RICS has no objection to the proposed threshold of €300,000. In our understanding the threshold is consistent with European Central Bank (ECB) Guidance to banks on non-performing loans published in March 2017, which implies that indexed valuations “may be used to update the valuation for non-performing loans of less than 300,000 euro in gross value” (Section 7.2.3, page 88, “Individual versus indexed valuations”)
No further comments on the requirements for valuation of movable property collateral.
Zsolt Toth