Technical resources
In terms of adequate technical infrastructure, credit institutions should ensure that all NPE-related data are centrally stored in robust and secure IT systems and that they are complete and up to date throughout the NPE workout process.
An adequate technical infrastructure should enable NPE WUs to:
a) Access all relevant data and documentation, including:
current NPE and early arrears borrower information, including automated notifications;
exposure, collateral and guarantee information linked to the borrower or connected clients;
monitoring tools with the IT capabilities to track forbearance performance and effectiveness;
status of workout activities and borrower interaction, as well as details on forbearance measures agreed;
foreclosed assets, where relevant;
tracked cash flow of the loan and collateral;
sources of underlying information and complete underlying documentation;
where relevant, access to central credit registers, land registers and other external data sources.
b) Efficiently process and monitor NPE workout activities, including:
automated workflows throughout the entire NPE life cycle;
ii. an automated monitoring process for loan status, ensuring correct flagging of NPEs and FBEs;
iii. incorporated warning signals;
iv. automated quantitative reporting throughout the NPE workout life cycle as a basis for the analyses to be provided to NPE WU management, the management body and other relevant managers, as well as the regulator;
v. performance analyses of workout activities by NPE WUs, sub-teams and experts (e.g. cure/success rate, rollover information, effectiveness of restructuring options offered, cash collection rate, vintage analyses of cure rates, promises kept rate at call centre, etc.);
vi. evolution monitoring of portfolios, subportfolios, cohorts and individual borrowers.
c) Define, analyse and measure NPEs and related borrowers:
recognise NPEs and measure impairments;
ii. perform suitable NPE portfolio analyses and store outcomes for each borrower;
iii. support the assessment of the borrower’s personal data, financial position and repayment ability, at least for non-complex borrowers;
iv. conduct calculations of (i) the net present value and (ii) the impact on the capital position of the credit institution for each restructuring option and/or any likely restructuring plan under any relevant legislation (e.g. foreclosure law, insolvency law) for each borrower.
The adequacy of the technical infrastructure, including data quality, should be assessed by an independent internal or external audit function on a regular basis.