Submission #21

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CREDEM BANCA

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

No specific principles are provided with reference to factoring arrangements. A specific reference to factoring arrangements should be introduced, in particular for the types of factoring arrangements where the receivables are purchased by the institutions and recognised in the institutions’ balance sheet. Specific guidelines on the assessment of borrower’s creditworthiness should be provided in connection with public sector debtors.

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

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)? N/A

4. What are the respondents’ views on the requirements for credit risk policies and procedures (Section 4.3)? N/A

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

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

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

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

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

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

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

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

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Name of organisation CREDEM BANCA