Submission #3

Primary tabs

View(active tab)

Bundesverband Deutscher Leasing Unternehmen (BDL)

1. What are the respondents’ views on the scope of application of the draft guidelines? See our comment.

2. Do you see any significant obstacles to the implementation of the guidelines by the application date and if so, what are they? See our comment.

3. What are the respondents’ views on whether the requirements set in the draft guidelines are future proof, in particular in relation to technology enabled innovation (Section 4.3.2) and environmental factors and green lending (Section 4.3.3)? See our comment.

4. What are the respondents’ views on the requirements for credit risk policies and procedures (Section 4.3)? See our comment.

5. What are the respondents’ views on the requirements for governance for credit granting and monitoring (Section 4)? See our comment.

6. What are the respondent’s views on how the guidelines capture the role of the risk management function in credit granting process? See our comment.

7. What are the respondents’ views on the requirements for collection of information and documentation for the purposes of creditworthiness assessment (Section 5.1)? See our comment.

8. What are the respondents’ views on the requirements for assessment of borrower’s creditworthiness (Section 5.2)? See our comment.

9. What are the respondents’ views on the scope of the asset classes and products covered in loan origination procedures (Section 5)? See our comment.

10. What are the respondents’ views on the requirements for loan pricing (Section 6)? See our comment.

11. What are the respondents’ views on the requirements for valuation of immovable and movable property collateral (Section 7)? See our comment.

12. What are the respondents’ views on the proposed requirements on monitoring framework (Section 8)? See our comment.

Upload files 2019-09-30 BDL on EBA-CP-2019-04.pdf

Name of organisation Bundesverband Deutscher Leasing Unternehmen (BDL)