Credit event data only needs to be provided for the primary obligor. However, if the primary borrower is not defined it is acceptable to report data for all borrowers, guarantors etc. that are associated with the receivable.
If a past credit event (for example, bankruptcy or credit discharge) is known to the issuer at the date on which the tranche is first issued, then this should be reported in AP402 and AP403. There is no time limit applicable to this field - simply report what was known as at the issue date in relation to credit.
The data in the publicly reported pool level template should represent the sum of the loan level fields reported to the Reserve Bank. For example, RL012 in the public pool level reporting template should reflect the summation of the individual RL012 fields in the loan level template that is reported to the Reserve Bank.
If the obligor is an individual then they should be classed as a ‘consumer obligor’ regardless of their employment situation. The ‘government obligor’ is specifically for contracts where the obligor is a government related entity. So if the financing contract is with a government-related entity the obligor is ‘government’; if the contract is with an individual the obligor is ‘consumer’. An obligor cannot be both ‘government’ and ‘commercial’.
The definition of a ‘consumer obligor’ is any instance where the financing contract is with an individual. If the financing contract is with an entity then it is either a ‘commercial obligor’ or ‘government obligor’ depending on the entity type.