Submission #69

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French Banking Federation (FBF)

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

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

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 attachment

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

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

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

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 attachment

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

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

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

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

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

Upload files 20190930_FBF response_ EBA CP on loan origination.pdf

Name of organisation French Banking Federation (FBF)