On 2 December 2021, the European Banking Authority (EBA) published three consultation papers related to its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’ (in short, the IRRBB Guidelines). In this article, we focus on one of these consultation papers, concerning the update of the IRRBB Guidelines.
This new update is triggered by the revised Capital Requirements Regulation (CRR2) and Capital Requirements Directive (CRD5). Both documents were adopted by the Council of the EU and the European Parliament in 2019 as part of the Risk Reduction Measures package. The CRR2 and CRD5 included numerous mandates for the EBA to come up with new or adjusted technical standards and guidelines. These are now covered in three separate consultation papers
In this article we focus on the first consultation paper. The update of the IRRBB Guidelines can be split up in three topics and each will be discussed in further detail:
The 2018 IRRBB Guidelines introduced the obligation for banks to monitor CSRBB. However, the publication did not describe how to do this. In the updated consultation paper the EBA defines the measurement of CSRBB as a separate risk class in more detail. The general governance related aspects such as (management) responsibilities, IT systems and internal reporting framework are separately defined for CSRBB, but are similar to those for IRRBB.
Also similar to IRRBB is that banks must express their risk appetite for CSRBB both from an NII as well as an economic value perspective.
The EBA defines CSRBB as:
EBA
Compared to the previous definition, rating/PD migrations are explicitly excluded from CSRBB. Including idiosyncratic spreads could lead to double counting since these are generally covered by a credit risk framework. However, the guidelines give some flexibility to include idiosyncratic spreads, as long as the results are more conservative than when idiosyncratic spreads are excluded. This is because, based on the Quantitative Impact Study of December 2020 (QIS 2020), banks indicated to find it difficult to separate the idiosyncratic spreads from the credit spread.
Also, the scope of CSRBB has changed from the current IRRBB Guidelines. All assets, liabilities and off-balance-sheet items in the banking book that are sensitive to credit spread changes are within the scope of CSRBB whereas the 2018 IRRBB Guidelines focused only on the asset side. Based on the results of the QIS 2020, the EBA concluded that most of the exposures to CSRBB are debt securities which are accounted for at fair value (via Profit and Loss or Other Comprehensive Income). However, this does not rule out that other assets or liabilities could be exposed to CSRBB. It is stated that banks cannot ex-ante exclude positions from the scope of CSRBB. Any potential exclusion of instruments from the scope of CSRBB must be based on the absence of sensitivity to credit spread risk and appropriately documented. At a minimum, banks must include assets accounted at fair value in their scope.
We believe that the obligation to report CSRBB for all assets accounted for at fair value will be challenging for exposures that do not have quoted market prices. Without a deep liquid market, it will be difficult to establish the credits spread risk (even when idiosyncratic risk is included).
Another possible candidate to be included in the scope of CSRBB is the issued funding on the liability side of the banking book, especially in a NII context. When market spreads increase, this could become harmful when the wholesale funding needs to be rolled over against higher credit spread without being able to increase client interest on the asset side. Similar to IRRBB, the exposure to this risk depends on the repricing gap of the assets and liabilities. In this case, however, swaps cannot be used as hedge.
Other products such as consumer loans, mortgages, and consumer deposits, which are typically accounted for at amortized cost, are less likely to be included. This is also stated by the BCBS standards. The BCBS states that the margin (administrative rate) is under absolute control of the bank and hence not impacted by credit spreads. However, it is unclear whether this is sufficient to rule these products out of scope.
The EBA is mandated to specify the criteria for determining an IRRBB internal system as non-satisfactory. The EBA has identified specific items for this that should be considered. At a minimum, banks should have implemented their internal system in compliance with the IRRBB Guidelines, taking into account the principle of proportionality. More specifically:
Major parts of the guidelines for managing IRRBB have not changed. In the section on IRRBB stress testing, however, a new article (#103) for products with significant repricing restrictions (e.g. an explicit floor on non-maturing deposits – NMDs) is introduced. As part of their stress testing, banks should consider the impact when these products are replaced with contracts with similar characteristics, even under a run-off assumption. The exact intention of this article is unclear. For NII-purposes it is common practice to roll over products with similar characteristics (or use another balance sheet development assumption). Our interpretation of this article is that banks are expected to measure the risk of continued repricing restrictions in an economic value perspective when the maturity of those funding sources is smaller than the maturity of the asset portfolio. This may for example materialize when banks roll over NMDs that are subject to a legally imposed floor.
Another update is the restriction on the maximum weighted average repricing maturity of five years for NMDs. This cap was prescribed for the EVE SOT and is now included for the internal measurement of IRRBB. We believe that the impact of this will be limited since only a few banks will have separate NMD models for internal measurement and the SOT.
Finally, some minor additions have been included in the guidelines. For example, the guidelines emphasize multiple times that when diversification assumptions are used for the measurement of IRRBB, these must be appropriately stressed and validated.
It is expected that the final guidelines will not deviate significantly from the consultation paper. Banks can therefore start preparing for these new expectations. For the measurement of IRRBB, limited changes are introduced in the consultation. Although the exact intention of the EBA is unclear to us, it is interesting to notice that the updated IRRBB Guidelines include the expectation that banks pay special attention in their stress tests to products with significant repricing restrictions. Furthermore, banks must invest in their CSRBB measurement. For their entire banking book, banks need to assess whether market wide credit spread changes will have an impact on an NII and/or economic value perspective. The scope of CSRBB measurement may need to be extended to include the funding issued by the bank. And to conclude, the obligation to measure CSRBB for fair value assets that do not have quoted market prices will be a challenge for banks.
On 2 December 2021, the European Banking Authority (EBA) published three consultation papers related to its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’ (in short, the IRRBB Guidelines). In this article, we focus on one of these consultation papers, concerning the update of the IRRBB Guidelines.
