Country Comparison

Modify selection

download excel sheet

Questions	Armenian Covered Bonds	Asset Covered Securities - ACS	Australian Covered Bonds	Austrian Pfandbriefe	Belgian Covered Bonds	Bonos Garantizados (CH, CT, CI)	Bulgarian Covered Bonds	Caisse de Refinancement de l'Habitat - CRH	Canadian Covered Bonds	Contractual Law Based Covered Bonds	Czech Covered Bonds	Danish Covered Bonds	Dutch registered CBs programmes	Estonian Covered Bonds	Finnish Covered Bonds	Greek Covered Bonds	Hungarian Covered Bonds	Icelandic Covered Bonds	Latvian Covered Bonds	Lithuanian Covered Bonds	New Zealand Covered Bonds	Norwegian Covered Bonds	Obbligazioni Bancarie Garantite - OBG	Obligations à L'Habitat - OH	Obligations Foncières - OF	Obligatiuni garantate - Covered Bonds	Pfandbriefe	Polish Covered Bonds	Regime Jurídico das Obrigações Cobertas	Singapore Covered Bonds	Slovak Covered Bonds	South Korean Covered Bonds	Swedish Covered Bonds	Swiss Pfandbriefe	UK Covered Bonds
I. STRUCTURE OF THE ISSUER
1. Who is the issuer?	Universal credit institution Banks and credit organizations	Special credit institution / Special purpose entity		Universal credit institution with a special licence	Universal credit institution with a special licence A universal credit institution needs to obtain a general and a specific license for the issuance of Belgian covered bonds.	Universal credit institution	Universal credit institution The issuer is a bank authorised to pursue banking business under the Bulgarian Credit Institutions Act.	Universal credit institution with a special licence CRH-Caisse de Refinancement de l'Habitat	Universal credit institution See National Housing Act 21.52 and Canadian Registered Covered Bond Guide section 2.2	Universal credit institution Valiant Bank AG	Universal credit institution	Special credit institution / Special purpose entity "Special credit institution / Special purpose entity" covers Danish mortgage banks and Danish ship finance institutions which are specialised banks. Universal credit institutions with a special licence are also allowed to issue covered bonds.	Universal credit institution	Universal credit institution with a special licence The company wishing to issue covered bonds must hold the authorisation of credit institution and an additional authorisation to issue covered bonds.	Universal credit institution Also: Special credit institution / Special purpose entity	Universal credit institution	Special credit institution / Special purpose entity	Universal credit institution	Universal credit institution The cover assets of the CBs are segregated from the other assets of the credit institution issuing the bonds in a special purpose vehicle (SPV).	Universal credit institution with a special licence		Special credit institution / Special purpose entity Norwegian Covered Bonds are issued by credit institutions with special licences.	Universal credit institution	Special credit institution / Special purpose entity Société de Financement de l'Habitat	Special credit institution / Special purpose entity Société de Crédit Foncier	Universal credit institution	Universal credit institution with a special licence Since the PfandBG 2005, the issuer does not need to be a specialised bank.	Special credit institution / Special purpose entity	Universal credit institution	Universal credit institution Also "Special credit institution / Special purpose entity". Covered bonds can be issued by either a bank or a SPV.	Universal credit institution with a special licence No special banking licence but prior approval from the regulator for any covered bond programme is required	Universal credit institution Banks licensed under the Bank Act, Korea Development Bank, Korea Eximbank, Industrial Bank of Korea, NH Bank, Suhyup Bank each of which with equity capital of not less than KRW 100 billion and BIS ratio of not less than 10%, Korea Housing Finance Corporation	Universal credit institution with a special licence	Special credit institution / Special purpose entity The purpose of the Pfandbrief institutes (PB and PZ) is to enable mortgages for real estate owners at interest rates which are as constant and favourable as posssible (Article 1 Pfandbrief Act). Pfandbrief institutes have a highly restricted scope of business (Article 5 Pfandbrief Act).	Universal credit institution with a special licence Issuer must be a licensed deposit taker and registered with the FCA as a covered bond issuer
2. Does the bondholder have recourse to the issuer (in case of special issuer: recourse to the sponsor bank)?	Direct	Direct		Direct	Direct	Direct	Direct	Direct	Direct	Direct	Direct	Direct	Direct	Direct The terms of covered bonds must not restrict the holder's right of recourse.	Direct	Direct	Direct	Direct	Direct	Direct The investors are granted the dual recourse right. Therefore, the credit institution, as the issuer, has a direct responsibility for redemption, but the cover pool is ring-fenced in the SPV and the issuer’s creditors do not have any claim rights against it.		Direct Bond holders have recourse to the covered bond issuing credit institution	Direct	Direct	Direct	Direct	Direct There is no direct legal link between cover assets and Pfandbriefe. All obligations from the Pfandbriefe are obligations of the issuing bank as a whole, to be paid from all the assets of the issuing bank. Only in the case of insolvency, the cover pool is isolated from the general insolvency estate.	Direct	Direct	Direct In the case of an SPV issuing, the recourse would be indirect.	Direct	Direct For further comments, please see comments section at the end of the questionnaire	Direct	Indirect Security Chain: The bondholder has a direct recourse to the issuing Pfandbrief institute (Articles 27 - 31 Pfandbrief Act) and an indirect recourse to the member banks. The member banks cover assets secure for the loans granted by the Pfandbrief institute to the member bank.	Direct
3. Who owns the cover assets?	The issuer directly	The issuer directly		The issuer directly And "Others" based on EU-CBD Art 9 Joint Funding	The issuer directly	The issuer directly	The issuer directly	Others* (*e.g. credit institution pledges to issuer, capitalized legal entity etc.) Borrowing institutions/CRH's shareholders, but pledged to CRH (transfer of ownership to the issuer upon default without any formality)	SPE which guarantees the bonds	SPE which guarantees the bonds	The issuer directly	The issuer directly	SPE which guarantees the bonds The legal ownership of the assets is transferred to the SPE (Covered Bond Company).	The issuer directly	The issuer directly	The issuer directly	The issuer directly Motgage banks have the legal licence for both own origination of mortgage loans and refinancing commercial banks' (purchasing independent/separated mortgage lien') mortgage lending. In the refinancing scheme-pooling-original loans remain in the originator bank's balance sheet.	The issuer directly	SPE which guarantees the bonds As of alienation of asset, payments, claims, rights and assets received by issuer/alienor in relation to cover asset belong to a CBs company.	SPE which guarantees the bonds the cover assets owned by the SPV must be supervised by a cover pool monitor		The issuer directly	SPE which guarantees the bonds	Others* (*e.g. credit institution pledges to issuer, capitalized legal entity etc.) Issuer directly, or other credit institution, but pledged to the issuer (which transfer to the issuer upon trigger event)	Others* (*e.g. credit institution pledges to issuer, capitalized legal entity etc.) The issuer directly, or credit institution, but pledged to the issuer (which transfer to the issuer upon trigger event)	The issuer directly	The issuer directly	The issuer directly	The issuer directly	SPE which guarantees the bonds Collateral transferred to the SPV in a manner that ensures they are beyond the issuer's and its creditors' reach, even in an insolvency situation.	The issuer directly	The issuer directly	The issuer directly	Others* (*e.g. credit institution pledges to issuer, capitalized legal entity etc.) The Pfandbrief institute uses the proceeds raised through Swiss Pfandbrief issuance and pass them on to the member banks who originated the eligible mortgage loans. The underlying mortgages remain on the member bank's balance sheets, but PB and PZ receive a lien on the eligible cover assets.	SPE which guarantees the bonds
4. Is the issuer the originator of the cover assets?	Yes, partly (external origination possible)	Yes, partly (external origination possible)		Yes, partly (external origination possible)	Yes, partly (external origination possible) External origination is possible if the conditions in art 4 of Annex III of the Banking Law are met.	Yes, partly (external origination possible) External origination legally posible but very rare in practise	Yes, partly (external origination possible)	No 5 banking groups as sponsors and also shareholders, originate the cover assets (domestic residential mortgages only): BNPP, BPCE, Crédit Agricole, Crédit Mutuel, Société Générale	Yes, partly (external origination possible) Where the cover asset (mortgage loan) is not originated by issuer, the mortgage loan must comply with registered issuer's approved underwriting policies	Yes, solely	Yes, solely	Yes, partly (external origination possible) Joint funding of other credit institutions mortgage loans is possible.	Yes, solely The issuer or group entitities of the issuer.	Yes, partly (external origination possible) Primary cover assets may only be the issuer's claims, subtitute collateral may also include other cover assets.	Yes, partly (external origination possible) Instituitions belonging to the same group may be originators	Yes, partly (external origination possible)	Yes, partly (external origination possible) In case of refinancing (mortgage loans) the original mortgage loan remains in the loan book of the partner bank, but at the same time the 're-purchase price' of the independent mortgage lien provides the cover pool asset at the mortgage bank's balance sheet.	Yes, solely	Yes, partly (external origination possible)	Yes, partly (external origination possible)		Yes, partly (external origination possible) Loans are originated partly by the issuer, partly acquired from parent bank or from another bank.	Yes, partly (external origination possible)	No	No The sponsor bank originates the assets.	Yes, partly (external origination possible)	Yes, partly (external origination possible) A Pfandbrief bank as a funding vehicle only is not allowed.	Yes, solely Polish Mortgage Banks can own originated loans as well as purchased (true sale) from parent bank.	Yes, partly (external origination possible) Notwithstanding Article 16 of Decree-law 31/2022 allowing ‘joint funding’, general market practice has been issuer being sole credit originator	Yes, solely	Yes, partly (external origination possible) In addition to assets originated by issuing bank also assets originated by bank subsidiary or by other bank that meets the definition of primary asset and that has been transferred to issuing bank or provided to it under financial collateral agreement meeting the requirements of special regulations	Yes, partly (external origination possible)	Yes, partly (external origination possible) Origination is mostly done by issuer	No Originators of the underlying mortgage loans are the member banks. The Pfandbrief institutes issue the Swiss Pfandbriefe to refinance their member banks mortgage loans.	Yes, solely
II. COVER ASSETS & TRANSPARENCY
1. What type of assets may be included in the cover pool?	Exposures to public sector entities Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Substitution assets Commercial mortgage loans Mortgage assets Substitution assets Derivatives Other 1	Exposures to public sector entities Public sector assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Exposure to Private Participation in Infrastructure (PPI) or Private Finance Initiative (PFI) where public sector is conditional Public sector assets Exposures to multilateral development banks Public sector assets Derivatives Public sector assets Mortgage assets		Exposures to public sector entities Public sector assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Ship loans Other 1 Derivatives Substitution assets Exposures guaranteed by public sector entities (CRR 129 (1) a) Public sector assets Assets pursuant to CRR Art 129 (1) Substitution assets Other 1 is "Ship assets". Primary Asset must be at least 85% of Coverage Requirements pursuant to §9 Austrian CB Law.	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Derivatives Other 1	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Export finance loans Other 1 Cédulas internacionalización (Others 1) are a sub-type of public sector CB distinguished by their purpose of financing initiatives related to the internaziolitation of entrepreneurs. They are CRR compliant.	Exposures to public sector entities Public sector assets Exposures to credit institutions Mortgage assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Senior MBS issued by third parties Mortgage assets Group originated MBS Mortgage assets Ship loans Other 1 Exposures to multilateral development banks Public sector assets Derivatives Public sector assets Exposures to institution with 1st rank of credit quality under Chapter 2, Section 2 of CRR. Substitution assets	Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets For further comments see Comments box at the end of the questionnaire	Residential mortgage loans Mortgage assets Derivatives Mortgage assets "Government of Canada securities Repos of Government of Canada securities" Other 1 Other 2 Substitution assets Derivates are exclusively for hedging purposes.	Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets	Exposures to public sector entities Public sector assets Other 1 Substitution assets Exposures to credit institutions Public sector assets Other 1 Substitution assets Residential mortgage loans Mortgage assets Other 1 Substitution assets Commercial mortgage loans Mortgage assets Other 1 Substitution assets Senior MBS issued by third parties Mortgage assets Other 1 Substitution assets Ship loans Other 1 Substitution assets Exposures to multilateral development banks Public sector assets Other 1 Substitution assets Derivatives Other 1 Substitution assets Other eligible assets pursuant to Article 129(1)(a-b) of the CRR Public sector assets Other 1 Substitution assets Other eligible assets pursuant to Article 129(1)(d-f) of the CRR Mortgage assets Other 1 Substitution assets (other than eligible assets pursuant to Article 129(1)(a-b) and Article 129(1)(d-f) of the CRR) Other 1 Substitution assets Other 1 is "mixed assets". Further comments in the last section at the end of the questions list.	Exposures to public sector entities Public sector assets Mortgage assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Ship loans Other 1 Derivatives Substitution assets Internal issued covered bonds Other 2 Collateral in ships is not an option for mortgage banks. For further information please see comments section at the end of the questionnaire.	Exposures to public sector entities Public sector assets Exposures to credit institutions Public sector assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Exposures to credit institutions which are members of a system of mutual guarantee Public sector assets Exposures to multilateral development banks Public sector assets Legislation requires that at least 80% of the cover pool shall consist of one type of the primary cover assets.	Exposures to public sector entities Other 1 Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Other 1 Commercial mortgage loans Mortgage assets Other 1 Exposures to credit institutions which are members of a system of mutual guarantee Substitution assets Exposures to multilateral development banks Substitution assets Derivatives Substitution assets Credit Debt securities Other1 is "mixed assets". The types of covered bonds under Estonian law are (i) mortgage covered bond; and (ii) the mixed asset covered bond.	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Loans to housing association without mortgage Mortgage assets Exposures to credit institutions which are members of a system of mutual guarantee Substitution assets Exposures to multilateral development banks Public sector assets Derivatives Other 1	Exposures to public sector entities Public sector assets Exposures to credit institutions Other 1 Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Group originated MBS Mortgage assets Exposures to multilateral development banks Public sector assets Derivatives Other 1	Exposures to credit institutions Mortgage assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Derivatives Other 1 Bonds from: government, government guaranteed, supranational, other issuers Substitution assets Special part of the grant mortgage loan secured by gvt guarantee according to mortgage bank act Other 2 For further information please see the comments section at the end of the questionnaire.	Exposures to public sector entities Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Exposure to Private Participation in Infrastructure (PPI) or Private Finance Initiative (PFI) where public sector is conditional Substitution assets	Exposures to public sector entities Public sector assets Exposures to credit institutions Public sector assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Ship loans Other 1 Loans to housing association without mortgage Mortgage assets Exposure to Private Participation in Infrastructure (PPI) or Private Finance Initiative (PFI) where public sector is conditional Substitution assets Exposures to multilateral development banks Public sector assets Other 1 is "maritime assets". Other than primary and substitution, these may be included: 1) issuer's loans to covered bond company for purchasing primary and substitution assets; 2) derivatives; 3) funds obtained from primary/substitution assets or derivatives; 4) collateral related to derivatives.	Exposures to public sector entities Public sector assets Exposures to credit institutions Public sector assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Exposure to Private Participation in Infrastructure (PPI) or Private Finance Initiative (PFI) where public sector is conditional Substitution assets Derivatives Substitution assets Other high-quality assets classified as eligible assets by the Lithuanian FSA Cover assets pool may also include other high-quality assets classified as eligible by the Lithuanian FSA in accordance with Article 129 of the CRR		Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Loans to housing association without mortgage Mortgage assets Exposures to multilateral development banks Substitution assets Derivatives Substitution assets The Norwegian covered bond legislation states that for OMF premium the assets in the cover pool will have to comply with the requirements in art. 129 CRR.	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Other 1 Substitution assets Residential mortgage loans Mortgage assets Substitution assets Commercial mortgage loans Mortgage assets Substitution assets Ship loans Other 1 Substitution assets Exposures to multilateral development banks Other 1 Substitution assets Derivatives Other 1 Substitution assets Liquid assets eligible for liquidity buffer Other 1 Substitution assets High-quality liquid assets pursuant to the delegated regulation n. 2015/61; short-term exposures with matuity until 90 days to credit institutions that qualify for CQS 1 or 2 or short-term deposits to credit institutions that qualify for CQS 1, 2 or 3.	Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets For further details see Comments box at the end of the questionnaire	Exposures to public sector entities Public sector assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets For further info please see the Comments box at the end of the questionnaire.	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Other 1 Substitution assets Residential mortgage loans Mortgage assets Substitution assets Commercial mortgage loans Mortgage assets Substitution assets Derivative contracts may be included as well in the cover pool but only for hedging purposes.	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Ship loans Other 1 Aircraft loans Other 2 Exposures to multilateral development banks Public sector assets Substitution assets Export finance loans Public sector assets Derivatives Substitution assets	Exposures to public sector entities Public sector assets Residential mortgage loans Public sector assets	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Other 1 Commercial mortgage loans Mortgage assets Other 1 Senior MBS issued by third parties Substitution assets Group originated MBS Other 1 Substitution assets Exposure to Private Participation in Infrastructure (PPI) or Private Finance Initiative (PFI) where public sector is conditional Public sector assets Exposures to credit institutions which are members of a system of mutual guarantee Public sector assets Exposures to multilateral development banks Public sector assets Derivatives Public sector assets Mortgage assets Substitution assets can be non-primary eligible EEA assets, deposits with Bank of Portugal, bank deposits, or other low-risk highly liquid assets	Residential mortgage loans Mortgage assets Derivatives Substitution assets Other Substitution assets For further comments, please see Comments section at the end of the questionnaire.	Exposures to public sector entities Public sector assets Substitution assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Exposures to multilateral development banks Substitution assets Other Other 1 Substitution assets Primary assets category "Others 1" means loans to/guaranteed by public undertakings	Exposures to public sector entities Public sector assets Exposures to credit institutions Substitution assets Residential mortgage loans Mortgage assets Senior MBS issued by third parties Mortgage assets Group originated MBS Mortgage assets Exposures to multilateral development banks Substitution assets Derivatives Other 1 For further comments, please see comments section at the end of the questionnaire	Almost all assets are mortgage loans.	Residential mortgage loans Mortgage assets Commercial mortgage loans Mortgage assets Bonds (Article 25 Pfandbrief Act) Substitution assets Only first class mortgages on properties in Switzerland are eligible (Article 19 and 34 - 36 Pfandbrief Act). Currently only residential properties (e.g. single-family houses, condominiums, multi-family houses) in the cover pools, even if commercial mortgages are permissible according to the law.	Residential mortgage loans Mortgage assets Wider range of assets or mixed assets are permitted, but to date all programmes are single use eg Housing Associalition loans
2. What is the geographical scope of assets?	Domestic Mortgage assets	Domestic Public sector assets Mortgage assets Substitution assets Multilateral development banks Public sector assets EU Public sector assets Mortgage assets Substitution assets EEA Public sector assets Mortgage assets Substitution assets CH Public sector assets Mortgage assets Australia Public sector assets Mortgage assets Canada Public sector assets Mortgage assets Japan Public sector assets Mortgage assets New Zealand Public sector assets Mortgage assets USA Public sector assets Mortgage assets		Domestic Public sector assets Mortgage assets Other 1 Substitution assets EEA Public sector assets Mortgage assets Other 1 Substitution assets UK Public sector assets Mortgage assets Other 1 Substitution assets CH Public sector assets Mortgage assets Other 1 Substitution assets Other 1 is "Ship assets"	EEA Mortgage assets OECD Public sector assets Substitution assets	Domestic Public sector assets Mortgage assets Substitution assets Assets are mainly domestic but other localitions are possible provided fulfilling with art 129 CRR	Domestic Public sector assets Mortgage assets Multilateral development banks Public sector assets EU Public sector assets Mortgage assets For further information please see comments section at the end of the questionnaire	Domestic Mortgage assets	Domestic Mortgage assets Canada Mortgage assets	Domestic Mortgage assets	Domestic Public sector assets Mortgage assets Other 1 Substitution assets Multilateral development banks Public sector assets Substitution assets EU Public sector assets Mortgage assets Other 1 Substitution assets EEA Public sector assets Mortgage assets Other 1 Substitution assets UK Public sector assets Other 1 Substitution assets CH Public sector assets Other 1 Substitution assets Australia Public sector assets Other 1 Substitution assets Canada Public sector assets Other 1 Substitution assets Japan Public sector assets Other 1 Substitution assets New Zealand Public sector assets Other 1 Substitution assets USA Public sector assets Other 1 Substitution assets OECD Public sector assets Other 1 Substitution assets G10 Public sector assets Other 1 Substitution assets	Domestic Mortgage assets Other 1 EU Mortgage assets Other 1 EEA Mortgage assets Other 1 UK Mortgage assets Other 1 CH Other 1 Australia Other 1 Canada Other 1 Japan Other 1 New Zealand Other 1 USA Other 1 OECD Other 1 G10 Other 1 Mortgages on real property situated abroad may form the basis of covered bond issuance.	EEA Public sector assets Mortgage assets In practice every programme solely uses Dutch residential mortgages as primary cover assets.	Domestic Mortgage assets Other 1 Substitution assets Multilateral development banks Substitution assets EU Mortgage assets Other 1 Substitution assets EEA Mortgage assets Other 1 Substitution assets UK Substitution assets CH Substitution assets Australia Substitution assets Canada Substitution assets Japan Substitution assets New Zealand Substitution assets USA Substitution assets OECD Substitution assets G10 Substitution assets Claims arising from a mortgage credit granted to a natural person against residential property situated in territory of another EEA country may only be used if mortgage provides creditor with protection equivalent to protection provided by a mortgage established under Estonian legislation.	EU Public sector assets Mortgage assets Other 1 Substitution assets EEA Mortgage assets	Domestic Public sector assets Mortgage assets Multilateral development banks Public sector assets EU Public sector assets Mortgage assets In principle non-EU assets will be permitted, but the Bank of Greece is empowered by law to introduce exceptions. Pending the issuance of secondary legislation by the BoG, it is unclear to what extent non-EU assets will be permitted.	Domestic Mortgage assets Substitution assets Multilateral development banks Substitution assets EU Mortgage assets Substitution assets EEA Mortgage assets Substitution assets OECD Substitution assets		Domestic Public sector assets Mortgage assets Other 1 Substitution assets Multilateral development banks Public sector assets EU Public sector assets Mortgage assets Other 1 Substitution assets EEA Public sector assets Mortgage assets Other 1 Substitution assets Other 1 is "Maritime assets".	EU Public sector assets Mortgage assets Substitution assets EEA Public sector assets Mortgage assets Substitution assets Assets can originate from third countries, when EU Commision recognises that the country apply at least similar finnacial/supervision requirements or the at least similar requirements for investors protection		Domestic Public sector assets Mortgage assets Other 1 Substitution assets Multilateral development banks Public sector assets Substitution assets EU Public sector assets Mortgage assets Other 1 Substitution assets EEA Public sector assets Mortgage assets Other 1 Substitution assets OECD Other 1 Substitution assets G10 Substitution assets Derivatives Other 1	Domestic Public sector assets Mortgage assets Substitution assets Multilateral development banks Public sector assets Substitution assets EU Public sector assets Mortgage assets Substitution assets EEA Public sector assets Mortgage assets Substitution assets UK Public sector assets Substitution assets CH Public sector assets Mortgage assets Substitution assets Australia Public sector assets Substitution assets Canada Public sector assets Substitution assets Japan Public sector assets Substitution assets New Zealand Public sector assets Substitution assets USA Public sector assets Substitution assets OECD Public sector assets Substitution assets G10 Public sector assets Substitution assets All the assets pursuant to art. 129 (1) of CRR are eligible, if specific requirements are met (consequently, both EU and third-country public sector entities exposures are potentially eligible). If the eligible assets are guaranteed by collateral, this should be located in EU, EEA or CH.	Domestic Mortgage assets EU Mortgage assets EEA Mortgage assets Other State benefiting from the highest level of credit assessment given by an external rating agency recognized by the ACPR	Domestic Public sector assets Mortgage assets EU Public sector assets EEA Public sector assets Mortgage assets Other Mortgage assets Mortgage assets: State outside EEA/ EU benefiting from the highest level of credit assessment. Public sector entity outside EEA/ EU must comply with specific limits and level of credit assessment given by an external rating agency recognized by the ACPR (minimum credit quality step 2)	Domestic Public sector assets Mortgage assets Other 1 Substitution assets EU Public sector assets Mortgage assets Other 1 Substitution assets	Domestic Public sector assets Mortgage assets Other 1 Other 2 Substitution assets Multilateral development banks Public sector assets Substitution assets EU Public sector assets Mortgage assets Other 1 Other 2 Substitution assets EEA Public sector assets Mortgage assets Other 1 Other 2 Substitution assets UK Public sector assets Mortgage assets Other 1 Other 2 Substitution assets CH Public sector assets Mortgage assets Other 1 Other 2 Substitution assets Australia Mortgage assets Other 1 Other 2 Canada Public sector assets Mortgage assets Other 1 Other 2 Substitution assets Japan Public sector assets Mortgage assets Other 1 Other 2 Substitution assets New Zealand Mortgage assets Other 1 Other 2 USA Public sector assets Mortgage assets Other 1 Other 2 Substitution assets OECD Other 1 Other 2 G10 Other 1 Other 2 Other Mortgage assets Other 1 Other 2 Ship and aircraft mortgages are allowed worldwide subject to speical criteria. Land mortgages in Singapore allowed as well for Mortgage Pfandbrief.	Domestic Public sector assets Mortgage assets EEA Public sector assets OECD Public sector assets For more information: Polish Covered Bond and Mortgage Banks Act, Art.3 para 4).	Multilateral development banks Public sector assets EU Public sector assets Mortgage assets Other 1 Other 2 Other 3 EEA Substitution assets	Domestic Mortgage assets Other Mortgage assets No restriction on geographical scope of the mortgage assets	Domestic Public sector assets Mortgage assets Other 1 Substitution assets Multilateral development banks Substitution assets EU Public sector assets Substitution assets EEA Substitution assets UK Substitution assets CH Substitution assets Australia Substitution assets Canada Substitution assets Japan Substitution assets New Zealand Substitution assets USA Substitution assets OECD Substitution assets G10 Substitution assets	Domestic Public sector assets Mortgage assets Multilateral development banks Substitution assets EU Substitution assets EEA Substitution assets UK Substitution assets CH Substitution assets Australia Substitution assets Canada Substitution assets Japan Substitution assets New Zealand Substitution assets USA Substitution assets OECD Substitution assets G10 Substitution assets	Domestic Public sector assets Mortgage assets Almost all assets in the pools have Swedish collaterals. Just two smaller pools have foreign assets (Nordic countries). EEA mortgage assets allowed in law.	CH Mortgage assets By law only domestic.	Domestic Mortgage assets A wider range is permitted but to date all are domestic
3. Is there a maximum level for substitute assets in the statutory national framework?	Yes, please specifiy 10%	Yes, please specifiy 15%			Yes, please specifiy 15% for credit quality step 1 and 2; 10% for credit quality step 2	Yes, please specifiy 10%	Yes, please specifiy max 15% of the principal amount of outstanding covered bonds	Yes, please specifiy 15% of the total amount of the issuer's liabilities benefiting from the privilège, including the aggregate of issued covered bonds	Yes, please specifiy 10% of all covered bond collateral	Yes, please specifiy 15% - Contractual obligations	Yes, please specifiy Please, see comments section at the end of the questionnaire	Yes, please specifiy No limits apply in general. Limits in CRR, Article 129 on credit institutions.	Yes, please specifiy 20% of the cover assets.	Yes, please specifiy Depending on an asset, 12-20%. Maximum per centage of the nominal value of the outstanding covered bonds in the covered bond portfolio that they cover	Yes, please specifiy 20% of the nominal value of the pool	Yes, please specifiy Under the Coverd Bond Law, substitution of assets and mixture of the cover pool is generally allowed (art. 14(4) in fine), subject to registering such replacement and the details of each replacement asset with the pledge registry of Greek law 2844/2000.	Yes, please specifiy The share of substitute assets may in no case be more than 20% of all mortgage bonds with remaining maturity of more than 180 days	Yes, please specifiy 20%	Yes, please specifiy Indirect limitation – at least 85% of cover assets must be primary assets.	Yes, please specifiy Substitution assets shall not exceed 20%; assets as provided for in Article 129(1)(c) shall not exceed 15% of collateral assets under relevant issue.		Yes, please specifiy Primary assets must represent the main portion of the cover pool. Subsitutions assets shall consist of the liquidity buffer, other eligible assets or derivative contracts.	Yes, please specifiy Substitution of eligible assets with other assets of the same kind is permitted if this is expressly set out in the issuance programme and term sheet. Supplementation is permitted solely to maintain coverage and/or liquidity requirements provided by national law and by the art. 129 of CRR.	Yes, please specifiy 15% of the total amount of the issuer's privileged liabilities.	Yes, please specifiy 15% of the total amount of the issuer's privileged liabilities	Yes, please specifiy 30%	Yes, please specifiy 20% for Mortgage Pfandbrief, Ship and Aircraft Pfandbrief; 15% for Public Sector Pfandbrief		Yes, please specifiy Substitution assets are subject to the limits set in Article 129	Yes, please specifiy Yes, 15%.	Yes, please specifiy 10% / 20% of the nominal value of issued covered bonds (depending on type of primary assets)	Yes, please specifiy 10%	No, substitute assets not allowed in general No longer a category of assets in Swedish law.	Yes, please specifiy If the statutory primary cover assets is not available in full and the deficiency cannot be remedied immediately, the cover shall be supplemented by debt securities of the Swiss Confederation, cantons or communes admitted to the Swiss Stock Exchange or by a cash deposit (Article 25 Pfandbrief Act).	No, substitute assets not allowed in general Liquid assets are restricted and do not count towards the minimum level of collateral
4. Are there any reporting requirements for covered bond issuers to investors?	Yes, by law	Yes, by law and in line with art. 14 of EU Covered Bond Directive		Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive Reporting is required as per Canadian Registered Covered Bond Guide and believed to be in line with article 14 of the EU Covered Bond Directive	Yes, contractual obligations	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive Quarterly disclose obligation about covered bond portfolios.	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	No reporting requirements by law There is no explicit requirement by law, but requirement for quarterly reporting is stipulated in Arion bank's covered bond licence	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive Additionaly to CBD, the Law of Covered Bond of the Repblic of Lithuania sets a requirement to provide investors with the information on the counterparties and the SPV; on stress testing scenarios and its results; other relevant information for the investor, as established by the Lithuanian FSA.		Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive The national law established a minimum set of information for investors, compliant with the CB Directive. Moreover, the disclosure can be also fulfilled through the publication of the ECBC Harmonised Transparency Templates (HTT), if they contain at least the information required by the law.	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law and in line with art. 14 of EU Covered Bond Directive According to § 28 I PfandBG issuers are obliged to publish on a quarterly basis information regarding nominal and NPV coverage, stress test and the cover pool assets.		Yes, by law and in line with art. 14 of EU Covered Bond Directive Decree-law DL 31/2022 Article 30	Yes, by law and in line with art. 14 of EU Covered Bond Directive Issuers are bound by law for timing of disclosures and are currently all reporting under the HTT template under the Covered Bond label.	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, by law Issuer and CoverPool monitor are required to submit quarterly reports to financial regulatory authority using report form setting out details relating to CBs and pool. Issuer is required to publish such information on relevant website and must include details as notes to annual report of such issuer	Yes, by law and in line with art. 14 of EU Covered Bond Directive	Yes, voluntary Since 2012, PB has published the "Pfandbriefbank Pool" with detailed info on a semi-annual basis. Swiss Banking law, Pfandbrief Act, Swiss Code of Obligations, ..., have further reporting requirements. New requirements expected to come with the national implementation of Basle 3 final.	Yes, by law and in line with art. 14 of EU Covered Bond Directive Regulatory reporting is believed to be in line with Article14 but until third country equivalence review is complete this cannot be formally confirmed
