Response to consultation on draft Regulatory Technical Standards on materiality threshold of credit obligation past due

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Q2. Do you agree with the proposed maximum levels of the thresholds?

Yes.

Q3. How much time is necessary to implement the threshold set by the competent authority according to this proposed draft RTS? Given current practices, what is the scope of work required to achieve compliance?

NA to me

Q4. Do you agree with the assessment of costs and benefits of these proposed draft RTS?

Yes.

Q5. What is the expected impact of these proposed draft RTS?

Generally, the implementation shall not be a big problem as generally each bank is using the materiality thresholds in DPD and in Default recognition. So it is modification of the current procedures.

Name of organisation

ppscoringsolutions, bank consultant in the field of IRB implementation