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STS 543 Luís T. D. et al.
Figure 3 – Summary of the Recommendation

According to the Recommendation, “Banco de Portugal shall monitor the
implementation of this Recommendation at least once a year as well as the
evolution of credit agreements for consumers excluded from the scope of this
Recommendation.” In previous years, the compliance with a Recommendation
such as this one would have to be done via an annual ad hoc request
addressed to all credit institutions, or, alternatively, directed to only a sample
of institutions with the inherent negative impact on the preservation of a level
playing field amongst credit institutions in Portugal. Presently, the universal
coverage of the CCR, together with the level of detailed information (given the
number of attributes) available on a loan-by-loan basis, allows the Bank to
assess the compliance with the Recommendation for all credit institutions
without needing to set up a dedicated report to obtain additional information
from them.
Furthermore, CCR data allow a more in-depth analysis that makes it
possible for the Bank to calibrate the Recommendation almost in real time,
should the need arises, rather than having to wait several months to receive
ad hoc information from the credit institutions to conduct such analyses.

4. Final Remarks
The development of the new Portuguese CCR was a major challenge, given
the ambitious objectives set for this project – inter alia, to act as the single
entry point of all credit and credit risk data with a very high level of granularity.

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