5. What is the frequency of reporting to investors?	Monthly	Quarterly		Quarterly	Monthly	Quarterly	Quarterly	Quarterly	Monthly	Monthly	Quarterly The relevant information is provided to investors at least on a quarterly basis (i.e. the issuers may report on a more frequent basis).	Quarterly	Monthly The law requires quarterly reporting but in practice banks report on a monthly basis.	Quarterly	Quarterly	Quarterly	Quarterly	Monthly Requirement from regulator is quarterly reporting. Arion reports monthly to investors	Quarterly	Quarterly Within one month after the end of the quarter		Quarterly	Quarterly	Quarterly	Quarterly	Quarterly	Quarterly		Quarterly Decree-law DL 31/2022 Article 30	Quarterly	Quarterly	Quarterly	Quarterly	Semi-annually The cover pool reporting is published on the website of the Pfandbrief institute.	Monthly
III. VALUATION OF THE MORTGAGE COVER POOL & LTV CRITERIA
1. What is the basis for property valuation	Market value	Market value		Mortgage lending value	Market value	Mortgage lending value	Market value Comparative, income and cost methods and other related to them applicable methods.	Market value	Market value Combination of mortgage lending value and market value under the Asset Coverage Test, as per Annex D of the Canadian Registered Covered Bond Guide	Market value Market value based on latest valuation	Market value Furthermore, the Czech covered bonds regulation allows property valuation on the basis of regular price (in Czech, cena obvyklá).	Market value	Market value Also, "Mortgage lending value". Both market value and mortgage lending value can be used but in practice, the value of Dutch property is based on the market value.	Market value The market value of the property standing as security for the credit shall be valuated by a valuator.	Market value Also: "Mortgage lending value"	Market value	Mortgage lending value	Market value Other: "Registers Iceland"	Market value	Market value		Market value	Market value	Market value	Market value	Market value	Mortgage lending value For further information please see comments box at the end of the questionnaire.		Market value Also: "Mortgage lending value". DL 31/2022 Article 10 (1) (a) current valuation amount only if no greater than the physical asset’s market value or mortgage lending value, done by qualified, independent and experienced valuer	Market value Valuation must be conducted at least annually, or on a more frequent basis where the property market is subject to significant changes in conditions.	Market value	Mortgage lending value	Market value	Mortgage lending value Article 19 and 34 - 36 Pfandbrief Act.	Market value
2. Is a regular update of the property value required?	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span		Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient	Yes, automated / indexed valuation sufficient External appraisal only necesary whenever an important depreciation takes place.	Yes, new external physical apraisal within a specific time span	Yes, automated / indexed valuation sufficient	Yes, automated / indexed valuation sufficient Quarterly by a disclosed recognized indexed. A registered Issuer must provide notice to CMHC of any change in an Index used.	Yes, new external physical apraisal within a specific time span but in general done by the client advisor after inspecting the property and confirmed using a third party valuation model (IAZI)	No	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient Monitoring and revalution of property values according to CRR Article 208, 3	Yes, automated / indexed valuation sufficient Property values are indexed quarterly. In general, house price decreases are fully taken into account whilst increases are only partially included.	Yes, new external physical apraisal within a specific time span Property value must be reviewed at least once a year and revaluated, if necessary.	Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient Physical apparaisal, statistical method including automated appraisal are allowed by law.	Yes, automated / indexed valuation sufficient The value of properties are valued annually based on official valuation from registers Iceland	Yes, automated / indexed valuation sufficient	Yes, automated / indexed valuation sufficient Market value indexation should be performed at least once a year, i.e. the loan-to-asset value ratio should be adjusted on an annual basis, unless higher indexation is provided in the covered bond programme or more frequent indexation is required by the cover pool monitor or the Lithuanian FSA.		Yes, automated / indexed valuation sufficient The property values are monitored quarterly using advanced statistical models	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient	Yes, automated / indexed valuation sufficient	Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span There is a monitoring of the property value. §26 BelWertV wants a review of underlying assumptions of the MLV, if there are hints that these could have deteriorated; especially, when market prices have declined substantially in a respective region. But, yearly valuation reports are not necessary.		Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient As per DL 59/2006 regulation (applicable until revoked by regulation issued under DL 31/2022), Article 208 CRR (3) and Article 129 (3) of CRR	Yes, automated / indexed valuation sufficient Not specified under MAS Notice, however contractually all issuers currently use indexed valuation in their covered pool reporting.	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient New external physical appraisal is required when changes are made to the subject of the lien	Yes, automated / indexed valuation sufficient	Yes, automated / indexed valuation sufficient	Yes, new external physical apraisal within a specific time span Yes, automated / indexed valuation sufficient The regulatory requirements for banks provide for an assessment of the loan at origination and a reassessment when the limit expires. Hedonic valuation methods are subject to qualitative and quantitative requirements. In times of rising prices, there is no compulsion to track the higher prices.	Yes, automated / indexed valuation sufficient Quarterly by a national recognised index
3. What are the LTV limits (single asset based)? Please specify in %/n.a.	Residential Commercial 70% LTV. If LTV exceeds 85%, then the issuer shall post additional collateral whose cash flows accrue to bondholders only if the issuer defaults.	Residential Commercial Residential: 75%; Commercial: 60%		Residential Commercial Residential 80%; Commercial 60%. Limits are directly referenced from CRR Art 129 (1) d) and f).	Residential Commercial Residential 80%; Commercial 60%. Value of a receivable is capped by the Value of Cover Asset mechanism.	Residential Commercial Residential 80%; Commercial 60%	Residential Commercial Other assets According to the respective originators internal policies and requirements. No specific requirements were included in the Ordinance No42 adopted by Bulgarian National Bank.	Residential Commercial By law: Residential 80%LTV ; Commercial 60% LTV . No Commercial exposures allowed in CRH.	Residential Residential LTV limit 80%	Residential Residential 80%	Residential Commercial Agricultural All:100%.Specific coll value applies to eligible assets pursuant Art129(1)-(2) CRR as cover assets.Lower limit set in conditions of CBs contractually.	Residential Commercial Agricultural Ships Residential 80%; Commercial 60%; Agricultural 60%; Ships 60%. The LTV limit for commercial and agricultural can be raised to 70% if the bank adds additional collateral.	Residential Commercial Ships Residential 80%. Commercial 60%. Ships 60%. No additional limits on portfolio basis applicable. There is the possibility for the LTV ratio to rise to 70% for commercial mortgage loans.	Residential Commercial Other assets Residential 70%; Commercial 60%; Housing construction credit 60%.	Residential Commercial Residential 80%; Commercial 60%	Residential Commercial Ships Residential 80%; Commercial 60%; Ships 60%	Residential Commercial Residential 70%; Commercial 60%	Residential Commercial Agricultural Residential 80%; Commercial 60%; Agricultural 70%	Residential Commercial Agricultural Ships Other assets Additional limits on portfolio basis applicable? Residential 70%; Commercial 60%; Agricultural N/A; Ships 60%; Other N/A	Residential Commercial Residential 70%; Commercial 60%		Residential Commercial Other assets Residential 80%. Commercial 60%. 60% for leisure property mortgages. It is possible as per the art. 129 (CRR) to increase LTV for commercial to 70%, subject to increased OC requirements	Residential Commercial Ships Residential: 80%; Commercial: 60 or 70%; Ships: 60%. Comment: The same LTV limits provided by the art. 129 of CRR.	Residential Residential 80%	Residential Commercial Other assets Residential 80%; Commercial 60%; Other (Public assets) 100%	Residential Commercial Residential: 80% if compliant with art 129 of CRR and 85% LTV at origination for high quality assets Commercial: 60% if compliant with art 129 of CRR and 70% LTV at origination for high quality assets No additional limits on portfolio basis applicable	Residential Commercial Agricultural Ships Other assets All limits 60%. Other assets (Aircraft) 60%.		Residential Commercial Agricultural Ships Other assets Residential 80%; Commercial 60%; Agricultural n/a; Ships 60%; Other assets: Commercial 70%, conditional to programme keeping minimum 10% overcolateralisation	Residential Residential 80%. No additional limits on portfolio basis applicable.	Residential Commercial Other assets Residential 80% (CRR compliant assets); Commercial 60% / 70% (if conditions under CRR Art.129 par. 1(f) are met); Other 70% LTV for high quality assets according to Art.6 par.1 b) CBD; 100% LTV only if loan pledged with mortgage real estate in compliance with CRR	Residential Ships Other assets Residential 70%; Ships 70%; Other: Aircraft 70%	Residential Commercial Additional limits on portfolio basis applicable? Residential 80%; Commercial 60%. LTV limits follow article 129(1) in CRR. There is an additional limit for commercial assets other than agricultural assets, which may not exceed 10 % of the cover pool.	Residential Commercial Residential max. 66 2/3 % or lower, ..., commercial max. 40 % or lower (Article 34 - 36 Pfandbrief Act; Schätzungsreglement).	Residential Residential 80%
4. Are loans in excess of LTV limits eligible for inclusion in the cover pool?	No (hard limit)	Hard limit upon inclusion but soft limit accepted following inclusion		Yes (soft limit)	Yes (soft limit) Value of a receivable is capped by the Value of Cover Asset mechanism.	Hard limit upon inclusion but soft limit accepted following inclusion	Other, please specify Not specified	Yes (soft limit)	Hard limit upon inclusion but soft limit accepted following inclusion The portion of the loan which exceeds the 80% LTV would not be counted in coverage ratios, but can remain in the pool after inclusion in the cover pool, so covered bond holders would get benefit of that portion exceeding 80% LTV.	Hard limit upon inclusion but soft limit accepted following inclusion	Yes (soft limit)	Hard limit upon inclusion but soft limit accepted following inclusion	Yes (soft limit) Any difference between the actual (higher) LTV and the 80% maximum will serve as additional credit enhancement.	Yes (soft limit) So called relative LTV, which determines how much of the amount of credit may be taken as a collateral.	Hard limit upon inclusion but soft limit accepted following inclusion	Yes (soft limit)	No (hard limit)	Hard limit upon inclusion but soft limit accepted following inclusion	No (hard limit)	No (hard limit)		Hard limit upon inclusion but soft limit accepted following inclusion It is not required to remove the loan from the cover pool once included. When testing OC, only the part of the loan up to LTV-limit, is eligible.	No (hard limit)	Yes (soft limit)	Yes (soft limit)	Hard limit upon inclusion but soft limit accepted following inclusion For loans compliant with art 129 of CRR, the respective LTV provisions will apply. In case of high quality assets, LTV at origination of the loan must be observed (85%/70% residential/commercial) at inclusion in the covered pool. Thereafter, soft limits are accepted.	Yes (soft limit) No absolute lending limit only relative: mortgage loans may have higher LTV than 60 % but only the part of the loan up to 60 % LTV is part of the cover pool.		Yes (soft limit)	Yes (soft limit) Loans in excess of LTV limits can be included in the cover pool, but all amounts above 80% will not be given benefit under the ACT calculations.	Hard limit upon inclusion but soft limit accepted following inclusion	No (hard limit) Portion of the assets which exceed the required LTV shall not be eligible cover asset but shall be treated as being part of the Cover Pool unless the Cover Pool registration with respect to such portion of assets are cancelled. The right of priority shall also not be affected.	Yes (soft limit)	Yes (soft limit) LTV limits cap the cover value of an asset.	Yes (soft limit) The value of loans is subject to an individual haircut to restrict it to 80% in coverage testing
IV. ASSET-LIABILITY GUIDELINES
IV.1 Derivative contracts in the cover pool
1. Are derivative contracts eligible for the inclusion in the cover pool?	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)		Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (contractual obligations)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law) Restrictions on termination are applied by the law.	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)		Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)		Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	Yes, exclusively for hedging purposes (by law)	No Member Banks: Derivatives are possible contents in some of the mortgage products.	Yes, exclusively for hedging purposes (by law)
2. Are there requirements for derivative contracts (e.g. eligibility criteria for hedging counterparties)?	Yes, specified in law	Yes, specified in law		Yes, specified in law Derivative Counterparty has to consent explicitly to the entry into the cover pool	Yes, specified in law	Yes, specified in law Hedging counterparties must be creditit institution with specific credit quality mentioned in art. 129.1 c)CRR	Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, by contract The use of derivative hedge instrumtents is allowed under the programme but has not been used until yet.	Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, specified in law BoG to determine eligibility criteria. Determination still pending	Yes, specified in law Mortgage loan companies permitted to engage in derivative transactions for reasons of liquidity, risk management operations, only for hedging purposes	Yes, specified in law	Yes, specified in law	Yes, specified in law		Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, specified in law	Yes, specified in law		Yes, specified in law	No Not specified under MAS Notice, contractually governed.	Yes, specified in law	Yes, by contract	Yes, specified in law	No Member Banks: Derivatives possible as part of the mortgage product.	Yes, specified in law Must be formally documented with FCA guidance on credit risk
3. Will derivative contracts remain in case of insolvency of the issuer?	Yes	Yes		Yes	Yes	Yes	Yes	Yes	Yes Programs are required to include Ratings Triggers for collateralization and/or guarantee of hedges by suitably rated counterparty.	Yes	Yes	Yes	Yes	Yes After sepration, counterparties' claims to the derivative instruments in the register are satisfied on the pool account, proceeds to be then received.	Yes	Yes	Yes Mortgage loan company undergoes liquidation: liabilities of derivative instruments (collateral security) not deemed payable at opening of proceedings.	Yes	Yes	Yes		Yes	Yes	Yes	Yes	Yes	Yes For further information please see comments box at the end of the questionnaire.		Yes	Yes	Yes	Yes	Yes	Yes Not applicable, as there are no standalone derivative contracts in the cover pool.	Yes
4. If derivatives are permitted in the cover pool, what is their ranking?	Pari passu to covered bond holders	Pari passu to covered bond holders		Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Not applicable	Pari passu to covered bond holders	Pari passu to covered bond holders Canadian Registered CB Guide section 4.5.6 (b) states that the terms of each hedge must preclude the Counterparty from ranking in priority to the covered bondholders' entitlement to receive interest payments and for so long as an issuer event of default has occurred and is continuing.	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders		Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders		Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Pari passu to covered bond holders	Not applicable Member Banks: Derivatives possible for mortgage contracts. Pfandbrief institution: Subject to compliance with Financial Market Infrastructure Act.	Pari passu to covered bond holders
IV.2 Exposure to market risk
1. What is the primary method for the mitigation of market risk?		Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments		Other Credit institution must have appropriate risk management system in place. System must ensure the identification, assessment, management and monitoring of all risks associated with covered bond business, such as in particular market risks, interest rate and currency risks, credit and liquidity risks.	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments	Use of derivative hedging instruments A Valuation Calculaton measuring present value of the covered bond collateral relative to the CAD dollar equivalent of the market value of the outstanding covered bonds guaranteed by it (without regard for such derivatives) is also conducted and disclosed to investors.	Other “Natural” hedging combined with overcollateralisation	'Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing is ordinarily used as well.	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments Danish mortgage banks have in practice structured their mortgage lending business in such a way that they have nearly eliminated market risk.	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing An increasing number of programs/pools use 'natural' hedging although there are still programs/pools that make use of derivatives.	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments		Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments		Use of derivative hedging instruments	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Use of derivative hedging instruments	Use of derivative hedging instruments Computation of OC under certain stress scenarios.	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing		Use of derivative hedging instruments	Use of derivative hedging instruments	Use of derivative hedging instruments	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Where the cover pool consists of mortgages, any mortgages in arrears will be calculated by applying certain ratios and the other assets shall be valued using market values. Any assets which are not eligible assets and any derivative instruments entered into for hedging purposes shall be valued at '0	Not specified in framework and it differs between issuers.	Natural' matching (i.e. match funding, matching without the use of off-balance sheet instruments) and stress testing Other Pfandbrief Institute: By law matching principle for loans to member banks and Swiss Pfandbriefe, as both are denominated in CHF and have the same terms. Member banks: High overcollateralisation and member banks duty to provide additional cover, if nominal or interest coverage is not complied.
