Opinion of the European Central Bank of 24 March 2016 on the reform of cooperative banks, a guarantee scheme for securitisations of non-performing loans and the lending capacity of alternative investment funds (CON/2016/17)
Date: 2016-03-24
Institutions: European Central Bank
Subjects: Italy, banking supervision, cooperative bank, financial stability

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 24 March 2016 

on the reform of cooperative banks, a guarantee scheme for securitisations  

of non-performing loans and the lending capacity of alternative investment funds 

(CON/2016/17) 

Introduction and legal basis 

On  2  March  2016,  the  European  Central  Bank  (ECB)  received  a  request  from  the  Italian  Ministry  of 

Economic  Affairs  and  Finance  for  an  opinion  on  Decree-Law  No  18  of  14  February  2016  on  urgent 

measures concerning the reform of banche di credito cooperativo (‘BCCs’, ‘Italian cooperative banks’), a 

guarantee  scheme  for  securitisations  of  non-performing  loans,  tax  arrangements  relating  to  crisis 

procedures,  and  the  collective  management  of  assets  (hereinafter  the  ‘Decree-Law’).  The  Decree-Law 

must  be  converted  into  a  law  within  60  days  of  publication,  i.e.  by  15  April  2016,  failing  which  it  is 

rendered invalid ab initio. 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 

Functioning  of  the  European  Union,  and  the  third  and  sixth  indents  of  Article 2(1)  of  Council 
Decision 98/415/EC1, as the Decree-Law relates to the Banca d’Italia and to rules applicable to financial 

institutions  insofar  as  they  materially  influence  the  stability  of  financial  institutions  and  markets.  In 

accordance  with  the  first  sentence  of  Article 17.5  of  the  Rules  of  Procedure  of  the  European  Central 

Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the Decree-Law 

The Decree-Law contains three elements of interest to the ECB. First, it reforms the Italian BCCs. 

Second,  it  introduces  a  guarantee  scheme  for  securitisations  of  non-performing  loans.  Third,  the 

Decree-Law introduces new rules concerning the capacity of alternative investment funds governed 
by  Directive  2011/61/EU  of  the  European  Parliament  and  of  the  Council2  and  established  in  Italy 

(hereinafter  ‘Italian  AIFs’)  or  in  another  Member  State  (hereinafter  ‘EU  AIFs’)  to  engage  in  non-

consumer lending activities. 

1.1  Reform of cooperative banks 

1.1.1  The  Decree-Law  reforms  BCCs  with  the  aim  of  bringing  about  more  transparent  and  efficient 

governance  standards,  and  eliminating  structural  weaknesses  in  the  system  of  BCCs.  It  provides 

1  

2  

Council  Decision  98/415/EC  of  29 June  1998  on  the  consultation  of  the  European  Central  Bank  by  national 
authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 
Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund 
Managers  and  amending  Directives  2003/41/EC  and  2009/65/EC  and  Regulations  (EC)  No  1060/2009  and  (EU) 
No 1095/2010 (OJ L 174, 1.7.2011, p. 1). 

 
 
 
 
                                                 
ECB-PUBLIC 

for  the  establishment  of  Cooperative  Banking  Groups  (hereinafter  ‘Groups’)  each  led  by  a  parent 

company. 

1.1.2  The  Decree-Law  requires  each  BCC  to  choose  between  joining  a  Group  or,  subject  to  certain 

conditions,  being  converted  into  a  joint  stock  company.  A  BCC  must  join  a  Group  in  order  to  be 

authorised by the Banca d’Italia to carry out banking business in the form of a BCC. Alternatively, 

individual  BCCs  whose  net  assets  exceed  EUR 200  million  may  opt  not  to  join  a  Group  on 

condition that they become joint stock companies, with the authorisation of the Banca d’Italia, and 

pay an extraordinary tax of 20 % of their cash reserve. 

1.1.3  Each Group must have a parent company, incorporated as a joint stock company, with the majority 

of  its  shares  held  by  the  BCCs  in  the  group.  A  parent  company  must  have  net  assets  of  at  least 

EUR 1  billion,  and  be  authorised  by  the  Banca  d’Italia  to  carry  out  banking  activities.  A  parent 

company primarily directs and coordinates the BCCs in its Group in accordance with the relevant 

cohesion contract. 

