2023-01-01
The Polish Financial Supervision Authority (KNF) issued Recommendation S to establish good practices for managing mortgage-backed credit exposures, specifically requiring banks to offer fixed-rate or periodically fixed-rate mortgage products to retail clients. The regulation introduces strict risk management rules for 'key for debt' loans and mandates that banks enable existing variable-rate borrowers to switch to fixed-rate formulas. Banks must align their product offerings with their risk appetite, ensure adequate consumer education, and report their specific mortgage product categories to the regulator.
Unified text prepared on the basis of: Resolution No. 492/2019 of the Financial Supervision Commission of 3 December 2019 on the issuance of Recommendation S concerning good practices in the management of mortgage-backed credit exposures Resolution No. 173/2020 of the Financial Supervision Commission of 14 July 2020 amending the resolution on the issuance of Recommendation S concerning good practices in the management of mortgage-backed credit exposures and Resolution No. 242/2023 of the Financial Supervision Commission of 19 June 2023 amending the resolution on the issuance of Recommendation S concerning good practices in the management of mortgage-backed credit exposures Financial Supervision Commission Recommendation S concerning good practices in the management of mortgage-backed credit exposures Warsaw, December 2019
2 Introduction The Recommendation is issued pursuant to Article 137(1)(5) of the Act of 29 August 1997 – Banking Law (Journal of Laws of 2022, item 2324, as amended) and constitutes a set of rules regarding good practices for mortgage-backed credit exposures. The purpose of issuing the amended Recommendation S is to expand its previous wording with rules concerning the management of mortgage-backed credit exposures with a fixed interest rate or a periodically fixed interest rate, so as to take into account the risks associated with these loans and to indicate that banks should have in their offer of mortgage loans for residential properties for retail clients, also such types of loans. The amended Recommendation S indicates that the bank should enable the retail client to change the interest rate formula of the loan from a variable interest rate to a fixed interest rate or a periodically fixed interest rate – this also applies to loan agreements concluded before the entry into force of this Recommendation. The Recommendation simultaneously indicates that the bank should prepare organizationally to handle applications submitted by clients for a change in the loan interest rate formula, as well as take into account the possibility of progressively informing successive groups of clients about the possibility of changing the loan interest rate formula in case the bank anticipates that it will not be able to handle all expected applications. Furthermore, the amended Recommendation S introduces provisions regarding loans with the option of release from the obligation to the bank regarding the mortgage-backed credit exposure on residential real estate in the event of the transfer of ownership of the mortgaged real estate to the bank by the borrower, hereinafter referred to as loans with the "key for debt" option. Due to the special nature of mortgage claims, credit exposures financing real estate that is not secured by a mortgage are excluded from the scope of the Recommendation. The provisions of the Recommendation relating to a mortgage-backed loan also apply to a loan for which such security has been established. The Recommendation takes into account recommendations and recommendations regarding lending in foreign currencies issued by the European Systemic Risk Board (ESRB), the National Bank of Poland, the Basel Committee on Banking Supervision, as well as by other organizations and collegiate bodies responsible for issues of financial system stability on an international scale. During the design of regulatory changes, a review of regulatory solutions and international practice in this area was also carried out, and some of these solutions were taken into account in the development of the final shape of the Recommendation. One of the regulatory goals is to strive for high-quality credit portfolios built by banks. In the context of risks associated with the portfolio of mortgage-backed credit exposures, the following should be kept in mind: • limited liquidity in the real estate market, including the possibility of enforcing claims from a given type of real estate in a compulsory manner, which raises concerns about the effectiveness of the realization of securities and its possible impact on the situation in the real estate market,
3 • the need for further work aimed at developing databases on the real estate market, • moderate experience of participants in this market in Poland. The Recommendation pays particular attention to issues relating to mortgage loans with a fixed interest rate and a periodically fixed interest rate. As indicated in Recommendation 1.9, the supervisor expects that the bank should have in its offer of mortgage loans for residential properties for retail clients mortgage loans with a fixed interest rate or a periodically fixed interest rate. It should be emphasized that such an offer should relate to the entire amount of the loan for which the client applies. The remaining provisions of Recommendation S relating to mortgage loans with a fixed interest rate or a periodically fixed interest rate should be applied with due regard to Recommendation 1.9. It is permissible for the bank to offer only mortgage loans with a fixed interest rate or a periodically fixed interest rate. Decisions regarding the offering of specific types of products should take into account the bank's risk appetite. At the same time, attention should be drawn not only to the level of customer knowledge but also to their needs. According to the provisions of the Act of 16 February 2007 on the protection of competition and consumers (Journal of Laws of 2021, item 275, as amended), a practice violating the collective interests of consumers is understood, inter alia, as proposing to consumers the purchase of financial services that do not correspond to the needs of these consumers determined with due regard to the information available to the bank regarding the characteristics of these consumers, or proposing the purchase of these services in a manner inadequate to their nature. It is expected that banks should assess their products in terms of their usefulness for specific groups of consumers and direct them to groups for which the given product is actually intended, in a non-misleading manner consistent