Yes, it would be useful to detail the “of which defaulted” and “of which impaired” columns for impairments on non-performing forborne exposures. This would align with the splits shown in columns ‘c’ and ‘d’ for gross carrying amounts on non-performing forborne exposures.
We believe that this may be a useful breakdown, but should be balanced with information on collateral held on exposures as well as the relative risk associated with the different asset classes. Provision levels for exposures to households, for example, may not be fully comparable from lender to lender, as ratios of secured to unsecured lending and underwriting standards can vary significantly between credit institutions.
We would not fall within scope for this template, as we would not meet the significance criteria and the majority of exposures are domestic.
While we would not fall within scope for this template, we believe the loan-to-value splits are useful for the reader.
We agree with the underlying principle of addressing deficiencies in disclosure requirements. While some element of proportionality is embedded in the guidelines, the definition of significance outlined in the guidelines would extend to most banks within the UK. While the added NPL threshold is welcomed, we would suggest further consideration of proportionality where credit institutions have sustained small levels of non-performing loans.
The requirements for the 4 templates that all credit institutions will be in scope for, overlap significantly with FINREP reporting requirements and full alignment would limit cost and complexity associated with this change.