Association of Consumer Credit Information Suppliers

ACCIS is pleased to read in the EBA’s draft guidance that access to central credit registers and other relevant external data sources (which would thereby also include credit bureaus) is important for an institution’s NPE WUs to work effectively (paragraph 79). However, the guidance states that such access should take place ‘where technically possible’ although ‘an adequate technical infrastructure’ is a prerequisite and essentially assumes technical feasibility.

It has been acknowledged by the EBA that access to credit data collected on a regular basis by credit registers and credit bureaus can help an institution manage its NPEs, including where an institution needs to check the overall indebtedness of a borrower / project before granting any forbearance measures (paragraph 142).

It has also been stated that NPE WUs should be linked with loan origination units by means of a feedback mechanism (para 61) .

Furthermore, it should be recalled that access to and sharing of data and documentation by all NPE WUs with credit registers and credit bureaus has benefits for the financial system as a whole i.e. it helps detect the potential build-up of risks from a systemic, financial stability perspective and can help supervisors ascertain the magnitude and relevance of non-performing loans, changes and recent trends, etc. Analysis of credit data can help in defining and setting indicative thresholds to guide policy decisions on when a preventive intervention from the authorities responsible for financial stability may become necessary.

As a consequence, ACCIS is of the view that that ‘an adequate technical infrastructure’ should enable NPE WUs to ‘easily access all relevant data and documentation including […] access to central credit registers […] and other relevant external data sources such as credit bureaus'. Please, delete 'where technically possible'.

Furthermore, in line with EBA’s acknowledgement of the helpfulness of credit data, it would be recommendable to mention ‘credit bureaus’ in paragraph 121, within the context of the external information on the basis of which Early Warning Indicators should be set. This would also help better address the retail dimension of NPEs, which is also considered in the guidelines.

Paragraph 121 should, therefore, read:

‘EWIs should be set on the basis of internal (e.g. internal score systems) or external information (rating agencies, credit bureaus, specialised sector research, or macroeconomic indicators for specific geographical areas) and refer to a point in time or an observation period. Annex 3 includes examples of EWIs as inputs into the early warning system.’
Enrique Velázquez