In June 2019, the EBA launched a consultation on a set of draft guidelines on loan origination and monitoring in response to a mandate under the Council action plan on non-performing loans (NPLs) from July 2017. At that time, the critical mass of NPLs and an objectively insufficient regulatory framework were raising doubts about the sustainability of the NPL stock for EU banks. Since then, however, considerable progress has already been made both at supervisory level and at regulatory level. Furthermore, the evaluation of the Consumer Credit Directive is ongoing, and a review of the Mortgage Credit Directive is also planned.

Against this background and taking into account the principles of proportionality and subsidiarity, the need for high-quality EU legislation that is fit for purpose without unnecessary layers of complexity, and the fact that the EBA draft guidelines on loan origination and monitoring have been published at a time when many other relevant initiatives have already been or are being taken:

1. Are these guidelines in the suggested form really necessary to achieve the objectives pursued?

2. Has the Commission considered that introducing the guidelines at this stage could create considerable inefficiencies in bank processes, waste scarce resources, and generate confusion for clients who would be confronted with continuous changes in terms, conditions and lending procedures?

3. With a view to ensuring consistency, coordination and simplicity, is the Commission planning to ask the EBA to align the timing and the content of the guidelines with its own work programme on level I legislation in both the consumer and the prudential area?