Performing exposures with forbearance measures are distinguished into these that were considered as performing from the date when forbearance measures were extended (see paragraph 178) and these that were previously non-performing and have been reclassified from the non-performing category. Is there a distinction regarding the assessment criteria for these two types of exposures or have all performing exposures with forbearance measures to be assessed on a quarterly basis (see paragraph 177), although the class of formerly non-performing exposures is exposed to a higher risk to become non-performing again as compared to these that have always been performing since forbearance measures were extended?

According to our understanding, paragraph 176 (e.g., “probation period of 2 years”) applies to all performing exposures with forbearance measures (see page 52 of the final draft "harmonised period for all exposures") and paragraph 179 only applies to formerly non-performing exposures (see page 55 of the final draft "once a forborne exposure exits the non-performing category and becomes a performing forborne exposure under probation period, any additional forbearance measure or any amount more than 30 days past due should lead to the reclassification of the exposure as non-performing"). However, it is not clear to us to which type of performing exposures with forbearance measures the paragraph 177 applies. If it only applied to these exposures that were formerly non-performing, the question would arise, in which frequency have these to be reported to which the conditions of paragraph 178 apply as no further information regarding frequency of the assessment and the final assessment at the end of the probation period is given.