1.1.4  Cohesion contracts set out the powers of the parent company, in accordance with the principle of 

mutuality, including: (i) the power to identify and implement the strategic orientation and operational 

objectives of the Group adjusted to the risk level of the BCC in question; (ii) the power to approve 

or  reject,  in  exceptional  cases,  the  appointment  of  one  or  more  BCCs’  board  members  up  to  the 

majority of its members; and (iii) the power to expel a BCC from the Group in the event of a serious 

breach  of  one  or  more  of  the  terms  of  the  cohesion  contract,  and  other  types  of  sanction 

proportionate to the seriousness of the breach in question. 

Cohesion contracts also provide for joint and several guarantees of the obligations assumed by the 

parent  company  and  the  BCCs,  in  accordance  with  the  prudential  regulations  of  the  Groups  and 

individual banks in the Group. 

1.1.5  The Decree-Law also amends the rules regarding the capitalisation of individual BCCs as follows: 

(i) the maximum share capital in a BCC that can be held by a single shareholder is increased from 

EUR 50 000 to EUR 100 000; and (ii) the minimum number of shareholders of a BCC is increased 

from 200 to 500. 

1.2  Guarantee scheme for securitisations of non-performing loans 

1.2.1  The  Decree-Law  provides  for  the  introduction  of  a  State  guarantee  scheme  to  cover  the  senior 

tranches  of  securitisation  transactions  carried  out  by  banks  incorporated  in  Italy  and  backed  by 

non-performing  loans  (NPLs).  The  guarantee  scheme  will  be  open  to  all  Italian  banks  and  the 

guarantee  for  the  senior  notes  will  be  priced  at  market  rates  and  be  based  on  specified  credit 

default  swap  contracts,  in  order  to  ensure  compliance  with  State  aid  rules.  The  Minister  for 

Economic Affairs and Finance is authorised to issue guarantees under the scheme for 18 months 

starting from the date the Decree-Law enters into force, i.e. 16 February 2016. This period may be 

extended for a further 18 months, subject to the prior approval of the European Commission. 

1.2.2  The scheme is based on individual banks seeking to set up a securitisation structure under which 

NPLs  will  be  transferred  at  a  price  no  higher  than  their  net  book  value,  i.e.  gross  value  minus 

provisions.  The  securitisation  structure  is  financed  by  issuing  senior,  mezzanine  (optional)  and 

junior notes. 

2 

ECB-PUBLIC 

1.2.3  The  State  guarantee  is  an  unconditional,  irrevocable  and  first-demand  guarantee,  covering 

contractual  payments  for  interest  and  capital,  but  only  for  the  benefit  of  senior  noteholders.  The 

guarantee will become effective only once the following conditions are fulfilled: (i) the bank appoints 

an independent NPL servicer to deal with securitisations; (ii) the securities receive a rating equal to 

or  higher  than  investment  grade  from  a  rating  agency  included  in  the  list  of  the  external  credit 

assessment  institutions  accepted  by  the  Eurosystem;  and  (iii)  the  originating  bank  has  sold  to 

private investors a share of at least 50 % plus one of the junior tranches, and has sold a sufficiently 

large  part of the junior and mezzanine tranches to achieve accounting  derecognition of the NPLs 
sold3. 

1.3 

Lending capacity of alternative investment funds 

1.3.1  Since 2014 the Italian Consolidated Law on finance  4 has provided for the possibility for Italian AIFs 
to engage in  direct  lending  under certain conditions,  specified in Banca d’Italia’s regulation 5: they 
must  have  a  closed  ended  structure  and  are  subject  to  concentration 6  and  leverage  limits7;  the 

maturity of credits cannot exceed that of the fund.  

As for internal controls, asset managers are required to define, within the risk management system, 

a  specific  process  of  managing  credit  risk,  with  particular  regard  to:  i)  risk  measurement;  ii)  risk 

diversification;  iii)  credit  monitoring;  iv)  classification  of  risk  positions;  v)  assessment  and 

management of impaired loans. 