2. Are there mitigating provisions for interest rate risk?	Yes, by legislation/regulation Stress testing requirements are defined in the Central bank Bylaw	Yes, by legislation/regulation		Other see IV.2.1	Yes, by legislation/regulation The issuer needs to report to the regulator on a quarterly basis on the results of interest rate risk stress tests	Yes, by legislation/regulation tests mandatory	No	Yes, by legislation/regulation	Yes, by legislation/regulation Canadian Registered CB Guide section 4.5.	Other Overcollateralisation	No	Yes, by legislation/regulation	Yes, by legislation/regulation Derivatives and/or 'natural' hedging can be used.	Yes, by legislation/regulation	Yes, by legislation/regulation	Yes, by legislation/regulation BoG to determine relevant rules. This is still pending.	Yes, by legislation/regulation The provisions related to mitigating interest rate risk can be found in the Act CLXII of 2009 on Consumer Credit	Yes, by legislation/regulation	Yes, by legislation/regulation	Yes, by legislation/regulation		Yes, by legislation/regulation	No	Yes, by legislation/regulation	Yes, by legislation/regulation	Yes, by legislation/regulation	Yes, by legislation/regulation		No	Other Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	Yes, by legislation/regulation	No	Yes, by legislation/regulation	Yes, by legislation/regulation Matching Principle on the balance sheet of the Pfandbrief institute. Interest coverage requirement for member banks: Interest on cover assets must exceed interest on loans from Pfandbrief institute.	Yes, by legislation/regulation
3. Are there mitigating provisions for foreign exchange risk?	Yes, by legislation/regulation A pool shall consist of assets denominated in a single currency.	Yes, by legislation/regulation		Other see IV.2.1	Yes, by legislation/regulation The issuer needs to report to the regulator on a quarterly basis on the results of foreign exchange risk stress tests (if applicable)	Yes, by legislation/regulation tests mandatory	No	No		Other The use of derivative instruments is allowed under the programme but has not been used until yet, since no foreign exchange risk	No	Yes, by legislation/regulation	Yes, by legislation/regulation Derivatives can be used.	Yes, by legislation/regulation	Yes, by legislation/regulation	No	Yes, by legislation/regulation	Yes, by legislation/regulation	Yes, by legislation/regulation	Yes, by legislation/regulation		Yes, by legislation/regulation	No	No	No	Yes, by legislation/regulation	Yes, by legislation/regulation		No	Other Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	Yes, by legislation/regulation	Yes, by legislation/regulation For further comments, please see comments section at the end of the questionnaire	Yes, by legislation/regulation	Yes, by legislation/regulation All contracts of the Swiss Pfandbrief collateral chain have to be denominated in Swiss Francs.	Yes, by legislation/regulation
4. Are there mitigating provisions for maturity mismatch risk?	Yes, by legislation/regulation	Yes, by legislation/regulation		Other see IV.2.1	No	Yes, by legislation/regulation tests mandatory	No	Yes, by legislation/regulation	Yes, by legislation/regulation Pre-maturity tests are designed to ensure the CB collateral includes sufficient cash to satisfy in full the Canadian dollar equivalent of all principal payments due under series of hard-bullet CB. It is common for Canadian Issuers to issue soft-bullet CB with extendable maturities of 12 months.	Other Overcollateralisation	No	Yes, by legislation/regulation	Yes, by legislation/regulation Also, "Other". Issuers have issued long(er)-dated, fixed-rate covered bonds to match maturity/interest rate profile of the assets.	Yes, by legislation/regulation	Yes, by legislation/regulation	No This could change upon issuance of BoG decision.	Yes, by legislation/regulation Mortgage Funding Adequacy Ratio-20/2021. IV.23) Hungarian National Bank Decree-regulation	No	Yes, by legislation/regulation	Yes, by legislation/regulation		No	Yes, by legislation/regulation Active Portfolio Management and ALM techniques aiming to assure the matching between assets and liabilities' maturities	Yes, by legislation/regulation	Yes, by legislation/regulation	No	No No requirements on maturity mismatch risk. PfandBG requires Pfandbriefe are covered on NPV even in case of interest rate and currency movements.		No	Other Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	No	No	Yes, by legislation/regulation	Other Matching principle: Pfandbrief Act requires capital cash flow matching between loans to member banks and Swiss Pfandbriefe. Member banks: High overcollateralisation and usualy longer average maturity on the refinancing side than for the mortgage loans.	Yes, by legislation/regulation
5. What type of coverage test is applied?	Nominal cover; Present value cover; Other (Cash flow matching requirements)	Present value cover		Other, please specify Nominal cover mandatory by law, additional optional present value cover (pursuant to Art 15 (6))	Nominal cover	Nominal cover	Nominal cover		Nominal cover Present value cover Nominal coverage in Asset Coverage Test and minimum OC Calculation. Present value coverage in the Valuation Calculation.	Nominal cover		Nominal cover Other, please specify CDB coverage requirement plus CRR OC minimum requirement	Nominal cover		Nominal cover Present value cover	Nominal cover Pending the decision of the BoG.	Nominal cover Present value cover	Nominal cover Present value cover	Nominal cover			Nominal cover	Nominal cover Other, please specify Other: Net present value; Interest coverage test	Nominal cover		Nominal cover Present value cover	Nominal cover Present value cover		Nominal cover	Nominal cover	Other, please specify For further details see comments section at the end of the questionnaire		Nominal cover Present value cover	Nominal cover Other, please specify 1. Nominal cover (for each member bank: cover value AND pricipal value of cover assets must exceed nominal value of loans from Pfandbrief institute incl. OC) 2. Interest cover (see "mitigation provisions for interest rate risk")
6. Are there stress scenarios applied?	Yes, other Central bank regulation	Yes, by law		No see IV.2.1	Yes, by law	Yes, by law	Yes, by law	No	Yes, by law Unless the interest rate risk is mitigated, a negative carry factor must be applied to the asset value, for the Asset-Coverage-Test. Programs are required to prescribe a cash reserve requirement for all obligations in a prescribed period below a Ratings Trigger (as specified in the Program)	No	No	Yes, by law Balance principle which provides limits to the scope of differences allowed on one hand the payments from borrowers and on the other hand the payments to the holders of the covered bonds.	No	Yes, by law	Yes, other Regulation	No Pending the decision of the BoG.	Yes, by law	Yes, by law	Yes, by law	Yes, by law Stress scenarios shall be defined by Lithuanian FSA		Yes, by law Yes by law and other. Stress tests are required to test the value cover and the liquidity risk as well as interest rate changes. Issuers also typically stress test for instance declining house prices.	Yes, other The portfolio is weighted for taking in account payment holidays, arrears, etc.	No	No	Yes, by law Computation of over collateralisation under stress scenarios, i.e. shocks to the yield curve, EUR-RON exchange rate, payment patterns, housing prices decrease, the loss given default in real estate enforcement, is mandatory by law.	Yes, by law For further information please see comments box at the end of the questionnaire.		No	Yes, other Contractually governed. Stress tests on affordability and property valuation are regularly performed by issuers.	Yes, by law	No	Yes, by law	No Extremely conservative framework (low LTV levels, haircuts, high OC, replacement and supplementation duty, several diversification levels,...). Outstanding historical track. No loss since the Pfandbriefgesetz entered into force (1931).	Yes, by law
IV.3 Liquidity risk
1. Is exposure to liquidity risk mitigated?	Yes, by law	Yes, by law		Yes, by law	Yes, by law	Yes, by law	Yes, by law	Yes, by law	Yes, by law and contractual obligations. See above regarding Pre-maturity liquidity tests and Cash Reserve requirements.	Yes, contractual obligations	No	Yes, by law	Yes, both by law and contractual	Yes, by law	Yes, by law Regulation	Yes, by law	Yes, by law		Yes, by law	Yes, by law		Yes, both by law and contractual Norwegian covered bonds issued pre 8 July 2022 normally have contractual soft bullet terms. CVBs issued under the new legislation post 8 July have objective triggers based on law.	Yes, both by law and contractual	Yes, by law	Yes, by law	Yes, by law	Yes, by law		Yes, by law	Yes, contractual obligations Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	Yes, by law	Yes, contractual obligations For further comments, please see comments section at the end of the questionnaire	Yes, by law	Yes, by law 1) Pfandbrief institute: Capital cash flow matching principle + several provisions to protect timely payment in case of member banks insolvency + liquidity buffer: substantial free HQLA assets (SNB GC); 2) Risk management include cash flow concentration limits and other key figures.	Yes, both by law and contractual
2. What liquidity risk mitigation requirements are in place (principal)?	Matching requirements 90 days liquidity provision applies to the combined amount of interest and priciple payments	180 days liquidity provisions		180 days liquidity provisions Maturity extension provisions Matching requirements	Maturity extension provisions Stress testing requirements	180 days liquidity provisions Maturity extension provisions Stress testing requirements	180 days liquidity provisions	180 days liquidity provisions Maturity extension provisions Matching requirements Other, please specify Liquidity lines provided by CRH's shareholders	Maturity extension provisions Contractual pre-maturity test Other, please specify Similar to "180 days liquidity provisions" Cash reserve requirements are required to be prescribed and triggered at a Ratings Trigger for a period specified in the program. Hard bullets require pre-maturity tests and are required by the Guide and contractual obligations. Soft bullets dominate.	Maturity extension provisions	180 days liquidity provisions Other, please specify optional maturity extension provisions	180 days liquidity provisions Maturity extension provisions Matching requirements Stress testing requirements Other, please specify Other: LCR and for mortgage banks LCR national pillar 2 requirement, incl. stressed haircut on HQLA. 180 days requirement does not apply to covered bonds subject to match funding	180 days liquidity provisions Maturity extension provisions Contractual pre-maturity test	180 days liquidity provisions Maturity extension provisions Matching requirements Stress testing requirements Regarding matching requirements, cover pool administrator has an obligation to actively carry out asset-liability matching.	180 days liquidity provisions Maturity extension provisions Stress testing requirements	180 days liquidity provisions Maturity extension provisions	180 days liquidity provisions Maturity extension provisions From July 08, 2022 in accordance with EU directive implementation	180 days liquidity provisions	180 days liquidity provisions Maturity extension provisions Stress testing requirements	180 days liquidity provisions Maturity extension provisions		180 days liquidity provisions Maturity extension provisions Norwegian covered bonds issued pre 8 July 2022 normally have contractual soft bullet terms. CVBs issued under the new legislation post 8 July have objective triggers based on law.	180 days liquidity provisions Maturity extension provisions Contractual pre-maturity test	180 days liquidity provisions Maturity extension provisions Matching requirements	180 days liquidity provisions Maturity extension provisions Matching requirements	180 days liquidity provisions	180 days liquidity provisions Maturity extension provisions Pfandbrief issuer are obliged to cover the maximum liquidity gap within the next 180 days since 2009.		180 days liquidity provisions Maturity extension provisions DL 31/2022 Article 19: calculation of principal for issues of extendable maturity bonds is based on final maturity date, subject to the relevant terms and conditions	Other, please specify Other: Contractual arrangements, e.g. maturity extension or 12 months prematurity test for hard bullets. Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	180 days liquidity provisions Maturity extension provisions Stress testing requirements	Maturity extension provisions Contractual pre-maturity test	180 days liquidity provisions Maturity extension provisions Matching requirements Stress testing requirements	Other, please specify Risk management and limits include: 1) Law requires capital cash flow matching between loans to member banks and Swiss Pfandbriefe; 2) Substantial free HQLA assets (SNB GC eligible); 3) Cash flow concentration limits and other key figures.	Maturity extension provisions Contractual pre-maturity test Stress testing requirements Hard bullets have pre-maturity tests. Soft bullets predominate
3. What liquidity risk mitigation requirements are in place (interest)?	Matching requirements 90 days liquidity provision applies to the combined amount of interest and priciple payments	180 days liquidity provisions		180 days liquidity provisions Matching requirements	180 days liquidity provisions Stress testing requirements	180 days liquidity provisions Maturity extension provisions Stress testing requirements	180 days liquidity provisions Reserve fund requirements	180 days liquidity provisions Maturity extension provisions Matching requirements	Maturity extension provisions Reserve fund requirements Cash reserve requirements are required to be prescibed and trigger at a Ratings Trigger for a period specified in the program. Soft bullets apply unless there is a Pre-Maturity Liquidity Test.	Reserve fund requirements Liquidity funding requirements after the occurance of a liquidity reserve event	180 days liquidity provisions	180 days liquidity provisions Maturity extension provisions Matching requirements Stress testing requirements Other, please specify Other: LCR and for mortgage banks LCR national pillar 2 requirement, incl. stressed haircut on HQLA. 180 days requirement does not apply to covered bonds subject to match funding,	180 days liquidity provisions Maturity extension provisions	180 days liquidity provisions Maturity extension provisions Matching requirements Stress testing requirements	180 days liquidity provisions Stress testing requirements	180 days liquidity provisions Maturity extension provisions	180 days liquidity provisions Maturity extension provisions	180 days liquidity provisions	180 days liquidity provisions Matching requirements Stress testing requirements	180 days liquidity provisions Maturity extension provisions		180 days liquidity provisions	180 days liquidity provisions Maturity extension provisions Reserve fund requirements Reserve fund requirements are usually required by the rating agencies	180 days liquidity provisions Maturity extension provisions Matching requirements	180 days liquidity provisions Maturity extension provisions Matching requirements	180 days liquidity provisions	180 days liquidity provisions		180 days liquidity provisions Maturity extension provisions Reserve fund requirements	Other, please specify Other: Contractual arrangements, e.g. establishment of a reserve fund. Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	180 days liquidity provisions Stress testing requirements	Reserve fund requirements	180 days liquidity provisions Maturity extension provisions Matching requirements Stress testing requirements	Other, please specify Risk management and limits include: 1) Law requires capital cash flow matching between loans to member banks and Swiss Pfandbriefe; 2) Substantial free HQLA assets (SNB GC eligible); 3) Cash flow concentration limits and other key figures.	Reserve fund requirements Stress testing requirements
4. What is the consequence of not fixing a breach of liquidity risk mitigants?	Administrative penalty	No new covered bond issuance Administrative penalty		Administrative penalty	Other, please specify Potential loss of covered bond license	No new covered bond issuance Administrative penalty No new cover bond issuance normally will be adopted but this measure has not an explicit legal recognisition	Administrative penalty	No sale of assets No new covered bond issuance Event of default	No new covered bond issuance Event of default Other, please specify Canadian Registered CB Guide 3.5.2 (c) & (d) specifies reserve fund and pre-maturity test requirements. If registered Issuer fails to remedy material breach, CMHC can suspend issuance. Terms of Programs would provide that failure to comply with the requirements constitutes an Event of Default.	No new covered bond issuance Event of default The breach will trigger an issuer event of default	No new covered bond issuance Administrative penalty The breach may serve a trigger for extended maturity structure. Contractually, the breach may also be an event of default.	Administrative penalty	No new covered bond issuance Administrative penalty	Administrative penalty Other, please specify Other: The additional authorisation can be revocated e.g. If the issuer has repeatedly or materially violated the provisions of Covered Bonds Act.	Administrative penalty	No new covered bond issuance Administrative penalty	Administrative penalty From July 08, 2022 in accordance with EU Covered Bond (2019/2162) directive implementation	No new covered bond issuance	Administrative penalty The following sanctions are possible: 1) revocation of authorization for the covered bond programme; 2) public statement on violation; 3) warning; 4) monetary fine; 5) restrictions or complete recall from office for the officials.	Administrative penalty		Administrative penalty Other, please specify Breach must be notified to the FSA as well as a plan for fulfilling requirements. FSA has the option to impose sanctions.	No sale of assets No new covered bond issuance Administrative penalty	No sale of assets No new covered bond issuance Event of default	No sale of assets No new covered bond issuance Event of default	Administrative penalty	Other, please specify Breach of liquidity risk mitigants not allowed. Violation of legal req. could lead to measures by financial supervision authorities and license loss.		Administrative penalty	Other, please specify Other: Contractual arrangements, typically an event of default. Contractually governed. MAS Notice requires regular stress tests on risks including default, prepayment, currency, interest rate, counterparty and liquidity risks.	Administrative penalty Other, please specify The measure of last resort is the potential withdrawal of the prior consent of the regulator to issue covered bonds and obligation of the issuing bank to sell/transfer the programme to other bank	No new covered bond issuance Event of default A breach of liquidity risk mitigants constitues Issuer Event of Default	Administrative penalty	Other, please specify Law based action by the Swiss Financial Market Supervisory Authority (FINMA). A breach of liquidity risk mitigants is not allowed as the liquidity buffer is stipulated by law.	No new covered bond issuance Event of default Beach of ACT can be fixed in a timely manner and is not an automatic default
5. If 180 days liquidity provisions are in place, what types of liquid assets are eligible		Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)		LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3) Any assets pursuant to Art 129 (1) c	LCR Level 1 Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	Other, please specify Although not 180 liquidity provision, cash reserve requirements (discussed above which apply for a period prescribed by the Program), provide that they will be funded in cash.		LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3) From July 08, 2022 in accordance with EU Covered Bond (2019/2162) directive implementation	Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b		LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3) Other, please specify Other: accepted by the National Bank of Romania for money market operations	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2)		LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3)	Other, please specify Other: Contractual arrangements. Not specified under MAS Notice, contractually governed.	LCR Level 1 LCR Level 2a LCR Level 2b Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2)		LCR Level 1 LCR Level 2a Short term exposures to credit institutions (Credit Quality Step (CQS) 1) Short term exposures to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 1) Short term deposits to credit institutions (CQS 2) Short term deposits to credit institutions (CQS 3) Under certain conditions it is possible for the supervisor to allow CQS 3.	Other, please specify Risk management and limits include: 1) Law requires capital cash flow matching between loans to member banks and Swiss Pfandbriefe; 2) Substantial free HQLA assets (SNB GC eligible); 3) Cash flow concentration limits and other key figures.
