Response to consultation on Guidelines on management of non-performing and forborne exposures

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Question 1: What are the respondents’ views on the scope of application of the guidelines?

Please see attachment.

Question 2: What are the respondents view of the proposed threshold of 5 % NPL ratio?

Please see attachment.

Question 3: Do you see any significant obstacles to the implementation date and if so, what are they?

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Question 4: Does section 4.3.2 capture all relevant options available for credit institutions to implement their NPE strategy?

Please see attachment.

Question 5: Do you see any significant obstacles to the operationalisation of the NPE strategy as described in chapter 5?

Please see attachment.

Question 6: Does the viability assessment of forbearance measures capture all relevant aspects?

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Question 7: What are the respondents view on the proposed requirements for recognition of non-performing and performing/non-performing forborne exposures?

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Question 8: What are respondents view on the requirements on timeliness of impairments and write-offs of NPEs?

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Question 9: Do you have any significant objection against the proposed threshold for property-specific valuation (EUR 300,000)?

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Question 10: Do the requirements for valuation of movable property collateral capture all relevant aspects?

Please see attachment.

Name of organisation

AFME