The Bank Association of Slovenia (Zdruzenje bank Slovenije)

In our opinion, the Guidelines are in scope with current best practice tools and measurements in restructuring and work-out departments. Nevertheless, please note our remarks concerning the proportionality principle in the attachment.
Please see our argumentation concerning the proposed threshold and the definition of the NPL ratio in the attachment.
We believe that the implementation date by end of 2018 is viable for the majority of institutions since most of the foreseen measurements are already implemented and in use, but considering the fact that especially for some small institutions (e.g. for those with balance sheet size of less than EUR 3bn) some demands would require further investments and upgrades of their existing systems with longer implementation deadlines. 1 January 2019 deadline therefore seems to be too strict and too ambitious and propose its extension by least one year.
Most of the foreseen measurements are already implemented and in use. We agree with the proposal.
We have not identified any particular obstacles for implementation.
Credit institutions have already implemented mentioned measures and are able to demonstrate, based on reasonable financial information, that the borrower is able to service its financial liabilities.
Institutions' policies seem to be in compliance with Annex V of Regulation (EU) 680/2014.
Institutions' policies seem to be in compliance with Annex V of Regulation (EU) 680/2014.
We would propose to increase the threshold to EUR 500,000 which would be valid up to 24 months, except when collateral is subject to divestment or materially adverse changes occurred (please see also our comment in the attachment).
We suggest to set a threshold below which the requirements of these paragraphs would not apply (e.g. EUR 300,000 – please see also our comment in the attachment).
Kristijan Hvala