The Central Bank does acknowledge the need to be careful in the design of loan modification techniques and for modelling of the capital implications of any plans in this area before targets are set.
But it is important that this piloting and modelling is done in time to  6  BIS central bankers’ speeches  feed into the next PCAR process to develop an updated picture on mortgage portfolio loan losses. The banks then need to as soon as possible thereafter to start implementing their loan modification programmes in earnest.