In 2016, the usual close oversight of risk-acceptance strategies was maintained, which are summarised in the Group’s Risk Appetite Framework (RAF), and in particular a specific RAF was defined for credit risk (Credit Risk Appetite Framework - CRA). This identifies areas of growth for loans and areas to control using an approach based on ratings and other predictive statistical indicators, to steer the growth in loans, optimising the management of risks and expected loss. In 2016, the CRA was implemented with credit process restrictions, through the quantification of specific limits that define the maximum risk tolerated for the most risky transactions. The limits identified are approved in the RAF and continually monitored by the Credit Risk Management Head Office Department. In 2016 a project launched in 2015 continued, identifying qualitative information such as success factors for SMEs (sector, innovation, certification, patents, brands, training, awarding legal ratings etc.), their competitive positioning (performance, sales trend, etc.), aspects connected to the presence of risks, investment policies adopted and forecasts, and membership of networks and supply chains.

These factors were identified by internal entities of the Bank (Risk Management, Credit and Marketing) and are currently being examined by the European Central Bank to be included, with full entitlement, in the new rating model which will have an impact on both credit granting and pricing procedures.

In line with Supervisory provisions, the systematic monitoring of Significant Transactions was introduced in 2014, and namely of transactions that may result in a potential significant change in the Group's risk profile. These include: acquisition or disposal extraordinary transactions which significantly alter the scope of Group risks, with a potential impact on the overall risk profile as defined in the Risk Appetite Framework (RAF); transactions that have an impact on specific risks identified in the RAF and any other transactions specifically characterised by the presence of potential risks which cannot be regularly quantified ex ante, or because of the high risk relating to each individual transaction (e.g. renegotiation or credit restructuring transactions).