EBA欧洲银行-EBA-draft-GL-on-loan-origination-public-hearing_15页_1mb

报告摘要

Summary of the Consultation Paper on Draft Guidelines on Loan Origination and Monitoring

Core Content

The consultation paper outlines the draft guidelines on loan origination and monitoring, aimed at enhancing the prudential supervision of credit institutions in the European Union. These guidelines are part of the regulatory framework under the Capital Requirements Regulation (CRR) and are designed to align with the European Banking Authority (EBA)'s role in setting standards for financial institutions. The paper invites public feedback through a public hearing on 20 September 2019.

Main Features of the Draft Guidelines

The draft guidelines focus on the following areas:

Governance requirements for credit granting and monitoring
Loan origination procedures for consumers and professionals
Pricing requirements with a focus on risk-adjusted performance indicators
Valuation of collateral (both immovable and movable property)
Monitoring framework for credit risk, market risk, and other exposures

The guidelines emphasize prudence, transparency, and risk management throughout the loan lifecycle, from origination to monitoring and valuation.

Scope of Application

The guidelines apply to:

All credit facilities (excluding debt securities) for Sections 4 and 8, covering all counterparties.
Loans and advances for Sections 5, 6, and 7, which apply to:
- New loans originated after the application date (proposed 30 June 2020)
- Existing loans with terms renegotiated after the application date

The scope includes professional clients and consumers for all sections, with Section 5 also addressing creditors under MCD and CCD.

Proportionality

Proportionality is a central principle in the guidelines and is applied in three forms:

Proportionality in relation to the size and complexity of the institution
Proportionality in relation to the size and complexity of the credit facility
No proportionality (in certain cases)

Section 4 (governance) applies proportionality criteria based on the EBA Guidelines on internal governance (Title I of EBA/GL/2017/11)
Sections 5-8 apply proportionality to all other requirements
Consumer protection aspects in creditworthiness assessments are not subject to proportionality, ensuring that consumer-related standards are applied uniformly regardless of the institution's size or complexity

Key Requirements

1. Information Collection and Documentation

Institutions must collect minimum information on borrowers, including:
- Income for consumers
- Cash flow and business plans for non-financial corporations (NFCs)
- Financial commitments for all borrowers
Additional considerations are provided in Annex 2

2. Creditworthiness Assessment

Consumers are subject to requirements under MCD (integration and repeal of EBA/GL/2015/11)
Secured and unsecured lending (e.g., CCD) are addressed
General requirements apply to:
- NFC and CRE (corporate real estate)
- Shipping
- Project and infrastructure finance
Includes sensitivity analyses to assess risk
Additional considerations are provided in Annex 3

3. Pricing

The pricing section sets high-level requirements but does not specify asset-specific pricing strategies
Institutions should consider:
- Cost of capital
- Cost of funding
- Operating and administrative costs
- Credit risk
- Other real costs
Risk-adjusted performance indicators such as:
- EVA (Economic Value Added)
- RORAC (Return on Risk-Adjusted Capital)
- RAROC (Risk-Adjusted Return on Capital)
Requires documentation and regular monitoring of pricing decisions

4. Valuation of Collateral

Aligns with CRR Article 208(3), focusing on policies, procedures, and processes, rather than specific methodologies
Encourages the use of advanced statistical models throughout the collateral's lifecycle, within legal boundaries
Requires transparent and comprehensive valuation reports covering the process and findings
Sets requirements for valuer quality and competency, including:
- Internal and external valuers
- Conflict of interest mitigation

5. Monitoring Framework

Institutions must have a prudent and granular monitoring framework to track all exposures
Monitoring is closely linked to IT and data infrastructure, using key risk indicators to identify:
- Credit risk
- Market risk
- Country risk
- Impairments
- Write-offs
Provides feedback loops to inform credit risk appetite, policies, and limits
Includes tools and frameworks such as:
- Stress testing
- Early Warning Indicators (EWIs) with an adequate escalation process
- Watch-list mechanisms

Next Steps

The tentative timeline for implementation is outlined in the paper, with the application date proposed as 30 June 2020
The EBA will review the feedback and finalize the guidelines accordingly