1.3.2  The  Decree-Law  amends  the  Italian  Consolidated  Law  on  finance  specifying  that  credit  funds 

cannot lend to retail consumers and that AIFs’ lending activity is subject to rules on transparency. It 

also  extends  the  possibility  to  grant  loans  to  EU  AIFs  under  the  following  conditions:  (i)  EU  AIFs 

are authorized by the competent authority  of the home Member State to  grant  loans in the home 

Member State; (ii) EU AIFs adopt a closed ended structure and their operating model, including the 

rules of participation, is comparable to that of Italian AIFs; (iii) the prudential regulation of the home 

Member State, including limits to leverage, are deemed equivalent to those applied to Italian AIFs. 

The  assessment  of  equivalence  is  carried  out  by  Banca  d’Italia  and  can  be  based  on  the 

contractual provisions governing the AIFs. The home competent authority must ensure that the EU 

AIFs comply with such provisions. 

1.3.3  Without  prejudice  to  the  foregoing,  the  Banca  d’Italia  is  obliged  to  lay  down  detailed  rules  to  be 

applied to EU AIFs engaging in direct lending in Italy. In any case, the Banca d’Italia has the power 

to veto EU AIFs engaging in direct lending in Italy. If no veto is imposed, EU AIFs operating in Italy 

will  be  also  required  to  comply  with  Italian  conduct  of  business  rules  governing  transparency  of 

contractual terms and client relationships. 

3   
4  
5  
6  
7  

No State body may buy junior or mezzanine notes. 

Testo Unico della Finanza, Decreto Legislativo (24.02.1998, n. 58). 
Regolamento sulla Gestione collettiva del risparmio (19.1.2015). 

The exposure to a single client is subject to a limit of 10 per cent of the total assets of the fund. 
More  specifically,  AIFs  marketed  to  retail  customers  are  subject  to  a  leverage  limit  of  1.3  (calculated  as  the  ratio 
between the total assets and the total net value  of the fund) and can enter into derivative contracts exclusively for 
hedging purposes, whereas AIFs marketed to professional investors are subject to a leverage limit of 1.5.  

3 

 
                                                 
ECB-PUBLIC 

2.  

The appropriate time to consult the ECB 

2.1  The ECB must be consulted at an appropriate stage in the legislative process. Consultation should 

therefore take place at a time that enables the relevant national authority to take the ECB’s opinion 
into account before the provisions in question are adopted8. 

2.2 

In the Italian legal system, a decree-law enters into force when it is adopted by the Government. It 

takes effect following publication in the Gazzetta Ufficiale and must be submitted on the same day 

to Parliament for conversion into law. If not converted within 60 days of publication, the decree-law 

is rendered invalid ab initio. Amendments may be introduced during the conversion process. In the 
light of the foregoing, the ECB should be consulted before the adoption of a decree-law9.  

2.3 

In  the  present  case,  as  the  Decree-Law  was  adopted  on  14  February  2016  and  published  on 

15 February 2016, not only was the ECB not consulted before its adoption, but the submission of 

the  consultation  request  was  unnecessarily  delayed.  The  request  was  received  by  the  ECB  on 

2 March 2016, when the Ministry of Economic Affairs and Finance asked the ECB to consider the 

consultation  as  a  matter  of  urgency  in  view  of  the  short  deadline  for  conversion.  This  situation  is 

unfortunate and the ECB would like to emphasise to the Ministry the need for proper consultation.  

3.   Observations 

3.1  Reform of cooperative banks 

3.1.1  It  is  recalled  that  the  ECB  was  consulted  and  issued  an  opinion  on  Decree-Law  No  3/2015  on 

urgent measures for the banking system and investments, which introduced significant reforms of 
‘popolari  banks’10.  The  reform  of  cooperative  banks  is  part  of  the  same  reform  of  the  banking 

system. 

3.1.2  Under  the  current  prudential  regulatory  framework,  both  strong  governance  arrangements  and  a 

solid  capital  structure  are  crucial  concerns  for  the  banking  supervisor.  To  this  end,  the 

consolidation of the cooperative banking sector into Groups where the parent company is a joint-

stock  company  would  facilitate  each  Group’s  ability  to  raise  capital  and  enhance  shareholders’ 

control  over  management.  In  addition,  this  could  make  it  easier  for  capital  instruments  issued  by 

the  BCCs  to  fulfil  the  requirements  of  Regulation  (EU)  No 575/2013  of  the  European  Parliament 
and of the Council11, as supplemented by Commission Delegated Regulation (EU) No 241/2014 12, 

for  capital  instruments  to  qualify  as  Common  Equity  Tier  1  capital.  Furthermore,  the  Group 

arrangements make it possible for the Common Equity Tier 1 of the BCCs in excess of minimum 

8  

9 
10  
11  

12  

See Article 4, second sentence, of Council Decision 98/415/EC of 29 June 1998 on the consultation of the European 
Central  Bank  by  national  authorities  regarding  draft  legislative  provisions  (OJ  L  189,  3.7.1998,  p.  42);  Title  IV, 
Section I of the Guide to consultation of the European Central Bank by national authorities regarding draft legislative 
provisions, which is available on the ECB’s website at: www.ecb.europa.eu. 