6. If 180 days liquidity provisions are in place, the calculation of principal is based on:	The (extended) legal final maturity date	The (extended) legal final maturity date		The (extended) legal final maturity date The extended maturity date may only apply for the liquidity buffer, if the extension is triggered. Otherwise the contractual maturity applies	The (extended) legal final maturity date	The (extended) legal final maturity date	The (extended) legal final maturity date	The expected maturity date Also: "The (extended) legal final maturity date"	The expected maturity date Although not 180 liquidity provision, the cash reserve must satisfy in full the Canadian dollar equivalent of all interest payments due under all series or tranches of CB outstanding together with all payment obligations of the guarantor ranking prior to such interest payments.		The expected maturity date No clear point. From the interpratetive materials, it seems that the Czech Rep did not use a discretion in Article 16(5) of the CBD.	The (extended) legal final maturity date	The (extended) legal final maturity date	The (extended) legal final maturity date	The (extended) legal final maturity date	The (extended) legal final maturity date	The expected maturity date	The expected maturity date	The (extended) legal final maturity date	The (extended) legal final maturity date		The (extended) legal final maturity date	The (extended) legal final maturity date	The expected maturity date Also: "The (extended) legal final maturity date"	The expected maturity date Also: "The (extended) legal final maturity date"	The expected maturity date	The expected maturity date Maturity extension must not be considered when calculating the 180 days liquidity.		The (extended) legal final maturity date		The expected maturity date		The (extended) legal final maturity date	The expected maturity date The contractual maturity date of Pfandbrief issuances (only hard bullet), Pfandbrief loans to member banks and mortgages.
IV.4. Maturity extension
1. Is maturity extension allowed by national law?	Yes but optional The Administrator may stop paying up to 3 months after the event of insolvency	Yes but optional		Yes, but optional and subject to conditions	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions Pre-maturity liquidity test required for hard-bullet covered bonds. Soft bullets dominate.	Yes, required Required by contractual provision if non-discretionary conditions have been met	Yes, but optional and subject to conditions	Yes, required Covered bonds issued by a specialised ship finance institute are not required by law to have an extension trigger (soft bullet structure)	Yes, but optional and subject to conditions Maturity extension is not possible at discretion of the issuer.	Yes, but optional and subject to conditions	Yes but optional	Yes but optional	Yes, but optional and subject to conditions From July 08, 2022. The maturity extension is subject to objective triggers specified by the issuer in advance in the Final Terms.	Yes but optional	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions		Yes, but optional and subject to conditions Maturity extension is based on predefined triggers (specified in the legislation) and FSA approval.	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions	Yes, but optional and subject to conditions	No	Yes, required Detailed provisions (§ 30 Pfandbrief Act)		Yes, but optional and subject to conditions	Yes but optional Not specified under MAS Notice, contractually governed.	Yes, but optional and subject to conditions	Yes but optional	Yes but optional	Yes, but optional and subject to conditions Swiss Pfandbriefe are usually hard bullet. Soft bullet contractual terms have been used in the past in the form of private placements ("Limmat transaction").	Yes, but optional and subject to conditions
2. Is it possible to issue…	Hard bullet	Hard bullet Soft bullet		Hard bullet Soft bullet	Hard bullet Soft bullet	Hard bullet Soft bullet	Soft bullet	Hard bullet Soft bullet	Hard bullet Soft bullet	Soft bullet	Hard bullet Soft bullet	Hard bullet Soft bullet	Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet	Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet Soft bullet is an option from July 8, 2022. Soft bullet issuance is based on the issue program definition.	Hard bullet Soft bullet Conditional pass-through	Conditional pass-through	Soft bullet Conditional pass-through		Hard bullet Soft bullet	Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet	Hard bullet	Soft bullet		Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet Conditional pass-through As a AAA-rated sovereign, no reason for issuers to consider a conditional pass-through.	Soft bullet	Hard bullet Soft bullet Conditional pass-through	Hard bullet Soft bullet	Hard bullet Swiss Pfandbriefe are usually hard bullet. Soft bullet Pfandbriefe only in special cases. No soft bullet Pfandbriefe outstanding.	Hard bullet Soft bullet Soft bullets predominate
3. Which trigger plays a role for maturity extension according to law - independent or alone or in combination?	Issuer bankruptcy/resolution	Issuer failure to pay Other Other: Where directed by Authority or Manager		Issuer bankruptcy/resolution	Issuer bankruptcy/resolution Issuer failure to pay	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Other Other: "No viability of the issuer according to the Recovery and resolution Directive and serious markets disturbances determined by the AUTORIDAD MACROPRUDENCIAL CONSEJO ESTABILIDAD FINANCIERA." The triggers work independently.	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Issuer failure to pay Other Other: the special administrator. The special administrator may change the maturity of a covered bond issue. An advance written permission from the BNB is required.	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Issuer failure to pay	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Issuer failure to pay Per contractual market practice, Issuer default (which could be bankruptcy, breach or failure to pay) so Guarantor LP/SPV is required to pay on the bonds and has insufficient money available in accordance with Guarantee Priority of Payments to pay in full the guaranteed amounts of the relevent CB.	Other Issuer event of default and lack of liquidity	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Issuer failure to pay Please, see comments section at the end of the questionnaire	Other For the specialized mortgage bank it is a soft bullet mechanism controlled by two separate triggers: a refinancing failure trigger and an interest rate trigger. For banks issuing covered bonds there is a refinancing trigger.	Issuer bankruptcy/resolution Issuer failure to pay	Separation of cb portfolio for many reasons could be used as trigger(incl. bankruptcy, moratorium, expiration of authorisation, issuer dissolution,..)		Lack of liquidity; breach of liquidity rules	From July 8, 2022. Triggers have to be based on objective factors that comply with legal requirements and to be defined in the Final Terms.		Issuer bankruptcy/resolution Other Extension may be applied if CB programme so foresees. 2 conditions must be present: issuer’s insolvency or liquidation and circumstances credibly showing that issuer will not be able to make payments to investors.	Lack of liquidity; breach of liquidity rules		Issuer bankruptcy/resolution Other The Issuer is likely to fail in the near future and there is no reasonable prospect that any alternative measures can prevent the issuer from failing.	Issuer bankruptcy/resolution Issuer failure to pay Other Other: Early intervention measures defined by the Italian Consolidaded Law on Banking	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Issuer failure to pay	Issuer bankruptcy/resolution Lack of liquidity; breach of liquidity rules Issuer failure to pay		Issuer bankruptcy/resolution		Issuer failure to pay Other Other: Withdrawal of the issuer's banking licence. CMVM can object to maturity extension	Other Not specified under MAS Notice, contractually governed.	Issuer bankruptcy/resolution Issuer failure to pay Other Issuer failure to pay - in the event of forced administration imposed on the issuing bank; Other - withdrawal of prior consent for covered bond programme	Issuer failure to pay	Other The maturity may be extended subject to such extension being permitted by the Swedish FSA as a result of it being deemed likely that the extension will prevent insolvency.	Other Swiss Pfandbriefe are usually hard bullet. Soft bullet Pfandbriefe only in special cases. No soft bullet Pfandbriefe outstanding.	Issuer bankruptcy/resolution Issuer failure to pay
4. Does any competent authority need to give its okay (or non-opposition)?	Yes For prolongation of further 3 months there is requirement of Central Bank approval	No		No	No But the reasons for applying the extenstion need to be documented (ex-post) to the regulator	Yes	Yes	Yes	No	No	No	No The issuer must approve the Danish FSA that there were no other options.	No When issuing a program that allows for maturity extension the central bank needs to approve this program, if and when the maturity extension takes place there is no approval required from the central bank although they must be informed in advance.	No	Yes	No	Yes Magyar Nemzeti Bank, the competent financial authority, controls and gives consent to the Issue Programmes, including pillars of Final Terms.	No	Yes Special admin (appointed in situations such as issuer insolvency) has the right to use extendable maturity structure if legal conditions are met.	No However the list of possible triggers shall be prepared by Lithuanian FSA		Yes Approval by the FSA.	No Bank issuing covered bonds must promptly inform the Bank of Italy about the triggers occurred (within 10 days)	Yes	Yes		Yes Bankruptcy/resolution: a cp administrator can extend the maturity under certain conditions. Consent of supervision authorities not necessary.		Yes	No	Yes	No	Yes	Yes Swiss Pfandbriefe are usually hard bullet. Soft bullet Pfandbriefe only in special cases (see comment above). No soft bullet Pfandbriefe outstanding.	No Contractual requirement to extend if triggered
IV.5 Overcollateralisation
1. Is mandatory overcollateralisation required in the law ?	1% NPV under stress scenarios defined by the Central bank bylaw	For both Public and Mortgage covered bonds - 3% - Prudent market value Issuers also apply contractual commitments		All types of cover pools - 2% - nominal (or optional 2% present value over collateralisation with adherence to nominal principle pursuant to CBD Art 15 (6))	Covered Bond Type - 105% - on a Value of Cover Asset basis	mortgage - 5% - Nominal public sector - 5% - Nominal	Overcollateralisation over the nominal value - 5% - Nominal		Residential mortgages - 103% - Nominal	No, but contractual obligation and/or by rating agencies	Public Covered Bonds where the Statutory 85% Limit is met using predominantly public receivables - 110% - nominal Other types of Covered Bonds recognized under Czech covered bonds regulation - 102% - nominal	CRR compliant covered bonds/Residential real estate - 2% - Nominal CRR compliant covered bonds/Commercial real estate - 2% - Nominal CRR compliant covered bonds/Ship loans - 2% - Nominal	All types - 5% - Nominal Nominal, but taking CRR LTV cut-off limits into account.	Mortgage / mixed - 5% - nominal	if CRR 129 article 3a met - 2% - market value if not - 5% - market value	Nominal value of all cive assets must exceed the nominal value of outstanding covered bonds by at least 5%.	mortgage bond - 2% - nominal/NPV	Covered Bond Type - 5% - nominal No mandatory, but contractual obligation and/or by rating agencies	The claims resulting from the loans included in the cover assets and the value of the derivative. - 105% - The total outstanding nominal value of the covered bonds. Covered bonds where the cover assets are claims resulting from loans for companies controlled by public persons or guarantees by such companies. - 110% - The total outstanding nominal value of the covered bonds. Percentage figure: "No less than ...%" Cover bond programme may foresee more strict overcollateralisation requirements.	Statutory overcollateralisation level should be no less than 5% of total principal amounts outstanding in relation to bonds which asset pool relates to.		Mortgage or commercial real estate - 5% - Nominal Public sector - 2% - Nominal	Covered bond CRR compliant - 5% - Nominal The overcollateralisation is a mandatory law requirement for covered bonds which use the label "European Covered Bond (Premium)". In this case, the national law refers to the percentage floor of 5% indicated in the CRR. The OC is required also under contractual obligation and/or rating agencies.	Covered Bond Type - 5% - nominal	Covered Bond Type - 5% - nominal	All types - 5% - NPV	Public sector - 2% - OC: 2% NPV + Nominal 2% Mortgage - 2% - OC: 2% NPV + Nominal 2% Ship - 5% - OC: 2% NPV + Nominal 5% Aircraft - 5% - OC: 2% NPV + Nominal 5% The 2% on a NPV basis must not be taken into account in nominal OC calculations and should cover potential winding-down costs. They are thus to be seen as a general coverage requirement according to Art. 15 (3) CBD.		Obrigações Cobertas Europeias (Premium) - Mortgages & Public Sector - 5% - Nominal Obrigações Cobertas Europeias - Mortgages - Nominal Obrigações Cobertas Europeias - Public Sector - 10% - Nominal Obrigações Cobertas Europeias (Premium) backed by commercial mortgages allowing maximum LTV of 70% are subject to minimum OC of 10%, as per Article 129	Covered Bond Type - 3% - Nominal The value of assets in a cover pool shall be at least 103% of the face value of the covered bonds secured by the assets at all times.	CRR eligible assets min. OC - 5% - nominal CRR non-eligible assets min. OC - 10% - nominal		All types - 2% - Both nominal & NPV	Swiss Pfandbriefe, Cover values to Pfandbrief loans (OC1) - 108% - Nominal Swiss Pfandbriefe, Mortgages to Pfandbrief loans (OC2) - 110% - Nominal Swiss Pfandbriefe, Mortgages to Pfandbrief loans (OC2) - 108% - Interest p.a. Regulatory requirements (approved by Swiss Federal Council). Different Levels for PB and PZ.	Residential Mortgages - 108% - Nominal Additional collateral required due to contractual requirements/ rating agency requirements/FCA stress testing
V. COVER POOL MONITOR & BANKING SUPERVISION
V.1 Cover pool monitor (CPM)
1. Is there a cover pool monitor in addition to national competent authorities in the statutory law?	Yes, by law			Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law	Yes, by law and in line with Article 13 of EU Covered Bond Directive CRH's own collateral monitoring team in addition to CPM required by EU CB Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law Required by contractual provisions	No Please, see comments section at the end of the questionnaire	No	Yes, by law and in line with Article 13 of EU Covered Bond Directive The Dutch covered bond law allows for the appointment of an external or an internal cover pool monitor.	Yes, by law and in line with Article 13 of EU Covered Bond Directive	No Only in default of the issuer	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive		Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive For further information please see comments box at the end of the questionnaire.		Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law and in line with Article 13 of EU Covered Bond Directive Current national legislation is in line with the principles of Article 13 of the EU Covered Bond Directive. The cover pool monitor must be an external third party, qualified auditor under the Companies Act (Cap 50).	Yes, by law and in line with Article 13 of EU Covered Bond Directive	Yes, by law	Yes, by law There is an independent inspector appointed by the supervisor and regulated by law.	Yes, by law Within the scope of the Pfandbrief Act, the pfandbrief institution is responsible for monitoring, in particular with regard to the mortgage cover pool. FINMA may order the delivery of the cover assets and then acts as trustee (Article 40 Pfandbrief Act).	Yes, by law and in line with Article 13 of EU Covered Bond Directive Asset pool monitor must be independent firm capable of being the suditor
