Response to consultation on Guidelines on disclosure of non-performing and forborne exposures
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Therefore, the rows concerning immovable property in Templates 7, 8 and 10 on collateral valuation would be burdensome but irrelevant for those entities.
We would like to raise the following issues concerning the proposed templates:
Template 2:
The first row entitled more than once" may be useful to measure new forbearance.
On the opposite, for some consumer credit institutions for instance, the second proposed row entitled "more than twice" is not usefull since institutions internal rules usually do not authorise more than one forbearance in a single year.
Template 6:
This proposed Template seems relevant for credit institutions with high ratios of NPL. But it is not adapted to activities such as consumer credit.
Templates 7, 9 and 10
We underline the fact that specialised credit institutions, such as those specialised in consumer credit, do not usually carry loans secured by immovable properties.
Therefore, the rows concerning immovable property in Templates 7, 8 and 10 on collateral valuation would be burdensome but irrelevant for those entities.
Template 8:
The required details in this proposed template do not seem all operationnal for activities such as consumer credit."
Question 4: Could you provide your views on whether the information on loans and advances secured with immovable property with a loan-to-value higher than 60% and lower than 80% included in row 3 of template 7 – “Collateral valuation - Loans and advances at cost or amortised cost” is useful?
We underline the fact that specialised credit institutions, such as those specialised in consumer credit, do not usually carry loans secured by immovable properties.Therefore, the rows concerning immovable property in Templates 7, 8 and 10 on collateral valuation would be burdensome but irrelevant for those entities.
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.
As a general comment, with regards to the principle of proportionnality, we would like to underline the high cost of inserting new reporting (IT developments, operationnal costs associated….) in IT systems for smaller and specialised institutions.We would like to raise the following issues concerning the proposed templates:
Template 2:
The first row entitled more than once" may be useful to measure new forbearance.
On the opposite, for some consumer credit institutions for instance, the second proposed row entitled "more than twice" is not usefull since institutions internal rules usually do not authorise more than one forbearance in a single year.
Template 6:
This proposed Template seems relevant for credit institutions with high ratios of NPL. But it is not adapted to activities such as consumer credit.
Templates 7, 9 and 10
We underline the fact that specialised credit institutions, such as those specialised in consumer credit, do not usually carry loans secured by immovable properties.
Therefore, the rows concerning immovable property in Templates 7, 8 and 10 on collateral valuation would be burdensome but irrelevant for those entities.
Template 8:
The required details in this proposed template do not seem all operationnal for activities such as consumer credit."