See ECB Opinion CON/2012/64. All ECB opinions are available on the ECB’s website at: www.ecb.europa.eu. 
See ECB Opinion CON/2015/13. 

Regulation  (EU)  No  575/2013  of  the  European  Parliament  and  of  the  Council  of  26  June  2013  on  prudential 
requirements  for  credit  institutions  and  investment  firms  and  amending  Regulation  (EU)  No  648/2012  (OJ L 176, 
27.6.2013, p. 1). 
Commission  Delegated  Regulation  (EU)  No  241/2014  of  7  January  2014  supplementing  Regulation  (EU) 
No 575/2013 of the  European Parliament and of the Council with regard to regulatory technical standards for Own 
Funds requirements for institutions (OJ L 74, 14.3.2014, p. 8). 

4 

 
                                                 
ECB-PUBLIC 

requirements to be accounted for purposes of compliance with capital requirements at consolidated 

level. 

3.1.3  The  ECB  expects  that  the  Decree-Law  will  accelerate  consolidation  among  Italian  cooperative 

banks. This process should eventually result in the cooperative banking sector as a whole having 

an  improved  capacity  to  absorb  negative  shocks,  as  well  as  providing  new  opportunities  for 

rationalisation of resources and diversification of investments. Given the importance of the Decree-

Law  in addressing the  vulnerabilities of the Italian cooperative banking sector, the ECB generally 

supports the key elements of the proposed reform. 

3.1.4  Nevertheless, the ECB wishes to raise the following points: 

3.1.5  First, the establishment of a Group involves significant challenges for the parent company in terms 

of risk governance and control systems. In this regard, the ECB would like emphasise that, in order 

to  be  aligned  with  best  practices  at  international  level,  the  parent  company’s  powers  to  manage 

affiliated institutions and coordinate the Group should be broader than provided for in the Decree-

Law. In particular, the parent company should be able to direct and coordinate the Group, including 

by  giving  direct  instructions  to  the  affiliated  institutions  under  any  circumstances  to  ensure 

compliance with applicable prudential rules and supervisory requirements as well as to ensure that 

the  group  entities’  operations  and  strategies  are  in  line  with  the  Group’s  policies  and  objectives. 

The ECB understands that the powers of the parent company depending on the risk level of each 

BCC  will  be  clearly  specified  in  secondary  regulation  and  in  the  “cohesion  contracts”  in  a  way  to 

ensure  that  these  powers  are  strong  and  effective,  in  compliance  with  CRD  IV  requirements  and 

the  best  practices.  This  solution  reflects  the  principle  of  autonomy  of  the  BCCs  which  are 

cooperative companies devoted to a mutual activity according to their special statute. However, in 

order  to  safeguard  the  parent  company’s  effective  control  of  the  Group,  the  power  to  remove 

directors should not be limited to exceptional situations. 

3.1.6  Second, the ECB welcomes the Decree-Law stipulating that the parent company will have control 

systems  and  the  power  to  ensure  compliance  with  prudential  requirements,  as  it  is  of  great 

importance  that  Groups  have  well-designed  control  functions,  including  risk  management, 

compliance, internal audit and planning, reporting exclusively to the parent company. 

3.1.7  Third, the ECB notes that the provision according to which BCCs can decide whether or not to join 

a Group may undermine the reform. In particular, as the date by which BCCs must have net assets 

of at least EUR 200 million is not stipulated in the Decree-Law, there is a risk of promoting mergers 

between  BCCs  with  net  assets  below  EUR 200  million.  Not  joining  a  Group  should  be  an 

exceptional option which can only be exercised during a limited period of time and measured with 

reference  to  the  required  level  of  net  assets  for  a  BCC  on  a  specific  prior  date  (for  example,  net 

assets as at 31 December 2015). 

