Response to EBA's consultation on proposed Guidelines on management of non-performing and forborne exposures

UK Finance has responded to the European Banking Authority's consultation on its proposed Guidelines on management of non-performing and forborne exposures.

We supported the development of the Guidelines (GLs), whilst observing that Non-Performing or Foreborne Exposures are not a significant  issue for UK banks.

We noted however that the implementation deadline of 1 January 2019 may be testing, particularly as the GLs are unlikely to be finalised until q 3 of this year. This would particularly be the case if they were applied too prescriptively, in a way that required banks to change there long established, and effective processes for managing delinquent loans.

We also expressed a concern that the GLs assume a portfolio approach based to NPE management, which is not appropriate for commercial loans, which are often ?worked-out? on a case by case basis.