+5. NPE governance and operations
---+58. In order for credit institutions to be able to address their NPE issues in an efficient and …
---+59. This section sets out the key elements of governance and operations in relation to an NPE …
---+60. In the implementation of their NPE governance and operations, credit institutions should take …
---+5.1 Steering and decision-making
------+61. The overarching strategy of a credit institution and its implementation should cover the NPE …
------+62. The management body and senior management should dedicate an amount of their capacity and …
---+5.2 NPE operating model
------+5.2.1 NPE workout units
---------+63. In order to mitigate sufficiently any conflict of interest in managing NPEs, as well as to make …
---------+64. Where overlaps with the decision-making bodies, managers or experts involved in the loan …
---------+65. Credit institutions should have arrangements in place to ensure that regular feedback between …
---------+66. When designing an appropriate NPE WU structure, credit institutions should take into account …
---------+67. Credit institutions should consider designing automated processes for NPE WUs for homogeneous …
---------+68. Smaller and less complex credit institutions (e.g. those that are classified in SREP Category 3 …
---------+69. For proportionality purposes, smaller and less complex credit institutions (e.g. those that are …
------+5.2.2 Alignment with the NPE life cycle
---------+70. NPE WUs should be set up to ensure that NPE workout activities and borrower engagements are …
---------+71. Credit institutions should consider the following phases in the NPE life cycle, taking into …
---------+72. Managing foreclosed assets (or other assets stemming from NPEs): collateral repossession …
------+5.2.3 Grouping exposures
---------+73. The EBA Guidelines on credit risk management practices and accounting for expected credit …
---------+74. A list of potential selection criteria for grouping retail NPEs into portfolios is contained in …
---------+75. For corporate NPE portfolios, grouping by asset class or sector (e.g. commercial real estate …
------+5.2.4 Human resources
---------+76. Credit institutions should have in place an appropriate organisational framework relative to …
---------+77. Sharing management and resources with other parts of the value chain (e.g. loan origination) …
---------+78. Based on the findings of the credit institution’s NPE self-assessment on capabilities, as …
---------+79. Credit institutions should build up the relevant expertise required for the defined NPE …
---------+80. Where it is not possible or efficient to build in-house expertise and infrastructure, the NPE …
---------+81. The credit institution, in alignment with the overall NPE strategy and operational plan, should …
---------+82. The performance measurement framework for the management body and relevant managers should …
---------+83. Addressing early warnings signals and indicators should be encouraged by credit institutions …
------+5.2.5 Technical resources
---------+84. In terms of adequate technical infrastructure, credit institutions should ensure that all …
---------+85. An adequate technical infrastructure should enable NPE WUs to: a) Access all relevant data and …
---------+86. The adequacy of the technical infrastructure, including data quality, should be assessed by an …
---+5.3 Control framework
------+87. The management body should be responsible for establishing and monitoring the adequacy and …
------+88. Internal control functions should regularly submit to the management body written reports on …
------+89. The management body should follow up on the findings of the internal control functions in a …
------+90. The internal control framework should involve all three lines of defence in line with the EBA …
------+91. In the implementation of the control framework, larger and more complex credit institutions …
------+92. In the implementation of the control framework, smaller and less complex credit institutions …
------+5.3.1 First line of defence controls
---------+93. Credit institutions should ensure that the first line of defence is embedded into the …
---------+94. In order to ensure that adequate control mechanisms are implemented, credit institutions should …
------+5.3.2 Second line of defence controls
---------+95. Second line of defence functions should perform controls on a continuous basis to check that …
---------+96. The second line of defence controls the implementation of risk management measures by the NPE …
---------+97. Risk control and compliance functions should also provide guidance on the process of designing …
------+5.3.3 Third line of defence controls
---------+98. The third line of defence, the independent internal audit function, should have sufficient NPE …
---------+99. With regard to the NPE framework, the internal audit function should, at least, perform regular …
---------+100. In determining the frequency, scope and scale of the controls to be carried out, credit …
---------+101. Based on the results of its controls, the internal audit function should make recommendations …
---+5.4 Monitoring of NPEs and NPE workout activities
------+102. The monitoring systems should be based on the NPE targets approved in the NPE strategy and …
------+103. Credit institutions should define and monitor NPE-related KPIs. The NPE-related KPIs, should …
------+5.4.1 NPE metrics
---------+104. Credit institutions should closely monitor the relative and absolute levels of NPEs and FBEs …
---------+105. Credit institutions should carry out such monitoring activities at transaction/borrower level …
---------+106. Credit institutions should monitor the level of impairments of NPEs in order to provide the …
---------+107. Credit institutions should benchmark indicators related to the NPE ratio and coverage against …
---------+108. Credit institutions should monitor their deviations from the budget, in order for the …
---------+109. Key figures on NPE inflows and outflows should be included in periodic reporting to the …
---------+110. Credit institutions should consider if it would be useful to establish migration matrices to …
---------+111. Credit institutions should estimate the migration rates and the quality of the performing …
---------+112. In their monitoring activities, credit institutions should use internal information (e.g. from …
------+5.4.2 Borrower engagement and cash collection
---------+113. Once NPE WUs have been established, key operational performance metrics should be implemented …
------+5.4.3 Forbearance activities
---------+114. To resolve or limit the impact of NPEs, credit institutions should explore the possibilities …
---------+115. The main objective of forbearance measures should be the return of the borrower to a …
------+5.4.4 Liquidation activities
---------+116. If no sustainable restructuring solution can be reached, credit institutions should still …
---------+117. Liquidation activities should be monitored by the credit institution to help inform strategies …
---------+118. Credit institutions should monitor the volumes and recovery rates of legal and foreclosure …
---------+119. For exposures covered by collateral or another type of guarantee, credit institutions should …
---------+120. Monitoring the recovery rates from foreclosure and other legal proceedings should help credit …
---------+121. Credit institutions should also monitor the average duration of legal procedures recently …
---------+122. Credit institutions should carefully monitor cases where the debt is swapped with an asset or …
------+5.4.5 Other monitoring items
---------+123. Credit institutions should monitor and report to their management bodies the amount of …
---------+124. If foreclosure is a part of a credit institution’s NPE strategy, it should also monitor the …

5. NPE governance and operations

5. NPE governance and operations

1. Forbhreathnú

,
Teideal Rialáil
58. In order for credit institutions to be able to address their NPE issues in an efficient and …

In order for credit institutions to be able to address their NPE issues in an efficient and sustainable manner, an appropriate governance structure and operational set-up should be in place.

59. This section sets out the key elements of governance and operations in relation to an NPE …

This section sets out the key elements of governance and operations in relation to an NPE workout framework, covering aspects related to steering and decision-making, the NPE operating model, the internal control framework and NPE monitoring processes.

60. In the implementation of their NPE governance and operations, credit institutions should take …

In the implementation of their NPE governance and operations, credit institutions should take into account relevant consumer protection considerations and requirements, and ensure fair treatment of consumers.

5.1 Steering and decision-making

5.1 Steering and decision-making

5.2 NPE operating model

5.2 NPE operating model

5.3 Control framework

5.3 Control framework

5.4 Monitoring of NPEs and NPE workout activities

5.4 Monitoring of NPEs and NPE workout activities

1.1 Tagairtí

1.2 Ceanglais aitheanta

1.3 Caighdeáin ghaolmhara

2. Ceanglais aitheanta

Ceanglais
Foinse Ceanglas

3. Caighdeáin ghaolmhara

Caighdeáin
Foinse Ceanglas
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