3.1.8  Fourth, pursuant to the Decree-Law, the Banca d’Italia is the authority competent to verify whether 

the  requirement  to  form  a  Group  has  been  fulfilled.  The  Banca  d’Italia  is  also  competent  to 

authorise  a  BCC’s  membership  of  a  Group,  the  rejection  of  a  request  for  membership,  the 

exclusion of a BCC from a Group, and the conversion of a BCC into a joint stock company. Where 

5 

ECB-PUBLIC 

the  relevant  authorisations  are  not  granted,  the  BCC  must  commence  liquidation  proceedings 13. 

Further, in the event of non-compliance with the requirement to form a Group, the Banca d’Italia is 

competent  to  take  the  actions  necessary  to  revoke  the  authorisations  necessary  to  carry  out 
banking  activities 14.  It  is  understood  that  these  powers  assigned  to  the  Banca  d’Italia  are  without 

prejudice  to  the  powers  assigned,  within  the  scope  and  framework  of  Council  Regulation  (EU) 
No 1024/201315,  to  the  ECB  as  the  authority  competent  to  withdraw  authorisations  of  credit 
institutions 16  and  to  ensure  compliance  with  the  requirement  of  Directive  2013/36/EU  of  the 
European Parliament and of the Council17 that credit institutions have in place robust governance 
arrangements18.  

3.1.9  Finally, two key aspects of the proposed legal framework for Groups concern the procedure for the 

functioning  of  the  joint  guarantee  and  the  minimum  organisational  requirements  for  the  parent 

company.  Regarding  the  joint  guarantee,  there  should  be  sufficient  arrangements  in  place  to 

ensure  that  committed  support  will  be  given  when  necessary.  Regarding  organisational 

requirements, it is critical that the Decree-Law requires adequate corporate governance measures 

to  be  in  place  in  order  to  ensure  that  the  parent  company  is  able  to  meet  its  dual  mandate  as 

oversight body of the affiliated BCC and as executive body of the entire Group. The ECB notes that 

it is the intention of the Italian government to further develop these aspects in a ministerial Decree. 

The ECB would appreciate being consulted in advance of the final approval of this Decree. 

3.2  The guarantee scheme for securitisations of NPLs 

3.2.1  The ECB welcomes the guarantee scheme for securitisations of NPLs as it may lead to a reduction 

of  funding  costs  for  such  securitisations,  which  would  allow  NPLs  to  be  recognised  with  a  higher 

value  and  thus  incentivise  the  transfer  of  NPLs.  From  a  financial  stability  point  of  view,  the 

presence of significant volumes of NPLs on credit institutions’ balance sheets reduces their ability 

to fulfil their function as providers of credit to the real economy and hampers operational flexibility 

and  overall  profitability  essential  to  a  well-functioning  banking  sector.  As  such,  the  scheme  may 

have  a  positive,  albeit  incremental,  effect  on  financial  stability  to  the  extent  that  it  would  result  in 

transfer of the risks of NPLs off credit institutions’ balance sheets. However, the scheme needs to 

be seen in conjunction with other measures required in order to address the issues posed by NPLs 

for credit institutions in a systemic manner. 

3.2.2  The  ECB  notes  that  the  procedure  for  enforcement  of  the  guarantee,  in  particular  the  permitted 

timing of enforcement claims, set out in Article 11(1) of the Decree-Law should be clarified in order 

to  align  the  first  and  second  sentences  of  that  paragraph.  The  first  sentence  reads  as  if  the 

guarantee may only  be enforced  from the date of legal maturity  of senior notes until nine months 

13  
14  
15  

16  
17  

18  

Art. 1(4)(c) of the Decree-Law. 

Art. 2(4) of the Decree-Law. 
Council Regulation (EU) No 1024/2013 of 15 October 2013 conferring specific tasks on the European Central Bank 
concerning policies relating to the prudential supervision of credit institutions (OJ L 287, 29.10.2013, p. 63). 
Art. 4(1)(a) of Council Regulation (EU) No 1024/2013. 
Directive  2013/36/EU  of  the  European  Parliament  and  of  the  Council  of  26  June  2013  on  access  to  the  activity  of 
credit  institutions  and  the  prudential  supervision  of  credit  institutions  and  investment  firms,  amending  Directive 
2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC (OJ L 176 , 27.6.2013, p. 338). 

