Coronavirus and liquidity support measures through the banking system: some clarifications


published on 1 April 2020 | reading time approx. 1,5 minutes


With regard to the measures provided for by the Decree “Cura Italia” in support of liquidity of companies, the interpretative clarifications offered by the communication dated 23 March 2020 of the Bank of Italy and by the circular letter of 24 March 2020 of the Italian Banking Association (ABI) are described below.


In particular, the Bank of Italy has instructed financial intermediaries to take into account, for the purposes of reporting to the Central Credit Register, the provisions of Article 56, paragraph 2 of the Decree “Cura Italia” (providing for extraordinary moratorium on loans and credit lines to micro, small and medium-sized enterprises), pointing out that, in any case, the funded entity cannot be classified as non-performing from the time the benefit provided for in the above article has been granted.
Again in relation to the financial support measures provided under Article 56, paragraph 2 of the Decree, the Italian Banking Association has clarified the following:  

  • the moratorium of loan or lease instalments (referred to under Article 56, paragraph 2, lett. c) also includes the instalment due on 30 September 2020, which therefore does not have to be paid;
  • companies that have already obtained suspension or restructuring measures for the same loan in the previous 24 months may also access the measures, provided they are “in bonis” (i.e. they do not have debt positions classified as bad loans, unlikely to pay, past due and/or non-performing receivables);
  • companies interested in accessing the measures shall send a communication to their bank/financial intermediary (via certified e-mail or other means keeping track of the communication), jointly with a self-certification that they have suffered a temporary shortage of liquidity due to the Covid-19 emergency. It should be noted, however, that the bank shall not carry out a discretionary assessment of the situation or verify the truthfulness of the information therein provided, but simply accept communications of moratorium that comply with the requirements of the Decree.

Finally, with reference to the Guarantee Fund for SMEs and the measures referred to under Article 49 of the Decree “Cura Italia”, ABI underlines the provisions of the Manager of the Fund in the circular letter nr. 8/2020, namely that for transactions for which banks or financial intermediaries have granted, even on their own initiative, a moratorium of the instalments, or of the principal only, the duration of the Fund's guarantee is extended even if the companies have debt positions classified by the bank as non-performing and for loans with instalments overdue for more than 90 days.

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