The Commission is also conducting a benchmarking review of loan enforcement (including insolvency) regimes to establish a detailed and reliable picture of the outcomes that banks experience when faced with defaulting loans in terms of delays, costs and value-recovery.

maximising recovery for non-performing loans, while minimising incentives for strategic default by borrowers.

maximising recovery for non-performing loans, while minimising incentives for strategic default by borrowers. This shall include easing constraints on the seizure of collateral and proper monitoring and managing of non-performing loans.

As a consequence of that review, changes should be made in the areas of financial sector reform, fiscal policy and structural reforms, reflecting the steps taken by the Cypriot authorities by the first quarter of 2015, in particular with regard to: (i) continuing to closely monitor the liquidity situation of the banking sector; (ii) streamlining the regulation and supervision of insurance companies and pension funds; (iii) further measures to strengthen the banks' management of non-performing loans and ensure long-term sustainable restructuring solutions, including targets for the work-out of non-performing loans and a strategic default study; (iv) the submission of a legal proposal enabling the sale of loans; (v) the presentation of a ...[+++]legal proposal ensuring the transfer of issued title deeds without delay while safeguarding against abuse; (vi) the monitoring on a continuous basis of the implementation and performance of the insolvency and foreclosure frameworks, ensuring that they support their objectives and principles; (vii) to reflect the fiscal performance in the first quarter of 2015, a revision of the 2015 primary balance target to a surplus of at least EUR 264 000 000 (1,5 % of GDP) and further adjustments to the primary surplus target for 2016-2018, also to remain in line with the adjustment path prescribed by the Stability and Growth Pact; (viii) the full implementation of a National Health System (NHS) by 2017; (ix) the operationalisation of the new integrated tax agency by setting up a single registration process and approving a new tax procedure code; (x) the adoption of a plan for the public administration reform leading to the improvement of the wage-setting mechanism, the introduction of a new staff-appraisal and promotion system and an increase in staff mobility; (xi) the consolidation of disability and student benefits; (xii) the inclusion in housing-market regulations of further requirements to accelerate the issuance of title deeds; ...

Such action may, in particular, include studies, meetings, information activities, publications, expenditure on informatics tools, systems and networks for the exchange and processing of information, and any other expenditure on technical, scientific and administrative assistance and expertise to which the Commission may need to have recourse for the purposes of the implementation of this Decision.

Therefore, for the period running from the pay-out of the loan to HSY until the reimbursement by HSY, the Commission has to order the recovery the difference between the interest rate actually paid by HSY and an interest rate theoretically adequate for a loan presenting a very high risk.