Idem, see Article 74. 

6 

                                                 
ECB-PUBLIC 

thereafter.  The  second  sentence,  however,  allows  enforcement  procedures  to  be  commenced 

30 days after a non-payment event, which could also occur prior to the final maturity of the senior 

notes, e.g. in relation to interest payments. It would therefore seem more logical that the guarantee 

may be enforced at the latest nine months after final maturity of the senior notes, but also prior to 

final maturity after a non-payment event. The ECB suggests that the wording in the first sentence 

should be amended accordingly to include the words ‘at the latest’.  

3.2.3  The ECB further notes that Article 11(2) of the Decree-Law should be amended to clarify both the 

timing  and  quantum  of  payments  which  should  be  made  by  the  guarantor  under  the  guarantee. 

With  regard  to  timing,  the  ECB  understands  that,  within  thirty  days  from  the  date  of  receipt  of  a 

documented request for enforcement of the State guarantee, the Minister for Economic Affairs and 

Finance must undertake payment, and not only upon the maturity of the senior notes. As currently 

drafted, the amount payable appears to cover only the full amount of principal of the senior notes 

which  would  be  due  at  final  maturity.  This  appears  to  contradict  Article  8(2)  of  the  Decree-Law, 

which indicates that the guarantee covers payments of principal and interest for the entire term of 

the senior notes, since future interest payments would not be covered. In addition, the ECB notes 

that  the  current  drafting  implies  that,  even  if  there  were  a  non-payment  event  relating  only  to  an 

interest payment occurring prior to the maturity of the senior notes, the guarantee payment would 

involve payment of the full amount of  principal,  prior  to that  principal becoming  due  on such final 

maturity date. 

3.2.4  Finally,  the  ECB  also  welcomes  the  Decree-Law  requiring  the  appointment  of  a  qualified 

independent  entity  to  monitor  the  compliance  of  the  issued  guarantee  with  stated  conditions,  the 

appointment  of  an  independent  servicer  and  the  transfer  of  at  least  50 %  plus  one  of  the  junior 

notes, and in any case, an amount of mezzanine and junior notes permitting the derecognition of 

the underlying assets at consolidated level in accordance with Article 8(1) of the Decree-Law. 

3.3 

Lending capacity of alternative investment funds 

3.3.1  In general, alternative investment funds (AIFs) which are entitled to grant loans carry out a typical 

banking activity outside the regulated banking system (i.e. without being subject to Regulation (EU) 

No 575/2013 and Directive 2013/36/EU or comparable prudential regulation). AIFs might therefore 

act as substitutes for bank lending and could generate credit intermediation risks (i.e. runs and/or 

liquidity  risk)  without  having  a  banking  (or  comparable)  licence.  While  regulated  indirectly  as  a 

result  of  initial  capital,  own  funds  and  internal  controls  requirements  imposed  on  their  asset 

managers under Directive 2011/61/EU, AIFs are not subject to harmonised rules on concentration 
risks and credit assessments19.  

3.3.2  In  light  of  these  considerations,  it  should  be  ensured  that  the  direct  provision  of  loans  by  AIFs  is 

subject  to  targeted  measures  efficiently  mitigating  the  associated  risks.  The  ECB  thus  welcomes 
that Italian legislation20 provides for rules applicable to lending activities of both EU AIFs and Italian 

19  

20  

See  European  Banking  Authority  Guidelines  ‘Limits  on  exposures  to  shadow  banking  entities  which  carry  out 
banking  activities  outside  a  regulated  framework  under  Article  395(2)  of  Regulation  (EU)  No  575/2013’  of 
14 December 2015 (EBA/GL/2015/20), p. 10. 

Regolamento sulla Gestione collettiva del risparmio (19.1.2015). 

7 

                                                 
AIFs  on  managing  credit  risk  with  regard  to  risk  measurement  and  diversification,  leverage,  fund 

structure  as  well  as  credit  monitoring,  classification  of  risk  positions  and  assessment  and 

management of impaired loans.  

ECB-PUBLIC 

This opinion will be published on the ECB’s website. 

Done at Frankfurt am Main, 17 March 2016. 

[signed] 

The President of the ECB 

Mario DRAGHI 

8