Comment on the review of the NPL transaction data templates (EBA/DP/2021/02)

GBIC expressly supports the revision of the NPL transaction data templates with the aim of a simpler, more proportionate and more effective design in order to achieve a broader application and increase transparency in the NPL market. However, even considering the general intention as well as the recommendations from the EBA's cost-benefit analysis for reducing costs in the reporting system, we view the introduction of new mandatory reporting or data requirements very critically. Rather, relief should be offered that will cut administrative effort. We therefore strongly advocate maintaining the voluntary application of the data templates so as to limit the institutions' administrative burden.