Response to consultation on Guidelines on management of non-performing and forborne exposures

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Question 9: Do you have any significant objection against the proposed threshold for property-specific valuation (EUR 300,000)?

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”)

Question 10: Do the requirements for valuation of movable property collateral capture all relevant aspects?

No further comments on the requirements for valuation of movable property collateral.

Name of organisation

RICS