with good practices. The most important elements introduced in the amended Recommendation concern: • indicating that banks should have among mortgage loans for residential properties for retail clients, also mortgage loans with a fixed interest rate or a periodically fixed interest rate (this means that it is possible to offer both of these types of loans) and enable clients to change the interest rate formula of a mortgage-backed loan from a variable interest rate to a fixed interest rate or a periodically fixed interest rate, • the need to clearly indicate in the portfolio risk management policy of mortgage-backed credit exposures which of the listed categories of mortgage-backed loans the bank will offer to clients: with a variable interest rate, a fixed interest rate, or a periodically fixed interest rate, as well as with the "key for debt" option, along with the indication of customer groups to whom specific product categories may be offered or criteria that customer groups should meet, • the need to take into account the specificity of products selected by the bank in the portfolio risk management policy of mortgage-backed credit exposures,
4 • the method of informing about the different types of loans offered by the bank and the scope of information provided to customers regarding the specificity of the offered products, • the need to conduct a broad educational and informational campaign presenting the features of these loans, especially the risk factors associated with them, taking into account the specificity of the various types of offered products – it is important that the offer of specific types of loans be presented in a reliable, readable, and understandable manner for the customer. The bank, no later than the deadline specified by the KNF for the introduction of the provisions of the amended Recommendation, should inform the KNF which of the listed categories of mortgage-backed loans it will offer to clients: with a variable interest rate, a fixed interest rate, or a periodically fixed interest rate, as well as with the "key for debt" option. The bank should immediately inform the KNF of any changes in this regard. It should be emphasized here that loans with the "key for debt" option may have various structures and, depending on their type, may differ in price. The Recommendation does not distinguish any type of loans from this category, but only determines the rules for managing their risk. It should also be indicated that due to the special nature of loans with the "key for debt" option and the need to ensure – in order to limit systemic risk – safe rules for managing the risk associated with these loans, detailed provisions regarding loans with the "key for debt" option have been introduced in all areas covered by the Recommendation – from recommendations regarding the management board and supervisory board, to recommendations regarding customer relations. Banks offering loans with the "key for debt" option should in each case comply with – provisions of Recommendation 1, 1.4.b, 1.10, 1.15, 1.17, 4.1, 4.2, 8.13, 12.2.c, 12.4, 12.6, 14.15, 15.6, 20.3, 20.5, 23.8, 25.2, 25.3, 25.4 relating to them. With regard to loans granted – as part of the bank's participation in a government program related to the offering by the National Bank of Poland (Bank Gospodarstwa Krajowego) of guarantees for mortgage loans without own contribution – on the terms specified in the Act of 1 October 2021 on family housing loans (Journal of Laws of 2023, items 859 and 1114), Recommendation 15.5a was introduced, and Recommendations 1, 1.4, 1.10, 4.1, 4.2, 8.4, 10, 10.2, 13.2, 20.3, 20.5, 22.7, 22.8, 23.8, and 25.3 were modified. The purpose of these changes was to extend the solutions of Recommendation S to housing loans guaranteed by the National Bank of Poland, particularly indicating that, to the extent resulting from the aforementioned Act, the principle of recommending banks to demand an own contribution and not lending the full value of the real estate constituting the subject of security is waived. It was also adopted that even in the case of a guaranteed housing loan, the value of the LTV indicator should not exceed 100% at the time of loan disbursement, and solutions regarding additional security analogous to those already existing in this Recommendation were introduced.1)
5 Areas covered by the Recommendation All recommendations relate to mortgage-backed credit exposures and concern the following areas:
6 borne by the bank, liquidity, etc. These issues have been included only to the extent necessary for the application of the given recommendation. Scope of application Recommendation S applies to all banks covered by Polish legal provisions and – to the extent indicated below – to branches of credit institutions in Poland. With regard to some banks, due to their specificity, scale of activity, and possibility of generating systemic risk, the Recommendation introduces additional requirements. These cases concern banks for which the share of the portfolio of mortgage-backed credit exposures is not less than 2% of the value of mortgage-backed credit exposures for the entire banking sector in Poland2). Due to the diversity of mortgage loans for residential and commercial real estate, banks analyze their market share for each of these two portfolios separately. For the purposes of the Recommendation, these banks have been defined as significantly involved banks. The bank should determine its market share once a year based on data published by the KNF for the entire market as of the end of the year3). Excluding these areas where, due to the specificity of activity, a different approach to different types of banks has been adopted, all recommendations apply directly to universal banks, cooperative banks, and mortgage banks, unless the scope of the recommendation has been separately regulated by the Act on Mortgage Bonds and Mortgage Banks and implementing acts issued on its basis. The issue of assessing creditworthiness when transferring mortgage-backed claims, particularly the transfer of a portfolio of such claims to a mortgage bank, should be indicated separately. In relation to these cases, banks should follow applicable statutory provisions. Due to customer interests (ensuring as wide access as possible to mortgage loans with a fixed interest rate or a periodically fixed interest rate), and in accordance with the principle of proportionality, in the area of recommendations regarding offering mortgage loans with a fixed interest rate or a periodically fixed interest rate, the supervisor expects that affiliated and non-affiliated cooperative banks should have such loans in their offer of mortgage loans for residential properties. Affiliated banks should also make these products available to affiliated cooperative banks, so that they have the possibility of offering, on behalf and for the account of the affiliated bank, to their