2. Is the CPM separate from the issuing credit institution?	Yes, required by national statutory law			No, internal CPM allowed in line with the provisions of Article 13(3) CPM can be separate as well as internal (right to choose for the credit institution)	Yes, required by national statutory law	No, internal CPM allowed in line with the provisions of Article 13(3) but independent Yes, but external CPM also allowed. Two options.	Yes, required by national statutory law A cover monitor may be a bank authorised in the Republic of Bulgaria or in another Member State or an audit company.	Yes, required by national statutory law Internal CPM + external CPM	No, internal CPM allowed in line with the provisions of Article 13(3) The CPM can be the auditor of the issuer. The auditor would be separate from the credit decision process of the registered issuer.	No, internal CPM allowed in line with the provisions of Article 13(3) but independent			No, internal CPM allowed in line with the provisions of Article 13(3) but independent The internal CPM is independent from the credit decision process, but can be the same accountant as the external accountant of the bank.	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law		Yes, required by national statutory law	Yes, required by national statutory law The CPM must inform the issuer and the Bank of Italy about the outcomes of its controls submitting an annual report.	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law		No, internal CPM allowed in line with the provisions of Article 13(3) but independent DL 31/2022 Article 17 gives the option of external or internal auditor aligned with CBD Article 13 (3)	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law	Yes, required by national statutory law Within the scope of the Pfandbrief Act, the pfandbrief institution is responsible for monitoring, in particular with regard to the mortgage cover pool. FINMA may order the delivery of the cover assets and then acts as trustee (Article 40 Pfandbrief Act).	Yes, required by national statutory law
3. Is the appointment, dismissal, eligibility criteria and the role of the CPM regulated by the national statutory law?	Yes			Yes	Yes	Yes Very extensive regulation: elegibility criteria, duration, incompatibilities, reporting obligations..	Yes	Yes For external CPM	Yes	No	No		Yes By Article 40n of the Implementation Decree Covered Bonds.	Yes	Yes	Yes	Yes	Yes	Yes	Yes		Yes	Yes	Yes	Yes	Yes	Yes		Yes No regulation has been issued under DL 31/2022 as yet. DL 31/2022 (6) the CPM may only be dismissed for cause, and the dismissal and respective grounds shall be communicated to the CMVM within 10 days of their occurrence.	No Not specified under MAS Notice, contractually governed.	Yes	Yes	Yes	Yes Within the scope of the Pfandbrief Act, the pfandbrief institution is responsible for monitoring, in particular with regard to the mortgage cover pool. FINMA may order the delivery of the cover assets and then acts as trustee (Article 40 Pfandbrief Act).	Yes
V.2 Banking supervision
1. Which are the national competent authorities designated to carry out covered bonds public supervision in the law?	Central bank of Armenia - Website	Central Bank of Ireland - Website		FMA - Finanzmarktaufsicht (Financial Market Supervision) - Website	National Bank of Belgium - Website - National list	Bank of Spain - Website	Bulgarian National Bank (BNB) - Website Financial Supervision Commission (FSC) - Website FSC in case of listed covered bonds	Autorité de Contrôle prudentiel et de résolution - Website	Canada Mortgage and Housing Corporation (CMHC) - Website Office of Superintendent of Financial Institutions (OSFI) - Website Quebec Autorité des Marchés Financiers (AMF) - Website CMHC administers the Canadian covered bond legal framework. OSFI is prudential supervisor of federally incorporated financial institutions. AMF is prudential supervisor for Quebec regulated financial institutions. OSFI & AMF establishes covered bond encumbrance limits for regulated entities	No dedicated covered bond law for single issuer in Switzerland	Czech National Bank - Website List of compliant EU Covered Bonds/EU Covered Bonds Premium has not yet established in the Czech Republic.	Finanstilsynet (Danish Financial Supervisory Authority) - Website - National list	De Nederlandsche Bank - Website Link to register old law (https://www.dnb.nl/en/public-register/register-of-covered-bonds/?p=1&l=10&rc=V0ZUR08)	Estonian Financial Supervision and Resolution Authority - Website	FIN FSA - Website Regulation is under work	Bank of Greece - Website	Magyar Nemzeti Bank - Website	Financial Supervisory Authority of the Central Bank of Iceland - Website	The Financial and Capital Market Commission - Website	The Bank of Lithuania - Website		Finanstilsynet (Financial Supervisory Authority) - Website - National list	Bank of Italy - Website	Autorité de Contrôle prudentiel et de résolution - Website	Autorité de Contrôle prudentiel et de résolution - Website	National Bank of Romania - Website	The Federal Financial Supervisory Authority - Website The German banking supervisory authority (BaFin) carries out the supervision on German Pfandbrief banks with a special division and also carries out the supervision of the cover register. Copies of the cover register automatically shall be transmitted regularly to the supervisory authority.		Comissão do Mercado de Valores Mobiliários (CMVM) - Website DL 31/2022 sets rules for the cooperation between CMVM and the Bank of Portugal, as well as the ECB and, when applicable, with appointed resolution authorities	Monetary Authority of Singapore (MAS) - Website	National bank of Slovakia - Website	Financial Services Commission - Website Financial Supervisory Services - Website	Finansinspektionen - Website	Federal Council - Website FINMA - Website SER - Website	Financial Conduct Authority - Website As UK is outside the EEA Premium label will require the Third Country Equivalence regime to be in place
2. Is a special permission required for a covered bond programme according to national law?	No	Yes, licence for institution + competent autority		Yes, licence for institution	Yes, licence for institution	Others, please specify permission for programme granted by competent authority	Yes, licence for institution + competent autority	Yes, licence for institution + competent autority	Yes, licence for institution + competent autority	No	Others, please specify Permission for covered block	Yes, licence for institution	Yes, licence for institution Bank needs to obtain permission from the Dutch central bank to issue covered bonds.	Yes, licence for institution + competent autority If issuer want, after authorisation, to issue CBs with basis a programme other than one in business plan, shall submit application to the Financial Supervision Authority	Yes, licence for institution + competent autority	Yes, licence for institution	Yes, licence for institution + competent autority	Yes, licence for institution + competent autority	Yes, licence for institution	Others, please specify Covered bonds can be issued by an authorised credit institution and covered bond programme shall be included to covered bond programme list, supervised by Lithuanian FSA		Yes, licence for institution + competent autority The FSA has published a list of all issuers who has gotten the approval to issue covered bonds under the new legislation. Link (Norwegian only): https://www.finanstilsynet.no/nyhetsarkiv/nyheter/2022/oversikt-over-omf-foretak-som-kan-utstede-omf-premium/	Yes, licence for institution + competent autority The Bank of Italy grants or denies the authorisation within 90 days from the application. A different notification process regards the issuances under CB programmes established prior the new framework.	Yes, licence for institution + competent autority	Yes, licence for institution + competent autority	Yes, licence for institution + competent autority	Yes, licence for institution + competent autority For further information please see comments box at the end of the questionnaire.		Yes, licence for institution	Others, please specify Prior to the issuance of covered bonds, banks will be required to submit information on their covered bond programme to MAS at least one month in advance and at least 3 business days prior to each issuance under the programme.	Others, please specify Prior approval from the National bank for each type of covered bond programme	No No, but with additional requirements	Yes, licence for institution	Yes, licence for institution Pfandbrief institution must be in compliance with the Pfandbrief Act.	Yes, licence for institution + competent autority
3. Is there a covered bond issuance limit in law or regulation? If yes, please specify	No	No		Yes Issuance is not allowed if primary assets are below 85% of coverage requirements pursuant to §9 Austrian CB Law	No The NBB retains the right to impose an issuer-specific issuance limit on covered bonds to protect the other creditors of the issuer.	No	No	No	Yes Under OSFI and AMF regulatory requirements, total assets pledged for covered bonds must not represent more than 5.5% of a deposit-taking institution’s total on-balance sheet assets.	No	No	No	No	No	Yes Regulation is under work but mirroring the existing regulation	No	No	No No specific limits in covered bond legislation or regulation but the covered bond licence has a side letter which stipualates a maximum amount that an issuer can issue of of covered bonds. This can be updated upon request.	No	No		No	Yes Eligible assets may be assigned are subjected to internal operating limits set by the issuer, in copliance with the issuer's internal policies	No	No	Yes The total value of the cover pool collateralising a covered bond issuance cannot exceed certain thresholds of the issuer’s total assets, i.e. 10%, 15% or 20%, depending on the metrics defined by the National Bank of Romania.	No		No	Yes There is an encumberance limit imposed on all eligible issuers, equivalent to 10% of total assests (excluding assets earmarked for regulatory reserves and liquidity requirements and assets of subsidiaries)	No	Yes 4% of total asset of the issuer	No	Yes Pfandbrief institutes may only issue Pfandbriefe in such volumes, that the amount of all on-balance-sheet debt obligations, including Pfandbriefe, does not exceed fifty times the defined equity capital (Article 10 Pfandbrief Act).	Yes FCA approval required for every issue
4. Does the national statutory law provide for the appointment of a dedicated cover pool administrator in case of insolvency/resolution (transfer included acc. to BRRD [Bank Recovery and Resolution Directive])?	Yes	Yes		Yes Special administrator pursuant to CBD Art 20	Yes	Yes		Yes	Yes While the Canadian legal framework does not specifically provide for a dedicated special cover pool administrator, the registered issuer must designate a Bond Trustee. Independence requirements also apply to the guarantor entity following a default by the issuer.	No	Yes	Yes	No Member state option of CBD Article 20(2) and (3) was not used. Management of the cover pool is the task of the directors of an independent Trustee (appointed at the inception of the program).	Yes	Yes	Yes	Yes	Yes	Yes	Yes		Yes	No	Yes	Yes	No	Yes		Yes	No Not specified under MAS Notice, contractually governed.	No	No	Yes	Yes Several special provisions, especially Article 40 and 40a Pfandbrief Act.	Yes
5. Which is the typical frequency in the national statutory law of reporting from the covered bond issuers to the designated competent authorities?	Monthly	Quarterly Other: In addition to normal regulatory reporting for banks		Quarterly Quaterly frequency is statutory minimum but can be extended by regulation of the competent authority	Quarterly	Quarterly	Quarterly	Quarterly	Monthly A monthly investor report including detailed information on the covered bond program must be prepared and published each month.	None	Quarterly	Quarterly	Quarterly Quarterly: asset coverage and liquidity coverage. Other: at the start and upon request thereafter. Information asset coverage and liquidity coverage requirements have to be provided at the start and quarterly thereafter, other information at the start and upon request thereafter.	Quarterly	Monthly	Other Frequency to be determined by the decision of the BoG	Quarterly	Semi-annually The cover pool monitor sends a report semi annually to the regulator	Quarterly	Other Law sets forth that reports on stress testing results shall be provided in quarterly basis; other reporting requirements to be established by secondary legislation		Quarterly	Other The CPM must inform the Bank of Italy and the issuer at least on annual basis about the outcomes of its controls	Quarterly	Quarterly	Quarterly	Quarterly		Monthly Montly/Quarterly/Semi-annually. As regulation issued under DL 59/2006 that remains applicable until revoked by regulation issued under DL 31/2022	Other Reports certified by a qualified cover pool monitor has to be submitted to the regulatory authority annually at minimum.	Quarterly	Quarterly	Quarterly	Semi-annually Pfandbrief institutions report periodically, among other aspects, about Pfandbrief loans and the related mortgage cover pool. Some reports are quaterly.	Monthly
VI. COMPLIANCE WITH EUROPEAN LEGISLATION & RISK WEIGHTING
1. Does the national statutory law meet the requirements laid down in the EU Covered Bond Directive?	No No assesssment has been carried out	Yes		Yes	Yes	Yes	Yes	Yes	No Canada is not an EU member state.	No No dedicated covered bond law for single issuer in Switzerland	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes	Yes		Yes	Yes	Yes	Yes	Yes	Yes		Yes	No Singapore is not an EU member state and there is currently no requirements to meet the EU CRR Directive or EU Covered Bond Directive. However, national statutory law is aligned to the principles of the EU Covered Bond Directive.	Yes	No	Yes	Yes EU CBD not relevant. Differences in minor topics cannot be excluded. Switzerland has fully implemented the consolidated Basel framework, which includes all current and future standards of the Basel Committee on Banking Supervision.	No UK is outside the initial scope as non EEA
2. Does the statutory law meet the requirements of Article 129 of CRR [Capital Requirement Regulation]? In this case, please specify the collateral types meeting the Art. 129 CRR.	No	Yes For both Public and Mortgage covered bonds		Yes Limited to cover pools that qualify for "European Covered Bonds (Premium)"	Yes	Yes Mortgages and public sector assets.	Yes All types of collateral envisaged in Art. 129 CRR.	Yes - Residential mortgages - Guaranteed home loans	Yes	No	Yes Rules allow assets set out in Articles129(1)-(2)CRR to be used as a cover assets if the issuer meets conditions set out in Articles 129(1a)-(3)CRR.	Yes Loans secured by residential and commercial property, exposures to public authorities, exposures to credit institutions and collateral in ships (not an option for mortgage banks)	Yes The collateral types meeting the Art. 129 CRR requirements are those specified in paragraphs 1(a)-(g) of Art. 129 CRR.	Yes Please, see comments section below	Yes 1, 2A, 2B	Yes The law cross refers to art. 129 CRR. Therefore, all collateral types of art. 129 CRR are eligible.	Yes Loans secured by residential property and loans secured by commercial loans in accordance with CRR 129 (d) (f)	Yes	Yes Further comments in Comments Section at the end of the questionnaire.	Yes 129 (1)a, b, d, i, e,f, g.		Yes The Norwegian covered bond legislation states that for OMF premium the assets in the cover pool will have to comply with the requirements in art. 129 CRR (direct reference)	Yes All the assets of art. 129, paragraph 1, CRR	Yes - residential mortgages - guaranteed home loans	Yes - Residential mortgages - Guaranteed home loans - Commercial loans - Public sector loans	Yes art. 129 (1) a), c), d) and f)	Yes PfandBG is compliant with Art. 129 CRR. This was confirmed by German government in the reasons to the amendments 2021 for Mortgage, Public Sector and Ship Pfandbriefe, but not for Aircraft Pfandbriefe.		Yes DL 31/2022 Article 8 (1) (a) establishes as eligible all assets listed under Article 129 in the terms set therein	No Singapore is not an EU member state and there is currently no requirements to meet the EU CRR Directive or EU Covered Bond Directive. However, national statutory law is aligned to the principles of the EU Covered Bond Directive.	Yes CRR Art. 129 par.1) a, d, f for Primary assets; CRR Art. 129 par.1) b, c for Substitution assets	No	Yes	Yes The Swiss Pfandbrief is the only covered bond regulated by special law in Switzerland. Swiss Pfandbriefe are based on Swiss mortage loans.	Yes
