CM-1.6.6
(a) Scale and drivers of the NPL problem:
(i) The size and evolution of NPL portfolio on an appropriate level of granularity, which requires appropriate portfolio classification as outlined in Section 1.8;
(ii) The drivers of NPL in-flows and out-flows, by portfolio where relevant; and
(iii) Other potential correlations and causations.
(b) Outcomes of NPL actions taken in the past:
(i) Types and nature of actions implemented, including forbearance measures; and
(ii) The success of the implementation of those activities and related drivers, including the effectiveness of forbearance treatments.
(c) Operational capacities (processes, tools, data quality, IT/automation, staff/expertise, decision-making, internal policies, and any other relevant areas for the implementation of the strategy) for the different process steps involved, including, but not limited to:
(i) Early warning and detection/recognition of NPLs;
(ii) Forbearance;
(iii) Provisioning;
(iv) Collateral valuations;
(v) Recovery/legal process/foreclosure;
(vi) Management of foreclosed assets (if relevant); and
(vii) Reporting and monitoring of NPLs and effectiveness of NPL workout solutions.
Added: June 2022