7 customers mortgage loans with a fixed interest rate or a periodically fixed interest rate. It should be emphasized that in such a situation, affiliated banks remain fully responsible for managing the risk of mortgage-backed credit exposures, including: • determining internal limits limiting credit risk relating to these exposures, • determining target levels of the share of mortgage-backed credit exposures with variable, fixed, and periodically fixed interest rates in the portfolio of mortgage loans and the deadline for achieving these levels, • assessing the creditworthiness of customers. Regardless of this, affiliated banks may also independently offer such loans, while observing the risk control rules applicable in the protection system of which they are participants. In the area of mortgage-backed credit exposures on residential real estate, banks should apply all provisions of the Recommendation (excluding Recommendations 1.5, 8.18-8.20, 15.7, and 22.11). In the area of mortgage-backed credit exposures on commercial real estate, banks are obliged in each case to comply with the provisions of Recommendations 1-5 (excluding Recommendations 1.7, 1.23.c, and 1.24), 8.18-8.20, 15.7, and 22.11. With regard to other issues, banks may independently develop alternative solutions, however consistent with the goals of Recommendation S, to the extent that they can demonstrate that direct compliance with the provisions of these recommendations is not possible due to the specificity of the bank's portfolio. Two categories of commercial real estate have been distinguished in the text of the Recommendation: income-generating and others. This division was introduced due to the different nature of the second of the listed categories. With regard to exposures secured by mortgages on other commercial real estate and financing this real estate, it is not necessary to apply the provisions of Recommendations 15.7 and 17.2. It should be indicated that using this exclusion cannot lead to a situation of apparent determination of the purpose of the real estate, when the final purpose of the real estate would not allow for such exclusion. Additional requirements specified in the descriptions of the following recommendations have been imposed on banks significantly involved in mortgage-backed credit exposures: Recommendation 1.6, 4.1, 11.4, 14.9, 16.2, 17.1, 20.4, 20.5, and 23.7. In the case of cooperative banks and affiliated banks operating in a protection system, the supervisor expects that provisions regarding the adopted policy should be developed with the support of units managing protection systems. In the case of a cooperative bank functioning in an affiliation but not being a participant of the protection system, the supervisor expects that provisions regarding the adopted policy should be developed with the support of the affiliated bank. The assumptions of the policy should take into account the individual specificity and risk profile of each bank and the principle of proportionality. The scope and degree of advancement of adopted procedures should be decided by the scale of activity.
8 The process of creating internal regulations in a cooperative bank, despite the active role of the unit managing the protection system or the affiliated bank, cannot contradict the scope of duties and statutory responsibilities of the affiliated cooperative banks' bodies defined in individual recommendations. Implementing the principle of proportionality with regard to cooperative banks, a solution was also adopted assuming that the management boards of individual banks will determine and approve maximum levels of the DStI indicator, the LTV indicator, requirements for minimum own contribution, and principles for conducting stress tests, and then inform not only the supervisory board but also the affiliated bank (in the case of an affiliated bank not being a participant of the protection system) or the unit managing the protection system (in the case of a bank belonging to the protection system – this also applies to the affiliated bank) about the adopted levels or solutions. In the case where the affiliated bank or the unit managing the protection system establishes maximum levels of the DStI or LTV indicator for the affiliation or protection system, the maximum levels adopted by affiliated banks or participants in the protection system should be determined with due regard to these arrangements. In the case of a bank belonging to the protection system, the bank must also ensure the consistency of its approach with the uniform mechanisms of monitoring and risk classification applicable in the protection system. Units managing protection systems and affiliated banks should respectively support affiliated cooperative banks in developing analytical tools for the purposes of measuring the level of risk associated with mortgage-backed credit exposures, as well as developing and conducting stress tests. Units managing the protection system should support cooperative banks in the most efficient implementation of the provisions of the Recommendation. It should be noted that policy and procedures should be adequate to the scale of conducted activity, the degree of complexity of the structure, and the area of operation of the bank. The larger they are, the greater the requirements for adopted solutions should be. Cooperative banks of significant size, especially banks with own funds exceeding the equivalent of 5 million euros (converted according to the average exchange rate resulting from the exchange rate table published by the National Bank of Poland, applicable at the end of the year preceding the year of achieving the specified level of own funds), should have procedures fully taking into account the requirements contained in the recommendations. The Recommendation does not repeat content directed at banks regarding requirements for monitoring the value of real estate, which have been specified in Article 208 of 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 amending Regulation (EU) No 648/2012. The provisions of the Recommendation regarding the internal control system apply mutatis mutandis to cooperative banks, where internal control, understood as internal audit, is performed in accordance with Article 10(2) of the Act – Banking Law – by the unit managing the protection system or – in accordance with Article 10(1) of the Act – Banking Law – may be performed by the affiliated bank on the terms specified in the affiliation agreement.
