Greek Covered Bonds - Greece
1 | Who is the issuer? | Universal credit institution | |
2 | Does the bondholder have recourse to the issuer (in case of special issuer: recourse to the sponsor bank)? | Direct | |
3 | Who owns the cover assets? | The issuer directly | |
4 | Is the issuer the originator of the cover assets? | Yes, partly (external origination possible) |
1 | What type of assets may be included in the cover pool? | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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2 | What is the geographical scope of 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. |
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3 | Is there a maximum level for substitute assets in the statutory national framework? |
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. |
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4 | Are there any reporting requirements for covered bond issuers to investors? | Yes, by law and in line with art. 14 of EU Covered Bond Directive | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
5 | What is the frequency of reporting to investors? | Quarterly |
1 | What is the basis for property valuation | 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 |
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3 | What are the LTV limits (single asset based)? Please specify in %/n.a. |
Residential Commercial Ships Residential 80%; Commercial 60%; Ships 60% |
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4 | Are loans in excess of LTV limits eligible for inclusion in the cover pool? | Yes (soft limit) |
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) | |
2 | Are there requirements for derivative contracts (e.g. eligibility criteria for hedging counterparties)? |
Yes, specified in law
BoG to determine eligibility criteria. Determination still pending |
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3 | Will derivative contracts remain in case of insolvency of the issuer? | Yes | |
4 | If derivatives are permitted in the cover pool, what is their ranking? | 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 | |
2 | Are there mitigating provisions for interest rate risk? |
Yes, by legislation/regulation
BoG to determine relevant rules. This is still pending. |
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3 | Are there mitigating provisions for foreign exchange risk? | No | |
4 | Are there mitigating provisions for maturity mismatch risk? |
No
This could change upon issuance of BoG decision. |
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5 | What type of coverage test is applied? |
Nominal cover
Pending the decision of the BoG. |
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6 | Are there stress scenarios applied? |
No
Pending the decision of the BoG. |
IV.3 Liquidity risk
1 | Is exposure to liquidity risk mitigated? | Yes, by law | |
2 | What liquidity risk mitigation requirements are in place (principal)? |
180 days liquidity provisions Maturity extension provisions |
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3 | What liquidity risk mitigation requirements are in place (interest)? |
180 days liquidity provisions Maturity extension provisions |
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4 | What is the consequence of not fixing a breach of liquidity risk mitigants? |
No new covered bond issuance Administrative penalty |
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5 | If 180 days liquidity provisions are in place, what types of liquid assets are eligible |
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) |
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6 | If 180 days liquidity provisions are in place, the calculation of principal is based on: | The (extended) legal final maturity date |
IV.4. Maturity extension
1 | Is maturity extension allowed by national law? | Yes but optional | |
2 | Is it possible to issue… |
Hard bullet Soft bullet Conditional pass-through |
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3 | Which trigger plays a role for maturity extension according to law - independent or alone or in combination? | Lack of liquidity; breach of liquidity rules | |
4 | Does any competent authority need to give its okay (or non-opposition)? | No |
IV.5 Overcollateralisation
1 | Is mandatory overcollateralisation required in the law ? |
Nominal value of all cive assets must exceed the nominal value of outstanding covered bonds by at least 5%. |
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 and in line with Article 13 of EU Covered Bond Directive | |
2 | Is the CPM separate from the issuing credit institution? | 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 |
V.2 Banking supervision
1 | Which are the national competent authorities designated to carry out covered bonds public supervision in the law? |
Bank of Greece - Website |
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2 | Is a special permission required for a covered bond programme according to national law? | Yes, licence for institution | |
3 | Is there a covered bond issuance limit in law or regulation? If yes, please specify | No | |
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 | |
5 | Which is the typical frequency in the national statutory law of reporting from the covered bond issuers to the designated competent authorities? |
Other
Frequency to be determined by the decision of the BoG |
1 | Does the national statutory law meet the requirements laid down in the EU Covered Bond Directive? | Yes | |
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. |
Yes
The law cross refers to art. 129 CRR. Therefore, all collateral types of art. 129 CRR are eligible. |
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3 | Does the statutory law allow covered bonds out of the scope of Art 129 of CRR? In this case, please specify the collateral |
Yes
Collateral to be determined in the BoG decision. |
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4 | Are listed covered bonds eligible in repo transactions with the national central bank? | Yes |
Any further comments/information? |