3. Does the statutory law allow covered bonds out of the scope of Art 129 of CRR? In this case, please specify the collateral	No	No		Yes Cover assets pursuant to CBD Art 6 (1) b) may not be mixed up with cover assets pursuant to CBD Art 6 (1) a) in one cover pool	No	Yes Open category.Only comply with art.6 CBD requirements.	No	No	Yes Canada is not an EU member state.	No Contractual obligations	Yes Please see answer to question above.	No	No	Yes Net claims arising from derivative instruments, if do not exceed 15% of nominal value of outstanding CBs in the cb portfolio that they cover.	No	Yes Collateral to be determined in the BoG decision.	No	Yes Land for agriculture	No	No		Yes The collateral for "OMF standard" is not specified, just the requirements related to what needs to be fulfilled for a given asset	No	No	No	Yes High-quality assets that ensure that the issuer has a claim for payment and are secured by collateral assets such as residential properties, commercial properties or exposures to EU entities (credit institutions or public sector entities)	Yes Aircraft Pfandbriefe		Yes DL 31/2022 Article 8 (1) (b) and (c) establishes eligible in the terms set by Article 6 of the CBD	No Singapore is not an EU member state and there is currently no requirements to meet the EU CRR Directive or EU Covered Bond Directive. However, national statutory law is aligned to the principles of the EU Covered Bond Directive.	Yes Residential or commercial mortgage loans not meeting CRR requirements (e.g. LTV limits), loans to or guaranteed by the public undertakings	No	No	No The Swiss Pfandbrief is only regulated by a special law in Switzerland. Swiss Pfandbriefe are based on Swiss mortage loans.	No
4. Are listed covered bonds eligible in repo transactions with the national central bank?	Yes	Yes		Yes Conditional to additional requirements that are not defined in CBD but in the respective ECB-Guidelines	Yes	Yes	No	Yes	Yes Registered covered bonds are listed as eligible collateral under the Bank of Canada's Standing Liquidity Facilities.	No	Yes	Yes	Yes Eligible as collateral with the ECB.	Yes	Yes	Yes	Yes	Yes	No Not specified in the law.	Yes		Yes	Yes	Yes	Yes	Yes	Yes		Yes	No Singapore is not an EU member state and there is currently no requirements to meet the EU CRR Directive or EU Covered Bond Directive. However, national statutory law is aligned to the principles of the EU Covered Bond Directive.	Yes	No	Yes	Yes The Swiss National Bank maintains the 'List of collateral eligible for SNB repos (SNB GC Basket)', updating and publishing it on a daily basis. The Swiss Pfandbriefe are part of the SNB GC Basket.	Yes
VII. LEGISLATIVE FRAMEWORK
	Primary Legislation Law on Covered Mortgage Bonds (AM).pdf (Original language) LAW OF THE REPUBLIC OF ARMENIA ON COVERED MORTGAGE BONDS_eng.pdf (English language) Banks_and_Banking_Activity_arm.pdf (Original language) LAW OF THE REPUBLIC OF ARMENIA ON BANKS AND BANKING_eng.pdf (English language) Credit Organisations_arm.pdf (Original language) LAW OF THE REPUBLIC OF ARMENIA ON CREDIT ORGANISATIONS-eng.pdf (English language) Bankruptcy law_arm.pdf (Original language) LAW OF THE REPUBLIC OF ARMENIA ON BANKRUPTCY OF BANKS_eng.pdf (English language) Secondary Legislation Regulation 6-02_arm.pdf (Original language) Regulation 6-03_arm.pdf (Original language) Regulation 6-05_arm.pdf (Original language) Regulatoin 2_arm.pdf (Original language) Regulation_2_eng.pdf (English language)			Primary Legislation Austrian Covered Bond Law (DE).pdf (Original language) European Covered Bond Label (Premium) list https://www.fma.gv.at/en/banks/fma-disclosure/other-disclosure-items/ (English language)	Primary Legislation The Royal Decree of 15 February 2022 amending the Royal Decree of 11 October 2012 (NL_FR).pdf (Original language) The Royal Decree of 11 October 2012 on the issuance of Belgian covered bonds by Belgian credit institutions (NL-FR).pdf (Original language) The Law of 25 April 2014 on the status and supervision of credit institutions (Banking Law) (FR).pdf (Original language).pdf (Original language) The Law of 25 April 2014 on the status and supervision of credit institutions (Banking Law) (NL).pdf (Original language).pdf (Original language) Secondary Legislation NBB Circular Regulation on Covered Bonds (NBB_2022_15) (FR).pdf (Original language) NBB Circular Regulation on Covered Bonds (NBB_2022_15) (NL).pdf (Original language) NBB Circular Regulation on the Cover Pool Monitor (NBB_2022_16) (FR).pdf (Original language) NBB Circular Regulation on the Cover Pool Monitor (NBB_2022_16) (NL).pdf (Original language) European Covered Bond Label (Premium) list https://www.nbb.be/nl/financieel-toezicht/prudentieel-toezicht/toezichtsdomeinen/kredietinstellingen/lijsten/door-de (Original language) https://www.nbb.be/fr/supervision-financiere/controle-prudentiel/domaines-de-controle/etablissements-de-credit/listes-5 (Original language)	Primary Legislation RDL24_2021 (ES).pdf (Original language) European Covered Bond Label (Premium) list https://www.bde.es/bde/es/secciones/servicios/Instituciones_fi/autorizacion-de-bonos-garantizados/autorizacion-de-programas-de-bonos-garantizados.html (Original language)	Primary Legislation Bulgarian Covered Bonds Law (BG).pdf (Original language) Bulgarian Covered Bonds Act (with translation) (ENG).pdf (English language) Ordinance No42 of BNB for the requirements on Covered Bonds Issues (BG).pdf (Original language)	Primary Legislation Decree 7022-766 of May 2nd, 2022.pdf (Original language) Loi n° 85-695 du 11 juillet 1985.pdf (Original language) Ordonnance no 2021-858 du 30 juin 2021 portant transposition de la directive (UE) 2019-2162.pdf (Original language) Section 2 Les sociétés de crédit foncier (Articles L513-2 à L513-27) - Légifrance (FR).pdf (Original language) Decree n° 2021-898 of 6 July 2021 (FR).pdf (Original language) European Covered Bond Label (Premium) list https://acpr.banque-france.fr/en/covered-bonds (English language)			Primary Legislation Czech Act No. 182-2006 Coll., on Bankruptcy and Methods of its Resolution, as amended (most importantly Section 375) (CZ).pdf (Original language) Czech Act No. 190-2004 Coll, on Bonds, as amended (CZ).pdf (Original language) Decree of the Czech National Bank No. 2-2019 Coll., on Records of Covered Blocks, as amended (CZ).pdf (Original language) European Covered Bond Label (Premium) list https://www.cnb.cz/en/supervision-financial-market/lists-registers/other-lists/ (English language)	Primary Legislation Danish Financial Business Act (DK).pdf (Original language) Danish Mortgage-Credit Loans and Mortgage-Credit Bonds etc. Act (DK).pdf (Original language) Act on a Ship Financial Institute (DK).pdf (Original language) European Covered Bond Label (Premium) list https://www.dfsa.dk/Fact-and-Figures/List-of-issuers-of-covered-bonds (English language)	Primary Legislation 2021-12-15 Implementatiewet-richtlijn-gedekte-obligaties-voorstel-van-wet (NL).pdf (Original language) 2022-05-24 Besluit prudentiële regels Wft - definitief - stb-2022-223 (NL).pdf (Original language) Netherlands Decree on Prudential Rules under the FSA 2022 (EN).pdf (English language) Netherlands Financial Supervision Act 2022 (EN).pdf (English language) European Covered Bond Label (Premium) list https://www.dnb.nl/en/sector-information/supervision-sectors/banks/prudential-supervision/covered-bonds/implementation-of-the-european-covered-bonds-directive-in-dutch-law/ (English language)	Primary Legislation Estonian Covered Bonds Act (EST).pdf (Original language) Estonian Covered Bonds Act (ENG).pdf (English language) Secondary Legislation Regulation on the content of the supervision reports related to covered bonds, the basis for their preparation and the procedure for submission (EST).pdf (Original language) Regulation on composition of data to be entered in the cover register of covered bond (EST).pdf (Original language) European Covered Bond Label (Premium) list https://www.fi.ee/et/pangandus-ja-krediit/pandikirjad/eestis-emiteeritud-eriti-kvaliteetsed-euroopa-pandikirjad-0 (Original language)	Primary Legislation Act on Mortgage Credit Banks and Covered Bonds (151-2022).pdf (English language) Primary Law in Swe.pdf (Original language) Primary Law in Fin.pdf (Original language) European Covered Bond Label (Premium) list https://www.finanssivalvonta.fi/en/financial-market-participants/banks/credit-institutions/regulation/disclosure-requirement-for-mortgage-credit-bank-operations/ (English language)	Primary Legislation Law 4920-2022 on Covered Bonds (English Translation).pdf (English language) FEK-2022-Tefxos A-00074 (EL).pdf (Original language)	Primary Legislation HungarianCoveredBondAct (HU).pdf (Original language) HungarianCoveredBondAct (EN).pdf (English language)	Primary Legislation Iceland Covered Bond Legislation (IS).pdf (Original language) B_nr_528_2008 (IS).pdf (Original language) European Covered Bond Label (Premium) list https://en.fme.is/supervision/financial-undertakings/covered-bonds/ (English language)	Primary Legislation EU Regulation No 575-2013 (LV).pdf (Original language) Segto obligāciju likums (LV).pdf (Original language) Normatīvie noteikumi par iesniedzamajiem dokumentiem un tajos ietveramo informāciju lēmuma par atļauju īstenot segto obligāciju programmu pieņemšanai un paziņojuma izskatīšanai un par dokumentu izskatīšanas kārtību (LV).pdf (Original language)	Primary Legislation Lithuanian law 2022 (LT).pdf (Original language)		Primary Legislation Forskrift om finansforetak og finanskonsern (finansforetaksforskriften) (NO).pdf (Original language) Lov om finansforetak og finanskonsern (finansforetaksloven) (NO).pdf (Original language)	Primary Legislation Aggiornamento_n.42_del_30_marzo_2023.pdf (Original language) Dlgs 190_2021.pdf (Original language)	Primary Legislation Decree 7022-766 of May 2nd, 2022.pdf (Original language) Section 3 Les sociétés de financement de l'habitat (Articles L513-28 à L513-33) - Légifrance (FR).pdf (Original language) Decree n° 2021-898 of 6 July 2021 (FR).pdf (Original language) European Covered Bond Label (Premium) list https://acpr.banque-france.fr/en/covered-bonds (English language)	Primary Legislation Decree 7022-766 of May 2nd, 2022.pdf (Original language) Section 2 Les sociétés de crédit foncier (Articles L513-2 à L513-27) - Légifrance (FR).pdf (Original language) Decree n° 2021-898 of 6 July 2021 (FR).pdf (Original language) European Covered Bond Label (Premium) list https://acpr.banque-france.fr/en/covered-bonds (English language)	Primary Legislation Romanian Covered Bond Law (RO).pdf (Original language)	Primary Legislation PfandBG_2022_11_DE.pdf (Original language) Pfandbrief_Act_2022_12_08 (EN).pdf (English language) European Covered Bond Label (Premium) list https://www.bafin.de/DE/PublikationenDaten/Datenbanken/Pfandbriefbanken/pfandbriefbanken_artikel.html?nn=7845918 (Original language) https://www.bafin.de/EN/PublikationenDaten/Datenbanken/Pfandbriefbanken/pfandbriefbanken_node_en.html (English language)		Primary Legislation Decreto-Lei n.º 31_2022 (PT).pdf (Original language) European Covered Bond Label (Premium) list https://www.cmvm.pt/PInstitucional/Content?Input=CFCEABB643DE15EB21314BF536897B95C15081168D30D973175B240E88586315 (English language)	Primary Legislation 2022-06-24 MAS Notice 648 effective 1 July 2022 (ENG).pdf (English language)	Primary Legislation Act on Banks No. 483-2001 Coll, on Banks, as amended (SK).pdf (Original language) Act on Banks No. 483-2001 Coll, on Banks, as amended (EN).pdf (English language) European Covered Bond Label (Premium) list https://nbs.sk/dohlad-nad-financnym-trhom/dohlad/zoznam-krytych-dlhopisov-s-oznacenim-europsky-kryty-dlhopis/ (Original language)	Primary Legislation Korean Covered Bond Act (EN).pdf (English language) Enforcement Decree of Covered Bond Act (EN).pdf (English language)	Primary Legislation Finansinspektionen's regulations and general guidelines regarding covered bonds (SE).pdf (Original language) European Covered Bond Label (Premium) list https://www.fi.se/en/bank/supervision/list-of-covered-bonds/ (English language)	Primary Legislation Bundesgesetz über die Banken und Sparkassen (Bankengesetz, BankG, SR 952.0) (DE).pdf (Original language) Bundesgesetz über die Banken und Sparkassen (Bankengesetz, BankG, SR 952.0) (FR).pdf (Original language) Bundesgesetz über die Banken und Sparkassen (Bankengesetz, BankG, SR 952.0) (IT).pdf (Original language) Pfandbrief Act (PfG, SR 211.423.4) (DE).pdf (Original language) Pfandbrief Act (PfG, SR 211.423.4) (FR).pdf (Original language) Pfandbrief Act (PfG, SR 211.423.4) (IT).pdf (Original language) Pfandbrief Ordinance (PfV, SR 211.423.41) (DE).pdf (Original language) Pfandbrief Ordinance (PfV, SR 211.423.41) (FR).pdf (Original language) Pfandbrief Ordinance (PfV, SR 211.423.41) (IT).pdf (Original language) Secondary Legislation 220927 ECBC, Switzerland, Swiss Pfandbriefe, Secondary Legislation.pdf (English language)	Primary Legislation Supervision of UK regulated covered bonds (EN).pdf (English language)
VIII. ADDITIONAL INFORMATION
	Fact Book 3.1 Armenia.pdf (English language)	Hypostat Ireland.pdf (English language) Fact Book 3.21 Ireland.pdf (English language)	Fact Book 3.2 Australia.pdf (English language)	Hypostat Austria.pdf (English language) Fact Book 3.3 Austria.pdf (English language)	Hypostat Belgium.pdf (English language) Fact Book 3.4 Belgium.pdf (English language)	Hypostat Spain.pdf (English language) Fact Book 3.39 Spain.pdf (English language) Intro CB Video	Hypostat Bulgaria.pdf (English language) Fact Book 3.6 Bulgaria.pdf (English language) Intro CB Video	Hypostat France.pdf (English language) Fact Book 3.15 France.pdf (English language) Intro CB Video	Fact Book 3.7 Canada.pdf (English language)	Hypostat Switzerland.pdf (English language) Fact Book 3.41.2 Switzerland - Contractual Law Based Covered Bonds.pdf (English language)	Hypostat Czechia.pdf (English language) Fact Book 3.11 Czechia.pdf (English language)	Hypostat Denmark.pdf (English language) Fact Book 3.12 Denmark.pdf (English language) Intro CB Video	Hypostat The Netherlands.pdf (English language) Fact Book 3.27 The Netherlands.pdf (English language) Intro CB Video	Hypostat Estonia.pdf (English language) Fact Book 3.13 Estonia.pdf (English language)	Hypostat Finland.pdf (English language) Fact Book 3.14 Finland.pdf (English language) Intro CB Video	Hypostat Greece.pdf (English language) Fact Book 3.18 Greece.pdf (English language)	Hypostat Hungary.pdf (English language) Fact Book 3.19 Hungary.pdf (English language) Intro CB Video	Hypostat Iceland.pdf (English language) Fact Book 3.20 Iceland.pdf (English language)	Hypostat Latvia.pdf (English language) Fact Book 3.24 Latvia.pdf (English language) Intro CB Video	Hypostat Lithuania.pdf (English language) Fact Book 3.25 Lithuania.pdf (English language)	Fact Book 3.28 New Zealand.pdf (English language)	Hypostat Norway.pdf (English language) Fact Book 3.29 Norway.pdf (English language) Intro CB Video	Hypostat Italy.pdf (English language) Fact Book 3.22 Italy.pdf (English language) Intro CB Video	Hypostat France.pdf (English language) Fact Book 3.15 France.pdf (English language)	Hypostat France.pdf (English language) Fact Book 3.15 France.pdf (English language)	Hypostat Romania.pdf (English language) Fact Book 3.33 Romania.pdf (English language) Intro CB Video	Hypostat Germany.pdf (English language) Fact Book 3.17 Germany.pdf (English language) Intro CB Video	Hypostat Poland.pdf (English language) Fact Book 3.31 Poland.pdf (English language)	Hypostat Portugal.pdf (English language) Fact Book 3.32 Portugal.pdf (English language) Intro CB Video	Fact Book 3.35 Singapore.pdf (English language)	Hypostat Slovakia.pdf (English language) Fact Book 3.36 Slovakia.pdf (English language)	Fact Book 3.38 South Korea.pdf (English language)	Hypostat Sweden.pdf (English language) Fact Book 3.40 Sweden.pdf (English language)	Hypostat Switzerland.pdf (English language) Fact Book 3.41.1 Switzerland - Swiss Pfandbriefe.pdf (English language)	Hypostat UK.pdf (English language) Fact Book 3.43 United Kingdom.pdf (English language) Intro CB Video
Additional comments
