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

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Question 5: Do you agree with the overall content of these guidelines and with the templates proposed? In case of disagreement, please outline alternatives that would help to achieve the purpose of the guidelines.

There are credit institutions acting as investors on the secondary NPL market. As they are not creating new credit, but are buying existing credit at own risk, they do not cause prudential concerns and their potential contribution to systemic risk is negligible. Therefore, purchased NPL portfolios should be excluded from the disclosure requirements or at least disclosed separately.

Name of organisation

Marginalen Bank