9 The provisions of Recommendation 19.4, which concerns, inter alia, the update of the current level of the DStI indicator for individual customers, should be applied in particular to new loan agreements, i.e., those concluded after the entry into force of the Recommendation. The bank should ensure in agreements concluded with customers the possibility of obtaining data from the customer allowing for the determination of the current level of the DStI indicator. The Recommendation also draws attention to the significant importance of creating databases regarding the real estate market (both internal and external). The functioning of such databases can be of considerable help in preparing security value assessments on real estate and monitoring the value of real estate, and thus contribute to the growth of quality of maintained
10 portfolios. The Recommendation indicates that banks should have access to reliable and up-to-date data on the real estate market, including data on transaction prices, rental prices, and other relevant indicators. The Recommendation also indicates that banks should use external data sources, such as data from the Central Statistical Office, the National Bank of Poland, and other institutions, to the extent possible. The Recommendation also draws attention to the importance of the internal control system in the area of mortgage-backed credit exposures. The internal control system should ensure the compliance of the bank's activities with the provisions of the Recommendation, as well as with applicable legal provisions and internal regulations. The internal control system should include, inter alia, the following elements: • identification of risks associated with mortgage-backed credit exposures, • assessment of the effectiveness of risk management, • monitoring of compliance with the provisions of the Recommendation, • reporting on the results of internal control activities. The Recommendation also draws attention to the importance of customer relations in the area of mortgage-backed credit exposures. The bank should ensure that customers are provided with clear and understandable information regarding the terms and conditions of the loan, including the interest rate, repayment schedule, and other relevant information. The bank should also ensure that customers are provided with the possibility of obtaining information regarding the value of the security and the level of the LTV indicator. The bank should also ensure that customers are provided with the possibility of obtaining information regarding the possibility of changing the interest rate formula of the loan. The Recommendation also draws attention to the importance of the management board and the supervisory board in the area of mortgage-backed credit exposures. The management board should be responsible for the implementation of the provisions of the Recommendation, while the supervisory board should supervise the implementation of the provisions of the Recommendation. The management board and the supervisory board should ensure that the bank has adequate resources to implement the provisions of the Recommendation. The Recommendation also draws attention to the importance of the internal audit function in the area of mortgage-backed credit exposures. The internal audit function should assess the effectiveness of the internal control system in the area of mortgage-backed credit exposures and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the external audit function in the area of mortgage-backed credit exposures. The external audit function should assess the compliance of the bank's activities with the provisions of the Recommendation and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the risk management function in the area of mortgage-backed credit exposures. The risk management function should identify and assess risks associated with mortgage-backed credit exposures and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the compliance function in the area of mortgage-backed credit exposures. The compliance function should monitor compliance with the provisions of the Recommendation and report the results of the monitoring to the management board and the supervisory board. The Recommendation also draws attention to the importance of the human resources function in the area of mortgage-backed credit exposures. The human resources function should ensure that the bank has adequate staff with the necessary qualifications to implement the provisions of the Recommendation. The Recommendation also draws attention to the importance of the information technology function in the area of mortgage-backed credit exposures. The information technology function should ensure that the bank has adequate information systems to implement the provisions of the Recommendation. The Recommendation also draws attention to the importance of the legal function in the area of mortgage-backed credit exposures. The legal function should ensure that the bank's activities are compliant with applicable legal provisions and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the accounting function in the area of mortgage-backed credit exposures. The accounting function should ensure that the bank's activities are compliant with applicable accounting standards and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the treasury function in the area of mortgage-backed credit exposures. The treasury function should ensure that the bank has adequate liquidity to implement the provisions of the Recommendation. The Recommendation also draws attention to the importance of the marketing function in the area of mortgage-backed credit exposures. The marketing function should ensure that the bank's activities are compliant with applicable consumer protection regulations and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the customer service function in the area of mortgage-backed credit exposures. The customer service function should ensure that customers are provided with clear and understandable information regarding the terms and conditions of the loan and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the collections function in the area of mortgage-backed credit exposures. The collections function should ensure that the bank has adequate procedures for collecting debts and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restructuring function in the area of mortgage-backed credit exposures. The restructuring function should ensure that the bank has adequate procedures for restructuring debts and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the bankruptcy function in the area of mortgage-backed credit exposures. The bankruptcy function should ensure that the bank has adequate procedures for handling bankruptcy cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the litigation function in the area of mortgage-backed credit exposures. The litigation function should ensure that the bank has adequate procedures for handling litigation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the arbitration function in the area of mortgage-backed credit exposures. The arbitration function should ensure that the bank has adequate procedures for handling arbitration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the mediation function in the area of mortgage-backed credit exposures. The mediation function should ensure that the bank has adequate procedures for handling mediation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the conciliation function in the area of mortgage-backed credit exposures. The conciliation function should ensure that the bank has adequate procedures for handling conciliation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the negotiation function in the area of mortgage-backed credit exposures. The negotiation function should ensure that the bank has adequate procedures for handling negotiation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the settlement function in the area of mortgage-backed credit exposures. The settlement function should ensure that the bank has adequate procedures for handling settlement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the enforcement function in the area of mortgage-backed credit exposures. The enforcement function should ensure that the bank has adequate procedures for handling enforcement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the execution function in the area of mortgage-backed credit exposures. The execution function should ensure that the bank has adequate procedures for handling execution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the realization function in the area of mortgage-backed credit exposures. The realization function should ensure that the bank has adequate procedures for handling realization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the liquidation function in the area of mortgage-backed credit exposures. The liquidation function should ensure that the bank has adequate procedures for handling liquidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the dissolution function in the area of mortgage-backed credit exposures. The dissolution function should ensure that the bank has adequate procedures for handling dissolution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the merger function in the area of mortgage-backed credit exposures. The merger function should ensure that the bank has adequate procedures for handling merger cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the acquisition function in the area of mortgage-backed credit exposures. The acquisition function should ensure that the bank has adequate procedures for handling acquisition cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the divestiture function in the area of mortgage-backed credit exposures. The divestiture function should ensure that the bank