5. Reporting and monitoring
5.1 Who is responsible for monitoring the agreement?
The National Bank of Belgium has set up a monitoring system with Febelfin to monitor the establishment of moratoria and loans to businesses and individuals in general, and the banks’ commitments under the guarantee schemes in particular.
Sanctions apply if a bank abuses or fails to respect its commitments.
5.2 How is the monitoring of both guarantee schemes organised (global cap, cap by bank, cap on counterparty, reporting method (template), information channel, …)?
By extending the reporting to BECRIS with 2 features:
- First guarantee scheme:
- Inclusion of an attribute in the characteristics of the credit instrument that explicitly states (i) whether or not the instrument has been selected and (ii) the associated fee.
- Second guarantee scheme:
- Inclusion of an attribute in the characteristics of the protection stating that it is a Covid-19 State guarantee
- Since it is not possible to declare protection that does not exist and this protection is optional, it is not explicitly mentioned that no use is made of the guarantee.
5.3 Should the borrower be recorded in the CICR as defaulting for the duration of the payment delay?
No. To this end, an exemption from Article VII.133 of the Code of Economic Law was provided for in Royal Decree No 11 of 22 April 2020 on measures regarding the terms and conditions of mortgage loans in the context of the coronavirus crisis.
5.4 Is the bank under a declaration/reporting obligation in regard to the guaranteed loans under both guarantee schemes?
Yes, see question 5.2. The “reporting specification” and “validation checks” that have to be added in the BECRIS reporting were communicated by the NBB to the sector on 3 April 2020.
5.5 Regarding the calculation of the € 50 million limit of the first guarantee scheme, must each Belgian lender in the syndicate declare its share or should there be overall reporting for the syndicate as a whole?
Each Belgian lender in the syndicate reports its own share.
5.6 How will the follow up of the requests with regard to the guaranteed credits, requested by the Parliament, be organized?
Each bank should keep a register in which all requests with regard to the guaranteed credits are held, including the identity of the business entity formulating the request and the requested amount. The result of each request also needs to be registered. Credit institutions shall have to submit monthly reports to the NBB containing information on the total credit requests received and the result of these requests. Detailed information on the requirements regarding the submission was communicated in the course of April.
5.7 Is it possible to obtain an exhaustive overview of the different questions of reporting towards the NBB and the Treasury?
The fiche “Reporting and Monitoring” was formalized in a charter between the different parties involved (sector, NBB and Treasury).