The EACB welcomes the opportunity to comment on the EBA draft ITS on the NPL Transactions Data Templates mandated under the Directive on credit servicers and credit purchasers.
We appreciate the work done by the EBA in streamlining the templates and greatly reducing the number of data fields compare to previous versions. We believe however that the data points required are excessive for the purpose of disclosing information to prospective buyers.
Making the templates leaner and more focused would be beneficial to offering market participants information that is actually relevant and functional to the buyers’ assessment. In fact, it should not be overlooked that documentation and guarantees also play a key role in NPLs transactions.
Furthermore, although the draft ITS does not introduce any supervisory reporting requirements (background, paragraph 6) and although there is no formal role for the competent authorities in monitoring the use of the templates and enforcing the use of the draft ITS at the point of sale of NPL introduced (background, paragraph 42), the EBA would expect competent authorities to assess the availability of information and use of the template as part of their supervisory activities. We see that there is no legal basis in this respect for (national) competent authorities to act/operate this way.
Finally, we have a number of suggestions and observations to improve the design and structure of the templates.