Response to consultation Paper on draft Guidelines on loan origination and monitoring.

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

No comments.

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

No comments.

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

Please find the comments in the attached position paper.

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

Please find the comments in the attached position paper.

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

Please find the comments in the attached position paper.

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

Please find the comments in the attached position paper.

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

Please find the comments in the attached position paper.

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

Please find the comments in the attached position paper.

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Name of organisation

Verband der Privaten Bausparkassen e. V. / Bundesgeschäfsstelle Landesbausparkassen