							Section II.2: The cover pool may also include primary assets secured by physical collateral assets which are located or, respectively, which are recorded in a register in a third country wherewith the Republic of Bulgaria has agreements for the protection of investment and for the avoidance of double taxation in force and wherein the issuing bank or a bank belonging to the same group is established. The exposure to any such assets may not exceed 20 per cent of the principal amount of outstanding covered bonds. (2) The cover pool may also include primary assets secured by physical collateral assets which are located or, respectively, which are recorded in a register in a third country wherewith the Republic of Bulgaria has agreements for the protection of investment and for the avoidance of double taxation in force and wherein the issuing bank or a bank belonging to the same group is established, subject to the requirements of Paragraphs (3) and (4). The exposure to any such assets may not exceed 20 per cent of the principal amount of outstanding covered bonds. (3) Any assets referred to in Paragraph (2) may be included in the cover pool only if the issuing bank has at its disposal an independent expert opinion confirming that the said assets offer a level of security similar to that of the physical collateral assets which are located in a Member State, as well as a legal opinion that the arrangements for obtaining satisfaction from the said assets, inter alia with regard to the applicable procedures and time limits, are equivalent to the arrangements for obtaining satisfaction from assets located in a Member State. (4) The banks issuing covered bonds whereof the cover pool includes any assets referred to in Paragraph (2) shall adopt rules and procedures which provide for verifying on a regular basis that the assets in the third countries concerned conform to the requirements of this Act.	Further comments on Section II.1: "Guaranteed home loans are also eligible in the cover pool the guarantor must be rated at least ‘A-‘ ; For public sector assets, public entities must have minimum credit quality step 1 rating; Substitution assets subject to sub-limits: -Maximum 15% for credit quality step 1 exposures; -Maximum 10% for credit quality step 2 exposures; - Maximum 8% for credit quality step 3."		The answers to this questionnaire are based on the contractual Valiant covered bond programme 1. The base prospectus is available under: https://www.valiant.ch/ueber-valiant/investor-relations-fremdkapital-coveredbonds	Section II.1: "The Czech covered bonds regulation recognise three types of covered bonds (kryté dluhopisy): (i) mortgage covered bonds (hypoteční zástavní listy); (ii) public covered bonds (veřejnoprávní zástavní listy); and (iii) mixed covered bonds (smíšené zástavní listy). The distinction between these three types of covered bonds depends on what cover assets must prevail in the cover pool that serves as a cover in respect of those covered bonds and by virtue of which cover assets the applicable Statutory 85% Limit (stipulating that particular eligible assets must constitute such cover that the aggregate value of certain cover assets in the cover pool must be equal to at least 85% of the aggregate value of all debts for whose cover the cover pool serves) must be complied with." Section II.3: "Note that Czech covered bonds regulation does not formally distinguish between primary and substitute assets. However, depending on the type of covered bond (i.e. public covered bond, mortgage covered bond) eligible assets must constitute such cover that the aggregate value of certain cover assets in the cover pool must be equal to at least 85% of the aggregate value of all debts for whose cover the cover pool serves. This distinction between primary and substitute assets is not relevant in relation to mixed covered bonds." Section IV.4.3: "The Czech covered bonds regulation allows the issuers to issue covered bonds with a feature of extending their scheduled maturity for a pre-determined period of time if a specific trigger event specified in the terms and conditions of a series of covered bonds occurs. Note that only the events recognised under the Czech Act on Bonds may be used as trigger events for the purposes of an extendable maturity structure feature." Section V.1.1: "The Czech covered bonds regulation do not require the issuers of covered bonds to appoint mandatory asset (or cover pool) monitor within the meaning of Article 13 of the CBD. However, the issuers are free to appoint asset (or cover pool) monitor which, however, does not have to follow the requirements placed on 'obligatory' cover pool monitors under Article 13 of the CBD."	Comments on Section II.1: Collateral in ships is not an option for mortgage banks. Exposures to "public sector entities" must be understood as "Exposures to public authorities". Public housing mortgage loans can have 100% state guarantess. Derivatives are used for hedging purposes. Internal issued covered bonds according to CBD Article 8 and after permission from Danish FSA.		Further comments on section VI.2: - claims on or guaranteed by central banks within the European System of Central Banks, and central governments, public sector entities, regional governments or local authorities of EU Member States. - claims on or guaranteed by third-country central governments and central banks, multilateral development banks and international organisations that qualify for credit quality step 1 in accordance with CRR. - claims on or guaranteed by third-country public sector entities, regional governments and local authorities, for which a risk weight has been assigned the same way as for claims on credit institutions and investment firms or central governments and central banks in accordance with CRR and which qualify for the credit quality step 1 according to the risk weight so assigned. - claims specified in the two rows above, which qualify as a minimum for the credit quality step 2 in accordance with CRR, provided that they do not exceed 20% of the nominal value of the outstanding covered bonds in the covered bond portfolio that they cover. - claims on credit institutions and investment firms, which qualify for the credit quality step 1 in accordance with CRR, provided that they do not exceed 15% of the nominal value of the outstanding covered bonds in the covered bond portfolio that they cover. - claims on credit institutions and investment firms, which qualify for credit quality step 2 in accordance with CRR, provided that they do not exceed 10% of the nominal value of the outstanding covered bonds in the covered bond portfolio that they cover. - claims on credit institutions and investment firms in the EU with a term to maturity not exceeding 100 days, which qualify as a minimum for credit quality step 3 in accordance with CRR, provided that they do not exceed 8% of the nominal value of the outstanding covered bonds in the covered bond portfolio that they cover.			General comment: The Hungarian legislation also applies the Joint funding regulation under Article 9 of the Directive. The collateral may also be transferred through a financial collateral agreement under Directive 2022/47/EC. Comment on Section II.1: "1) Repurchase price of independent mortgage lien considered Exposures to credit institutions under pooling scheme 2) Substitute assets can be government or supranation bonds defined by law, other issuers mortgage or government guaranteed bonds 3) Part of grant mortgage loan secured by government guarantee in accordance with mortgage bank act"		Comments on VI.2: "Primary assets shall only include assets of the following classes: 1) the public sector assets - the exposures referred to in Article 129(1)(a) and Article 129(1)(b) of Regulation No 575/2013; 2) the residential mortgage assets - loans (credits) secured by residential real estate, as defined in Article 129(1)(d) of Regulation No 575/2013; 3) the commercial mortgage assets - loans (credits) secured by commercial real estate, as defined in Article 129(1)(f) of Regulation No 575/2013; 4) maritime assets - loans (credits) secured by a ship mortgage, as defined in Article 129(1)(g) of Regulation No 575/2013; 5) the assets which are loans to capital companies controlled by a public person or in cases where the law allows such capital companies to issue loans (credits) or to provide guarantees themselves - loans (credits) guaranteed by such capital companies in conformity with the provisions of Section 55, Paragraph six. Substitution assets shall include exposures that conform to the requirements of Article 129(1)(c) and (1)(a)(a), (b), (c), and (d) of Regulation No 575/2013."			Note important information: This questionnaire is based on the current market practice in Norway. For instance, issuers have so far only applied for approval for European Covered Bonds (Premium), "OMF Premium" in Norwegian. If market practice changes, this questionnaire will be updated to reflect the new situation.		Further comments on Section II.1: "Guaranteed home loans are also eligible in the cover pool Substitution assets subject to sub-limits: -Maximum 15% for credit quality step 1 exposures; -Maximum 10% for credit quality step 2 exposures; - Maximum 8% for credit quality step 3."	Further comments on Section II.1: "Guaranteed home loans eligible if guarantor rated at least ‘A-‘. For public sector assets, public entities must have minimum credit quality step 1 rating; Substitution assets subject to sub-limits: - Maximum 15% for credit quality step 1 exposures; - Maximum 10% for credit quality step 2 exposures; - Maximum 8% for credit quality step 3."		Section III.1: "The basis of this LTV calculation is the so called mortgage lending value (Beleihungswert), which has to be calculated in a different way compared to the market value, § 16 PfandBG. Details of the valuation procedure and the qualifications of the appraisers are regulated in a specific statutory order on mortgage lending value (Beleihungswertermittlungsverordnung, BelWertV), § 16 IV PfandBG. § 7 BelWertV requires personal and organisational independence of the valuer. Personal independence means that there must not be any connection between the valuer and the borrower. Organisational independence means that inhouse valuers must not be part of the credit division and must not be integrated in the credit decision. Organisational independence is assumed for external valuers. Similar provisions are regulated for mortgage lending values of ships and aircraft." Section IV.1.3: "PfandBG allows the use of derivatives for mitigation of market risks. In order to be eligible as cover pool assets derivatives have to be based on standardized master contracts in such way that a Pfandbrief bank’s insolvency does not lead to a termination or default of those derivatives registered in the cover pool register. The derivatives, which are registered in the cover register, form a part of the separate legal estate. The insolvency procedure has the same consequences for them like for the Pfandbriefe and they profit of the same ranking like the Pfandbriefe." Section IV.2.3: "A specific statutory order on net present value (PfandBarwertV) prescribes in detail how to calculate the net present value (procedure, stress scenarios, risk models etc.). This can be done by static (+-250 basis point parallel yield curve shift) or dynamic approaches (more sophisticated statistical approach with nonparallel yield curve shift of at least 100 basis points)." Section V.1.1: "The cover pool monitor (“Treuhänder”) supervises the cover register permanently. The CPM has to ensure that the prescribed cover for the Pfandbriefe exists at all times and that the cover assets are recorded correctly in the cover register, §§ 7, 8 PfandBG. Without his consent, no assets may be removed from the cover pool. The BaFin published a specific statutory order on details of the form and the contents of this cover register (Deckungsregisterverordnung – DeckRegV), § 5 III PfandBG." Section V.2.2: "The issuer is a fully equipped credit institution, which has a special licence to issue “Pfandbriefe”, which is provided by BaFin. § 2 I PfandBG sets minimum requirements to get and to keep this special licence: - core capital of at least 25 million euros, - general banking licence allowing to do lending business, - suitable risk management procedures and instruments, - business plan showing regular and sustainable issues as well as necessary organisational structure."		Some of these are subject to changes once regulation issued under previous DL 59/2006 regime is revoked by regulation to be issued under the new DL 31/2022 regime	Further comments on Section II.1: The cover pool can also include any other loans secured by the same residential properties or any other assets forming part of the security package under the mortgage loans (such as guarantees and indemnities). Derivatives held for the purpose of hedging risks arising from the particular issuance of covered bonds, Cash (including foreign currencies), Singapore Government Securities and MAS Bills.	Comments on Seciton IV.2.5: Coverage test is based on following formula: A/B, where: A represents the sum of nominal value of primary assets, the lower of nominal/real value of liquid and substitution assets and incoming cash flow from derivatives and B represents the sum of nominal value including accrued interest of issued covered bonds, expected costs associated with administration of covered bond programme and cash outflows from derivatives.	Comments on I.2: "Covered Bond holders, derivative counterparties related to Covered Bonds, other priority creditors including those with fees due shall have a priority right of payment on the registered Cover Pool over third parties. In case of bankruptcy of an issuer, the Cover Pool shall not be subject to bankruptcy proceeding, including compulsory execution, preservative measure and stay order with respect to such issuer. If the issuer becomes insolvent prior to repaying all of the principal of the Covered Bonds outstanding, the priority creditors have the right to participate in the bankruptcy proceedings of the issuers alongside other unsecured creditors of the issuer." Comments on II.1: ""residential mortgages, debts issued by public sector with LTV of less than 70%, vessel mortgages and aircraft mortgages with LTV of less than 70%. Liquid Assets: liquid assets such as cash, Certificate of Deposits issued by other financial institutions with maturity shorter than 100 days Other assets: recoveries from Cover Pool or Liquid Assets, derivative instruments etc. The following liquid assets may be registered as Cover Pool up to a limit of 10% of total value of the Cover Pool. 1. Cash 2. Certificates of Deposit issued by other financial institutions with maturity shorter than 100 days 3. Deposits, overdraft facilities, discounted bills, credit card receivables etc with maturity shorter than 3 months 4. Debt issued by central or local governments of OECD member countries 5. Financial instruments similar to certificate of deposit with maturity shorter than 100 days which have been issued by central banks, commercial banks, investment banks, securities companies etc with an international credit rating of 'A' or above from either an OECD member country" Comments on IV.2.3: "Where the currency of the Covered Bonds is different from the currency of the cover pool, the spot exchange rate prevailing on the calculation date shall be used to make the relevant calculations. Where the issuer has hedged its currency risk through derivative transactions, the exchange rate set out in such derivative contract may be utilised and the derivative counterparty will also be treated as a priority creditor under the Covered Bond Act." Comments on IV.3.1: "There are no separate provisions dealing with liquidity risk in the Covered Bond Act. The covered bonds issued to date require the issuer to make contractual pr+E180ovisions for interest payments, commissions and fees payable for a certain period of time and it is expected that the covered bonds issued under the Covered Bond Act will also likely stipulate such reserve requirements to mitigate liquidity risk by way of contractual provisions."		A description of the Swiss Pfandbrief Framework can be found in the annual ECBC Fact Book. Most relevant acts and ordiances in DE, FR or IT under: - PfG (https://www.fedlex.admin.ch/eli/cc/47/109_113_57/de) - PfV (https://www.fedlex.admin.ch/eli/cc/47/121_125_70/de) - BankG (https://www.fedlex.admin.ch/eli/cc/51/117_121_129/de) - BankV (https://www.fedlex.admin.ch/eli/cc/2014/273/de)