Submission #66

European Associaiton of Co-operative Banks

1. What are the respondents’ views on the scope of application of the draft guidelines? Please see the attached EACB position.

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

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)? Please see the attached EACB position.

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

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

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

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 see the attached EACB position.

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

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

10. What are the respondents’ views on the requirements for loan pricing (Section 6)? Please see the attached EACB position.

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

12. What are the respondents’ views on the proposed requirements on monitoring framework (Section 8)? Please see the attached EACB position.

Upload files FINAL_EACB comments on EBA draft GL on loan origination.pdf

Name of organisation European Associaiton of Co-operative Banks