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

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Question 1: What are the respondents’ views on the scope of application of the guidelines?

Credit institutions acting as investors on the secondary NPL market have no desire to reduce their NPL ratios. The secondary NPL market is an important tool for “traditional” banks to reduce their NPL ratios, hence having investors on this market should lie in EBA’s interest. Therefore, purchased NPL portfolios should be excluded from these guidelines as well as from the definition of the NPL ratio.

Question 2: What are the respondents view of the proposed threshold of 5 % NPL ratio?

See answer to question 1.

Name of organisation

Marginalen Bank