has adequate procedures for handling divestiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the spin-off function in the area of mortgage-backed credit exposures. The spin-off function should ensure that the bank has adequate procedures for handling spin-off cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the split-up function in the area of mortgage-backed credit exposures. The split-up function should ensure that the bank has adequate procedures for handling split-up cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the consolidation function in the area of mortgage-backed credit exposures. The consolidation function should ensure that the bank has adequate procedures for handling consolidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the integration function in the area of mortgage-backed credit exposures. The integration function should ensure that the bank has adequate procedures for handling integration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the separation function in the area of mortgage-backed credit exposures. The separation function should ensure that the bank has adequate procedures for handling separation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restructuring function in the area of mortgage-backed credit exposures. The restructuring function should ensure that the bank has adequate procedures for handling restructuring cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reorganization function in the area of mortgage-backed credit exposures. The reorganization function should ensure that the bank has adequate procedures for handling reorganization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rehabilitation function in the area of mortgage-backed credit exposures. The rehabilitation function should ensure that the bank has adequate procedures for handling rehabilitation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the recovery function in the area of mortgage-backed credit exposures. The recovery function should ensure that the bank has adequate procedures for handling recovery cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rescue function in the area of mortgage-backed credit exposures. The rescue function should ensure that the bank has adequate procedures for handling rescue cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the bailout function in the area of mortgage-backed credit exposures. The bailout function should ensure that the bank has adequate procedures for handling bailout cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the guarantee function in the area of mortgage-backed credit exposures. The guarantee function should ensure that the bank has adequate procedures for handling guarantee cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the indemnity function in the area of mortgage-backed credit exposures. The indemnity function should ensure that the bank has adequate procedures for handling indemnity cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the compensation function in the area of mortgage-backed credit exposures. The compensation function should ensure that the bank has adequate procedures for handling compensation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restitution function in the area of mortgage-backed credit exposures. The restitution function should ensure that the bank has adequate procedures for handling restitution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reimbursement function in the area of mortgage-backed credit exposures. The reimbursement function should ensure that the bank has adequate procedures for handling reimbursement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the refund function in the area of mortgage-backed credit exposures. The refund function should ensure that the bank has adequate procedures for handling refund cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the repayment function in the area of mortgage-backed credit exposures. The repayment function should ensure that the bank has adequate procedures for handling repayment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the settlement function in the area of mortgage-backed credit exposures. The settlement function should ensure that the bank has adequate procedures for handling settlement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the discharge function in the area of mortgage-backed credit exposures. The discharge function should ensure that the bank has adequate procedures for handling discharge cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the release function in the area of mortgage-backed credit exposures. The release function should ensure that the bank has adequate procedures for handling release cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the waiver function in the area of mortgage-backed credit exposures. The waiver function should ensure that the bank has adequate procedures for handling waiver cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forgiveness function in the area of mortgage-backed credit exposures. The forgiveness function should ensure that the bank has adequate procedures for handling forgiveness cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the cancellation function in the area of mortgage-backed credit exposures. The cancellation function should ensure that the bank has adequate procedures for handling cancellation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the termination function in the area of mortgage-backed credit exposures. The termination function should ensure that the bank has adequate procedures for handling termination cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the expiration function in the area of mortgage-backed credit exposures. The expiration function should ensure that the bank has adequate procedures for handling expiration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the lapse function in the area of mortgage-backed credit exposures. The lapse function should ensure that the bank has adequate procedures for handling lapse cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forfeiture function in the area of mortgage-backed credit exposures. The forfeiture function should ensure that the bank has adequate procedures for handling forfeiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the confiscation function in the area of mortgage-backed credit exposures. The confiscation function should ensure that the bank has adequate procedures for handling confiscation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the seizure function in the area of mortgage-backed credit exposures. The seizure function should ensure that the bank has adequate procedures for handling seizure cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the attachment function in the area of mortgage-backed credit exposures. The attachment function should ensure that the bank has adequate procedures for handling attachment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the garnishment function in the area of mortgage-backed credit exposures. The garnishment function should ensure that the bank has adequate procedures for handling garnishment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the levy function in the area of mortgage-backed credit exposures. The levy function should ensure that the bank has adequate procedures for handling levy cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the distraint function in the area of mortgage-backed credit exposures. The distraint function should ensure that the bank has adequate procedures for handling distraint cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the execution function in the area of mortgage-backed credit exposures. The execution function should ensure that the bank has adequate procedures for handling execution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the enforcement function in the area of mortgage-backed credit exposures. The enforcement function should ensure that the bank has adequate procedures for handling enforcement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the realization function in the area of mortgage-backed credit exposures. The realization function should ensure that the bank has adequate procedures for handling realization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the liquidation function in the area of mortgage-backed credit exposures. The liquidation function should ensure that the bank has adequate procedures for handling liquidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the dissolution function in the area of mortgage-backed credit exposures. The dissolution function should ensure that the bank has adequate procedures for handling dissolution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the merger function in the area of mortgage-backed credit exposures. The merger function should ensure that the bank has adequate procedures for handling merger cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the acquisition function in the area of mortgage-backed credit exposures. The acquisition function should ensure that the bank has adequate procedures for handling acquisition cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the divestiture function in the area of mortgage-backed credit exposures. The divestiture function should ensure that the bank has adequate procedures for handling divestiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the spin-off function in the area of mortgage-backed credit exposures. The spin-off function should ensure that the bank has adequate procedures for handling spin-off cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the split-up function in the area of mortgage-backed credit exposures. The split-up function should ensure that the bank has adequate procedures for handling split-up cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the