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German Savings Banks Association

We consider that such an addition would overload the already granular template. The additional benefits for market participants would have to be justified.
We already consider the level of granularity to be too high for a Pillar 3 report, so a further breakdown would not make sense in this respect. Rather, we advocate reducing the number of past due buckets or at least aligning them with the reporting requirements.
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We urge limiting the EBA Guidelines in their entirety to institutions with an NPL ratio greater than 5%, because, in our view, even tremendously detailed and complex prudential requirements for disclosing NPLs will not achieve the actual goal of reducing the still excessive levels of NPLs in some EU Member States and of avoiding further risk accumulation.
Silvio Andrae
030202255437