Rischio di credito 2.0

Abstract

The EBA Guidelines on loan origination and monitoring (hereinafter "GL LOM") undoubtedly represent a substantially new piece of the banking regulatory framework. In fact, for the first time, the regulator moves into a topic that was traditionally outside the scope of financial regulation, so far almost exclusively focused on aspects directly linked to both micro- and macro-prudential stability, notably through capital and liquidity management requirements and guidelines on Business Model and Internal Governance. The credit management process, and in particular loan origination and monitoring, has always been typically considered as a business issue under sole responsibility of banks, as it is considered one of the "core" processes (if not the "core" process) of the banking business. As a matter of fact, since the issue of the capital requirement regulation (i.e., Basel II and Basel III), and the introduction of the use requirements for the rating systems, the regulator moved very close, but not yet, to prescribe specific credit assessment criteria, while dictating methodological and organizational requirements for the authorization of the rating systems, and leaving substantial freedom to banks to define their own models and embedded assessment criteria and indicators. With the GL LOM, the regulator takes a further step, remarkably beyond its traditional remit, dictating principles and rules for the evaluation of the credit quality of borrowers. The starting point for this new approach from the regulator can be found in the ECB guidelines on Non-Performing Loans, later endorsed by the Bank of Italy Guidelines for Less Significant Banks, aimed at encouraging banks to define their NPL management processes and establish reduction plans to achieve NPL ratio targets in line with the regulator's expectations. Consistently with the focus on NPL, the regulation on Calendar Provisioning, amending the CRR was issued; as being a Regulation, it involves all banks, and not only significant ones (for which the ECB Addendum also applies). In addition, the new definition of default (the so-called "new Dod") has defined stricter criteria for the transition of exposures to the default status and also made the return of "cured" exposures to the performing status more difficult. The combined effect of these regulatory changes has been to make the default of counterparties not only more probable but also much more "expensive" for the banks. The natural “next step” of these regulatory changes was to "move backward" into the management process covering loan origination and monitoring . The EBA's stated objective with the issuance of the GL LOM is to define "robust and prudent" standards of lending practices so as to maintain a low level of NPLs in the future. Therefore, the focus of the GL LOM is the definition of requirements (some outlined as prescriptions, others in terms of principles) for the creditworthiness assessment of counterparties and for the management of the related data and information. Notwithstanding the fact that the Final Report has articulated the principle of proportionality much more clearly as compared to the Consultation Paper, the GLs set out three macro-categories of counterparties for which specific requirements are defined: • Individuals • Micro and small businesses • Medium and large companies. The GL LOM also provide recommendations about the valuation of guarantees both at origination and during ongoing monitoring, encouraging the use of advanced statistical models. The GL LOM focus on real estate guarantees, while financial collateral is outside the scope of the GL LOM. In the mind of the regulator, the GL LOM should not only reflect industry practices, but also incorporate the latest supervisory guidance on lending, and provide the stimulus to include ESG, AML/CTF and the use of innovative technologies into banking origination and, where applicable, monitoring processes.