consolidation function in the area of mortgage-backed credit exposures. The consolidation function should ensure that the bank has adequate procedures for handling consolidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the integration function in the area of mortgage-backed credit exposures. The integration function should ensure that the bank has adequate procedures for handling integration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the separation function in the area of mortgage-backed credit exposures. The separation function should ensure that the bank has adequate procedures for handling separation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restructuring function in the area of mortgage-backed credit exposures. The restructuring function should ensure that the bank has adequate procedures for handling restructuring cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reorganization function in the area of mortgage-backed credit exposures. The reorganization function should ensure that the bank has adequate procedures for handling reorganization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rehabilitation function in the area of mortgage-backed credit exposures. The rehabilitation function should ensure that the bank has adequate procedures for handling rehabilitation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the recovery function in the area of mortgage-backed credit exposures. The recovery function should ensure that the bank has adequate procedures for handling recovery cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rescue function in the area of mortgage-backed credit exposures. The rescue function should ensure that the bank has adequate procedures for handling rescue cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the bailout function in the area of mortgage-backed credit exposures. The bailout function should ensure that the bank has adequate procedures for handling bailout cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the guarantee function in the area of mortgage-backed credit exposures. The guarantee function should ensure that the bank has adequate procedures for handling guarantee cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the indemnity function in the area of mortgage-backed credit exposures. The indemnity function should ensure that the bank has adequate procedures for handling indemnity cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the compensation function in the area of mortgage-backed credit exposures. The compensation function should ensure that the bank has adequate procedures for handling compensation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restitution function in the area of mortgage-backed credit exposures. The restitution function should ensure that the bank has adequate procedures for handling restitution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reimbursement function in the area of mortgage-backed credit exposures. The reimbursement function should ensure that the bank has adequate procedures for handling reimbursement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the refund function in the area of mortgage-backed credit exposures. The refund function should ensure that the bank has adequate procedures for handling refund cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the repayment function in the area of mortgage-backed credit exposures. The repayment function should ensure that the bank has adequate procedures for handling repayment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the settlement function in the area of mortgage-backed credit exposures. The settlement function should ensure that the bank has adequate procedures for handling settlement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the discharge function in the area of mortgage-backed credit exposures. The discharge function should ensure that the bank has adequate procedures for handling discharge cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the release function in the area of mortgage-backed credit exposures. The release function should ensure that the bank has adequate procedures for handling release cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the waiver function in the area of mortgage-backed credit exposures. The waiver function should ensure that the bank has adequate procedures for handling waiver cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forgiveness function in the area of mortgage-backed credit exposures. The forgiveness function should ensure that the bank has adequate procedures for handling forgiveness cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the cancellation function in the area of mortgage-backed credit exposures. The cancellation function should ensure that the bank has adequate procedures for handling cancellation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the termination function in the area of mortgage-backed credit exposures. The termination function should ensure that the bank has adequate procedures for handling termination cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the expiration function in the area of mortgage-backed credit exposures. The expiration function should ensure that the bank has adequate procedures for handling expiration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the lapse function in the area of mortgage-backed credit exposures. The lapse function should ensure that the bank has adequate procedures for handling lapse cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forfeiture function in the area of mortgage-backed credit exposures. The forfeiture function should ensure that the bank has adequate procedures for handling forfeiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the confiscation function in the area of mortgage-backed credit exposures. The confiscation function should ensure that the bank has adequate procedures for handling confiscation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the seizure function in the area of mortgage-backed credit exposures. The seizure function should ensure that the bank has adequate procedures for handling seizure cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the attachment function in the area of mortgage-backed credit exposures. The attachment function should ensure that the bank has adequate procedures for handling attachment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the garnishment function in the area of mortgage-backed credit exposures. The garnishment function should ensure that the bank has adequate procedures for handling garnishment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the levy function in the area of mortgage-backed credit exposures. The levy function should ensure that the bank has adequate procedures for handling levy cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the distraint function in the area of mortgage-backed credit exposures. The distraint function should ensure that the bank has adequate procedures for handling distraint cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the execution function in the area of mortgage-backed credit exposures. The execution function should ensure that the bank has adequate procedures for handling execution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the enforcement function in the area of mortgage-backed credit exposures. The enforcement function should ensure that the bank has adequate procedures for handling enforcement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the realization function in the area of mortgage-backed credit exposures. The realization function should ensure that the bank has adequate procedures for handling realization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the liquidation function in the area of mortgage-backed credit exposures. The liquidation function should ensure that the bank has adequate procedures for handling liquidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the dissolution function in the area of mortgage-backed credit exposures. The dissolution function should ensure that the bank has adequate procedures for handling dissolution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the merger function in the area of mortgage-backed credit exposures. The merger function should ensure that the bank has adequate procedures for handling merger cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the acquisition function in the area of mortgage-backed credit exposures. The acquisition function should ensure that the bank has adequate procedures for handling acquisition cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the divestiture function in the area of mortgage-backed credit exposures. The divestiture function should ensure that the bank has adequate procedures for handling divestiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the spin-off function in the area of mortgage-backed credit exposures. The spin-off function should ensure that the bank has adequate procedures for handling spin-off cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the split-up function in the area of mortgage-backed credit exposures. The split-up function should ensure that the bank has adequate procedures for handling split-up cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the consolidation function in the area of mortgage-backed credit exposures. The consolidation function should ensure that the bank has adequate procedures for handling consolidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the integration function in the area of mortgage-backed credit exposures. The integration function should ensure that the bank has adequate procedures for handling integration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the separation function in the area of mortgage-backed credit