We welcome the final draft and believe that EBA found a reasonable compromise between buyers and sellers in defining a core data set. The new ITS do not create regulatory reporting obligations and non-delivery of mandatory fields will not result in sanctions other than through market discipline. Nevertheless, we remain concerned that the introduction of mandatory fields may deter some banks from selling NPLs if they cannot approach investors with a full list of all applicable mandatory fields.

Once adopted by the European Commission, the revised templates will become mandatory for credit institutions in the course of 2023 for the provision of information to investors under the directive on credit servicers and credit purchasers. EBA has designed the loan-level templates for sellers to provide standardised information to potential buyers of NPLs for the purposes of financial due diligence and valuation with the objective to increase efficiency in the market for NPLs and to reduce information asymmetries between the sellers and buyers of NPLs.

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