able to value the portfolio.
Our comments for the data fields we have added in the dedicated columns of the data glossary.
a) History of Repayments - From Direct Debit
Our comments for the data fields we have added in the dedicated columns of the data glossary.
We would like to strongly highlight how important is monthly view of repayments history from last 24/36 months (before cut-off date, without limitation to payments after default date). This approach to visualization these data is nothing new and impossible to implement by Sellers, because we receive it for valuation from Partners during the selling process. This is crucial data used in our valuation models.
Limiting the availability of data will reduce the quality of the valuation. Additionally, this kind of differentiating may increase the workload of the Seller, who will have to create two different standards for exporting data from the database. It is in contradiction with the idea of creating one standard.
Possible differentiating a range of data for smaller and larger balances is not recommended at the European level, due to different levels of value of loans / ability to borrow in different countries.
1. Do the respondents agree that these draft ITS fits for the purpose of the underlying directive?
Yes, we agree that this draft ITS fits for the purpose of the underlying directive.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 would like to add below data to Template 1 as a very valuable for valuation purposes:a) Original Creditor
b) Gender
c) Geographic Region of Residence
d) Income at the origination date
e) Probability of default
All of those points are needed for optimal assessment of Counterparty repayment ability.
Our comments for the data fields we have added in the dedicated columns of the data glossary.
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 would like to add below data to Template 3 as a very valuable for valuation purposes:a) Origination Amount
b) Termination Date of the Loan
c) Court Date
d) Execution Title Date
e) Execution Start Date
f) Execution Close Date
g) Type of Execution Title
h) Bailiff in case
All of those points are needed for optimal assessment of future payments on particular case.
Our comments for the data fields we have added in the dedicated columns of the data glossary.
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 would like to add data to Template 4 as very valuable for valuation purposes:a) Land and Mortgage registry number
In case of loans secured by mortgage we need a land and mortgage registry number in order to be able to value the portfolio.
Our comments for the data fields we have added in the dedicated columns of the data glossary.
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 would like to add below data to Template 5 as a very valuable for valuation purposes:a) History of Repayments - From Direct Debit
Our comments for the data fields we have added in the dedicated columns of the data glossary.
We would like to strongly highlight how important is monthly view of repayments history from last 24/36 months (before cut-off date, without limitation to payments after default date). This approach to visualization these data is nothing new and impossible to implement by Sellers, because we receive it for valuation from Partners during the selling process. This is crucial data used in our valuation models.
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?
Yes, we do agree.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.
Yes, we do agree.8. What are the respondents’ views on the content of instructions?
In our opinion content of instructions are clear.9. Do the respondents agree on the use of the ‘No data options’ as set out in the instructions?
Yes, we do agree.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)?
In our opinion the proposed set of templates, data glossary and instructions are enough to achieve the data standardisation in the NPL transactions on secondary markets under the condition that additional data added proposed by ZPF would be considered.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 would like to receive complex data for each portfolio. When the scope of data (i.e. SQL query) is developed once, it can be used every time with no additional work for portfolios with lower outstanding amount.Limiting the availability of data will reduce the quality of the valuation. Additionally, this kind of differentiating may increase the workload of the Seller, who will have to create two different standards for exporting data from the database. It is in contradiction with the idea of creating one standard.
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 do not agree with the proposed calibration of 25 000 euros threshold in line with AnaCredit Regulation. In our opinion this is to high limit. At the Polish market that we represent most of cases which are selling have outstanding amount under this threshold (more than 90%- if we talk about average outstanding amount of portfolio then it would be more than 99% of portfolios).Possible differentiating a range of data for smaller and larger balances is not recommended at the European level, due to different levels of value of loans / ability to borrow in different countries.