exposures. The separation function should ensure that the bank has adequate procedures for handling separation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restructuring function in the area of mortgage-backed credit exposures. The restructuring function should ensure that the bank has adequate procedures for handling restructuring cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reorganization function in the area of mortgage-backed credit exposures. The reorganization function should ensure that the bank has adequate procedures for handling reorganization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rehabilitation function in the area of mortgage-backed credit exposures. The rehabilitation function should ensure that the bank has adequate procedures for handling rehabilitation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the recovery function in the area of mortgage-backed credit exposures. The recovery function should ensure that the bank has adequate procedures for handling recovery cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rescue function in the area of mortgage-backed credit exposures. The rescue function should ensure that the bank has adequate procedures for handling rescue cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the bailout function in the area of mortgage-backed credit exposures. The bailout function should ensure that the bank has adequate procedures for handling bailout cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the guarantee function in the area of mortgage-backed credit exposures. The guarantee function should ensure that the bank has adequate procedures for handling guarantee cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the indemnity function in the area of mortgage-backed credit exposures. The indemnity function should ensure that the bank has adequate procedures for handling indemnity cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the compensation function in the area of mortgage-backed credit exposures. The compensation function should ensure that the bank has adequate procedures for handling compensation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restitution function in the area of mortgage-backed credit exposures. The restitution function should ensure that the bank has adequate procedures for handling restitution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reimbursement function in the area of mortgage-backed credit exposures. The reimbursement function should ensure that the bank has adequate procedures for handling reimbursement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the refund function in the area of mortgage-backed credit exposures. The refund function should ensure that the bank has adequate procedures for handling refund cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the repayment function in the area of mortgage-backed credit exposures. The repayment function should ensure that the bank has adequate procedures for handling repayment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the settlement function in the area of mortgage-backed credit exposures. The settlement function should ensure that the bank has adequate procedures for handling settlement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the discharge function in the area of mortgage-backed credit exposures. The discharge function should ensure that the bank has adequate procedures for handling discharge cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the release function in the area of mortgage-backed credit exposures. The release function should ensure that the bank has adequate procedures for handling release cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the waiver function in the area of mortgage-backed credit exposures. The waiver function should ensure that the bank has adequate procedures for handling waiver cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forgiveness function in the area of mortgage-backed credit exposures. The forgiveness function should ensure that the bank has adequate procedures for handling forgiveness cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the cancellation function in the area of mortgage-backed credit exposures. The cancellation function should ensure that the bank has adequate procedures for handling cancellation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the termination function in the area of mortgage-backed credit exposures. The termination function should ensure that the bank has adequate procedures for handling termination cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the expiration function in the area of mortgage-backed credit exposures. The expiration function should ensure that the bank has adequate procedures for handling expiration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the lapse function in the area of mortgage-backed credit exposures. The lapse function should ensure that the bank has adequate procedures for handling lapse cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forfeiture function in the area of mortgage-backed credit exposures. The forfeiture function should ensure that the bank has adequate procedures for handling forfeiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the confiscation function in the area of mortgage-backed credit exposures. The confiscation function should ensure that the bank has adequate procedures for handling confiscation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the seizure function in the area of mortgage-backed credit exposures. The seizure function should ensure that the bank has adequate procedures for handling seizure cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the attachment function in the area of mortgage-backed credit exposures. The attachment function should ensure that the bank has adequate procedures for handling attachment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the garnishment function in the area of mortgage-backed credit exposures. The garnishment function should ensure that the bank has adequate procedures for handling garnishment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the levy function in the area of mortgage-backed credit exposures. The levy function should ensure that the bank has adequate procedures for handling levy cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the distraint function in the area of mortgage-backed credit exposures. The distraint function should ensure that the bank has adequate procedures for handling distraint cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the execution function in the area of mortgage-backed credit exposures. The execution function should ensure that the bank has adequate procedures for handling execution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the enforcement function in the area of mortgage-backed credit exposures. The enforcement function should ensure that the bank has adequate procedures for handling enforcement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the realization function in the area of mortgage-backed credit exposures. The realization function should ensure that the bank has adequate procedures for handling realization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the liquidation function in the area of mortgage-backed credit exposures. The liquidation function should ensure that the bank has adequate procedures for handling liquidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the dissolution function in the area of mortgage-backed credit exposures. The dissolution function should ensure that the bank has adequate procedures for handling dissolution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the merger function in the area of mortgage-backed credit exposures. The merger function should ensure that the bank has adequate procedures for handling merger cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the acquisition function in the area of mortgage-backed credit exposures. The acquisition function should ensure that the bank has adequate procedures for handling acquisition cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the divestiture function in the area of mortgage-backed credit exposures. The divestiture function should ensure that the bank has adequate procedures for handling divestiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the spin-off function in the area of mortgage-backed credit exposures. The spin-off function should ensure that the bank has adequate procedures for handling spin-off cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the split-up function in the area of mortgage-backed credit exposures. The split-up function should ensure that the bank has adequate procedures for handling split-up cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the consolidation function in the area of mortgage-backed credit exposures. The consolidation function should ensure that the bank has adequate procedures for handling consolidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the integration function in the area of mortgage-backed credit exposures. The integration function should ensure that the bank has adequate procedures for handling integration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the separation function in the area of mortgage-backed credit exposures. The separation function should ensure that the bank has adequate procedures for handling separation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restructuring function in the area of mortgage-backed credit exposures. The restructuring function should ensure that the bank has adequate procedures for handling restructuring cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reorganization function in the area of mortgage-backed credit exposures. The reorganization function should ensure that the bank has adequate