Submission #54

Primary tabs

View(active tab)

Czech Banking Association

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

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

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 the attached file

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

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

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

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 the attached file

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

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

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

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

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

Upload files CP on GL on loan origination and monitoring_CBA Response_20190923.pdf

Name of organisation Czech Banking Association