In this article, we hope to provide you with general guidance on how to report loans affected by COVID-19.  Specifically, these reporting practices should reflect (i) legislative payment moratoria or (ii) payment relief initiated as part of a sector-wide moratorium scheme coordinated by the banking industry and agreed by bondholders. The terms of the payment moratoria may differ across countries, particularly in duration but potentially also in scope (interest and/or principal payments). In general, the following four rules apply across all asset classes for the ECB ABS templates and taxonomies:

1. Report all template fields with the most recent information available irrelevant if the field is labelled as static or dynamic in the taxonomy (examples are borrower employment status, primary income, loan maturity, current balance in case fees or interests have been capitalised or the corresponding date of most recent arrears capitalisation) There are two exceptions. Please DO NOT update Identifiers or Fields where “original” is part of the field name (e.g. original balance, loan origination date or OLTV). These fields should, and must, remain static
2. Use optional fields (if applicable) – especially Length of Payment Holiday, Subsidy Period, Restructuring Arrangement or Guarantee Provider
3. Additional documents can be uploaded under each deal in the document section that explain any kind of particularities in the reporting and treatment of borrowers due to Covid-19. Issuers are kindly asked to upload an excel file to the securitisation repository (ED) with the list of all Loan Identifiers affected by the moratorium for the relevant PCD
4. Regarding all contracts which have not entered into a payment agreement and are therefore expected to make normal payments, please continue reporting everything as usual.

In addition, we have received questions regarding how to report certain key fields during this crisis for contracts which have entered into a legislative or sector-wide payment agreement in the scope of Covid-19. Please find an overview describing how to report the fields mostly requested for each asset class below.

RMBS TEMPLATE

• Payment Due (AR71): If the contract is under payment holiday, then please enter the amount that will be payable on the borrower’s next occurring payment date i.e. zero. If there is a suspension for only the principal or the interest payment, Scheduled Payment Due (AR71) should reflect the special payment arrangement and only the interest or principal part is to be reported.
• Account Status (AR166): The account status (particularly “arrears”, “performing”, and “default”) needs to be consistent with the definition in the relevant transaction documentation.
• Length of Payment Holiday (AR92)(optional): Report the remaining number of months as of PCD. The length of Payment Holiday should be measured since the cut-off date, going forward only. For example, for a loan that previously went through a payment holiday period but is no longer enjoying that payment holiday should be filled in with 0.
• Restructuring Arrangement (AR122)(optional): Report as ‘Y’ if applicable as per transaction documentation.
• Principal Grace Period (AR62): This field must not be used to report loans under Covid-19  as it is stated in the ECB Q&As that AR62 refers only to the start of the loan (i.e. from the origination date) when the borrower may initially only be required to make interest payments for a period (e.g. for 2 years) before then becoming a repayment loan making payments of both interest and principal. This field does not refer to any principal grace period granted at a later date.

SME TEMPLATE

• Regular Principal Instalment (AS63): Please enter the amount that will be payable on the borrower’s next occurring payment date, zero or positive if only interest is covered by the payment holiday.
• Regular Interest Instalment (AS64): Please enter the amount that will be payable on the borrower’s next occurring payment date. This number should be zero or positive if only principal is covered by the payment holiday.
• Principal Grace Period End Date (AS70): This field must not be used to report loans under Covid-19 as it is stated in the ECB Q&As that this field is static and therefore refers only to grace periods granted at the commencement of the loan. It does not refer to any forbearance granted at a later date.

AUTO TEMPLATE

• Scheduled Payment Due (AA28): Please enter the amount that will be payable on the borrower’s next occurring payment date i.e. zero. If there is a suspension for only the respective principal or the interest payment, Scheduled Payment Due (AA28) should reflect the special payment arrangement and only the interest or principal part is to be reported.
• Account Status (AA74): The account status (particularly “arrears”, “performing”, and “default”) needs to be consistent with the definition in the relevant transaction documentation.

LEASING TEMPLATE

• Payment Due (AL61): Please enter the amount that will be payable on the borrower’s next occurring payment date i.e. zero. If there is a suspension for only the respective principal or the interest payment, Payment Due (AL61) should reflect the special payment arrangement and only the interest or principal part is to be reported.
• Account Status (AL122):  The account status (particularly “arrears”, “performing”, and “default”) needs to be consistent with the definition in the relevant transaction documentation.

Consumer template

• Scheduled Payment Due (AN27): Please enter the amount that will be payable on the borrower’s next occurring payment date (i.e. zero if there is a loan holiday). If there is only a suspension for only the respective principal or the interest payment, the Scheduled Payment Due (AN27) should reflect the special payment arrangement and only the interest or principal part is to be reported.
• Account Status (AN58): The account status (particularly “arrears”, “performing”, and “default”) needs to be consistent with the definition in the relevant transaction documentation.

Credit Card template

• Next Minimum Contractual Payment (AT38): Please enter the amount that will be payable on the borrower’s next occurring payment date i.e. zero. If there is a suspension for only the principal or the interest payment, Payment Due (AT38) should reflect the special payment arrangement and only the interest or principal part is to be reported.
• Account Status (AT42): The account status (particularly “arrears”, “performing”, and “default”) needs to be consistent with the definition in the relevant transaction documentation.