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ASSOCIATION FRANCAISE DES SOCIETES FINANCIERES

We underline the fact that specialised credit institutions, such as those specialised in consumer credit, do not usually carry loans secured by immovable properties.
Therefore, the rows concerning immovable property in Templates 7, 8 and 10 on collateral valuation would be burdensome but irrelevant for those entities.
As a general comment, with regards to the principle of proportionnality, we would like to underline the high cost of inserting new reporting (IT developments, operationnal costs associated….) in IT systems for smaller and specialised institutions.

We would like to raise the following issues concerning the proposed templates:

Template 2:
The first row entitled more than once" may be useful to measure new forbearance.
On the opposite, for some consumer credit institutions for instance, the second proposed row entitled "more than twice" is not usefull since institutions internal rules usually do not authorise more than one forbearance in a single year.

Template 6:
This proposed Template seems relevant for credit institutions with high ratios of NPL. But it is not adapted to activities such as consumer credit.

Templates 7, 9 and 10
We underline the fact that specialised credit institutions, such as those specialised in consumer credit, do not usually carry loans secured by immovable properties.
Therefore, the rows concerning immovable property in Templates 7, 8 and 10 on collateral valuation would be burdensome but irrelevant for those entities.

Template 8:
The required details in this proposed template do not seem all operationnal for activities such as consumer credit."
M. Yves-Marie LEGRAND
+33 (à)1 53 81 51 67