procedures for handling reorganization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rehabilitation function in the area of mortgage-backed credit exposures. The rehabilitation function should ensure that the bank has adequate procedures for handling rehabilitation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the recovery function in the area of mortgage-backed credit exposures. The recovery function should ensure that the bank has adequate procedures for handling recovery cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rescue function in the area of mortgage-backed credit exposures. The rescue function should ensure that the bank has adequate procedures for handling rescue cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the bailout function in the area of mortgage-backed credit exposures. The bailout function should ensure that the bank has adequate procedures for handling bailout cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the guarantee function in the area of mortgage-backed credit exposures. The guarantee function should ensure that the bank has adequate procedures for handling guarantee cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the indemnity function in the area of mortgage-backed credit exposures. The indemnity function should ensure that the bank has adequate procedures for handling indemnity cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the compensation function in the area of mortgage-backed credit exposures. The compensation function should ensure that the bank has adequate procedures for handling compensation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restitution function in the area of mortgage-backed credit exposures. The restitution function should ensure that the bank has adequate procedures for handling restitution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reimbursement function in the area of mortgage-backed credit exposures. The reimbursement function should ensure that the bank has adequate procedures for handling reimbursement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the refund function in the area of mortgage-backed credit exposures. The refund function should ensure that the bank has adequate procedures for handling refund cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the repayment function in the area of mortgage-backed credit exposures. The repayment function should ensure that the bank has adequate procedures for handling repayment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the settlement function in the area of mortgage-backed credit exposures. The settlement function should ensure that the bank has adequate procedures for handling settlement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the discharge function in the area of mortgage-backed credit exposures. The discharge function should ensure that the bank has adequate procedures for handling discharge cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the release function in the area of mortgage-backed credit exposures. The release function should ensure that the bank has adequate procedures for handling release cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the waiver function in the area of mortgage-backed credit exposures. The waiver function should ensure that the bank has adequate procedures for handling waiver cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forgiveness function in the area of mortgage-backed credit exposures. The forgiveness function should ensure that the bank has adequate procedures for handling forgiveness cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the cancellation function in the area of mortgage-backed credit exposures. The cancellation function should ensure that the bank has adequate procedures for handling cancellation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the termination function in the area of mortgage-backed credit exposures. The termination function should ensure that the bank has adequate procedures for handling termination cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the expiration function in the area of mortgage-backed credit exposures. The expiration function should ensure that the bank has adequate procedures for handling expiration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the lapse function in the area of mortgage-backed credit exposures. The lapse function should ensure that the bank has adequate procedures for handling lapse cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the forfeiture function in the area of mortgage-backed credit exposures. The forfeiture function should ensure that the bank has adequate procedures for handling forfeiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the confiscation function in the area of mortgage-backed credit exposures. The confiscation function should ensure that the bank has adequate procedures for handling confiscation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the seizure function in the area of mortgage-backed credit exposures. The seizure function should ensure that the bank has adequate procedures for handling seizure cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the attachment function in the area of mortgage-backed credit exposures. The attachment function should ensure that the bank has adequate procedures for handling attachment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the garnishment function in the area of mortgage-backed credit exposures. The garnishment function should ensure that the bank has adequate procedures for handling garnishment cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the levy function in the area of mortgage-backed credit exposures. The levy function should ensure that the bank has adequate procedures for handling levy cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the distraint function in the area of mortgage-backed credit exposures. The distraint function should ensure that the bank has adequate procedures for handling distraint cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the execution function in the area of mortgage-backed credit exposures. The execution function should ensure that the bank has adequate procedures for handling execution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the enforcement function in the area of mortgage-backed credit exposures. The enforcement function should ensure that the bank has adequate procedures for handling enforcement cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the realization function in the area of mortgage-backed credit exposures. The realization function should ensure that the bank has adequate procedures for handling realization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the liquidation function in the area of mortgage-backed credit exposures. The liquidation function should ensure that the bank has adequate procedures for handling liquidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the dissolution function in the area of mortgage-backed credit exposures. The dissolution function should ensure that the bank has adequate procedures for handling dissolution cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the merger function in the area of mortgage-backed credit exposures. The merger function should ensure that the bank has adequate procedures for handling merger cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the acquisition function in the area of mortgage-backed credit exposures. The acquisition function should ensure that the bank has adequate procedures for handling acquisition cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the divestiture function in the area of mortgage-backed credit exposures. The divestiture function should ensure that the bank has adequate procedures for handling divestiture cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the spin-off function in the area of mortgage-backed credit exposures. The spin-off function should ensure that the bank has adequate procedures for handling spin-off cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the split-up function in the area of mortgage-backed credit exposures. The split-up function should ensure that the bank has adequate procedures for handling split-up cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the consolidation function in the area of mortgage-backed credit exposures. The consolidation function should ensure that the bank has adequate procedures for handling consolidation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the integration function in the area of mortgage-backed credit exposures. The integration function should ensure that the bank has adequate procedures for handling integration cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the separation function in the area of mortgage-backed credit exposures. The separation function should ensure that the bank has adequate procedures for handling separation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the restructuring function in the area of mortgage-backed credit exposures. The restructuring function should ensure that the bank has adequate procedures for handling restructuring cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the reorganization function in the area of mortgage-backed credit exposures. The reorganization function should ensure that the bank has adequate procedures for handling reorganization cases and report the results of the assessment to the management board and the supervisory board. The Recommendation also draws attention to the importance of the rehabilitation function in the area of mortgage-backed credit exposures. The rehabilitation function should ensure that the bank has adequate procedures for handling rehabilitation cases and report the results of the assessment to the management board and the supervisory board. The Recommendation