Submission #59

Polish Bank Association

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

Due to the large number of comments, the responses can be found in 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?

Due to the large number of comments, the responses can be found in 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)?

Due to the large number of comments, the responses can be found in the attached file

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

Due to the large number of comments, the responses can be found in the attached file

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

Due to the large number of comments, the responses can be found in 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?

Due to the large number of comments, the responses can be found in 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)?

Due to the large number of comments, the responses can be found in the attached file

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

Due to the large number of comments, the responses can be found in 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)?

Due to the large number of comments, the responses can be found in the attached file

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

Due to the large number of comments, the responses can be found in the attached file

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

Due to the large number of comments, the responses can be found in the attached file

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

Due to the large number of comments, the responses can be found in the attached file

Upload files PBA opinion on EBA Guidelines on Loan Origionation and Monitoring.pdf

Name of organisation Polish Bank Association