The current version of the IRRBB Guidelines, published in 2018, came into force on 30 June 2019. At that time, the IRRBB Guidelines were aligned with the Standards on interest rate risk in the banking book, published by the Basel Committee on Banking Supervision (in short, the BCBS Standards) in April 2016.
The new updates are triggered by the revised Capital Requirements Regulation (CRR2) and Capital Requirements Directive (CRD5). Both documents were adopted by the Council of the EU and the European Parliament in 2019 as part of the Risk Reduction Measures package. The CRR2 and CRD5 included numerous mandates for the EBA to come up with new or adjusted technical standards and guidelines. These are now covered in three separate consultation papers:
Please note that we recently also published an article about the new disclosure requirements for IRRBB which is closely related to this topic.
Banks have been subject to an SOT already since the 2006 IRRBB Guidelines. The SOT is an important tool for supervisors to perform peer reviews and to compare IRRBB exposures between banks. The SOT measures how the EVE responds to an instantaneous parallel (up and down) yield curve shift of 200 basis points. Changes in EVE that exceed 20% of the institution’s own funds will trigger supervisory discussions and may lead to additional capital requirements.
Some changes to the SOT were included in the 2018 update of the IRRBB Guidelines. Next to further guidance on its calculation, the existing SOT was complemented with an additional SOT. The additional SOT was based on the same metric and guidelines, but the scenarios applied were the six standard interest rate scenarios introduced in the BCBS Standards. Also, a threshold of 15% compared to Tier 1 capital was applied. In the 2018 IRRBB Guidelines, the additional SOT was considered an ‘early warning signal’ only.
The new update of the IRRBB Guidelines includes two important SOT-related changes, which are incorporated through amendments to Article 98 (5) of the CRD: the replacement of the 20% SOT for EVE and the introduction of the SOT for NII. Both changes are discussed in more detail below.
Banks have been subject to an SOT already since the 2006 IRRBB Guidelines. The SOT is an important tool for supervisors to perform peer reviews and to compare IRRBB exposures between banks. The SOT measures how the EVE responds to an instantaneous parallel (up and down) yield curve shift of 200 basis points. Changes in EVE that exceed 20% of the institution’s own funds will trigger supervisory discussions and may lead to additional capital requirements.
Some changes to the SOT were included in the 2018 update of the IRRBB Guidelines. Next to further guidance on its calculation, the existing SOT was complemented with an additional SOT. The additional SOT was based on the same metric and guidelines, but the scenarios applied were the six standard interest rate scenarios introduced in the BCBS Standards. Also, a threshold of 15% compared to Tier 1 capital was applied. In the 2018 IRRBB Guidelines, the additional SOT was considered an ‘early warning signal’ only.
The new update of the IRRBB Guidelines includes two important SOT-related changes, which are incorporated through amendments to Article 98 (5) of the CRD: the replacement of the 20% SOT for EVE and the introduction of the SOT for NII. Both changes are discussed in more detail below.
The first part of the amended Article 98 (5) concerns the replacement of the original 20% SOT by the 15% SOT. While many banks are probably already targeting levels below 15%, we expect that this change will limit the maneuvering capabilities of banks as they will likely choose to implement a management buffer. Note that not only the threshold is lower (15% instead of 20%), but also the denominator (Tier 1 capital instead of own funds). Furthermore, the worst outcome of all six supervisory scenarios should be used, as opposed to worst outcome of just the two parallel ones. Combined, this leads to a significant reduction in the EVE risk to which a bank may be exposed.
Some other noteworthy updates to the SOT for EVE that are not directly related to the CRD amendment are listed below:
The second part of the amended Article 98 (5) concerns the introduction of an entirely new SOT. It is aimed at measuring the potential decline in NII for two standard interest rate shock scenarios. Compared to the SOT for EVE, the SOT for NII requires many more modeling assumptions, in particular to determine the expected balance sheet development. The consultation paper provides clarity on the approach the EBA wants to take but two decisions are explicitly consulted.
The SOT for NII compares the NII for a baseline scenario with the NII in a shocked scenario over a one-year horizon. The two shocks that need to be applied are the two instantaneous parallel shocks that are also used in the SOT for EVE. Furthermore, the same requirements that are specified for the SOT for EVE apply, for example the use of the floor and the aggregation approach. The two exceptions are the requirements to use a constant balance sheet assumption (as opposed to a run-off balance sheet) and to include commercial margins and other spread components in the calculations. The commercial margins of new instruments should equal the prevailing levels (as opposed to historical ones).
The two decisions for which the EBA is seeking input are:
The scope/definition of NII
In its narrowest definition, the SOT will focus on the difference between interest income and interest expenses. The EBA, however, also considers using a broader definition where the effect of market value changes of instruments accounted for at Fair Value (∆FV) is added, and possibly also interest rate sensitive fees and commissions.
The definition of the SOT’s threshold
Article 98 (5) requires the EBA to specify what is considered a ‘large decline’ in NII, in which case the competent authorities are entitled to exercise their supervisory powers. This first requires a metric. The EBA is consulting two:
The pros of the narrow definition of NII are improved comparability and ease of computation, where the main pro of the broader definition is that it achieves a more comprehensive picture, which is also more in line with the EBA IRRBB Guidelines. With respect to the metrics, the first (capital-based) metric is the simplest and it is comparable to the approach taken for the SOT for EVE. The second metric is close to a P&L-based metric and the EBA argues that its main advantage is that “it takes into account both the business model and cost structure of a bank in the assessment of the continuity of the business operations”. It does involve, however, the application of some assumptions on determining the α parameter.
For each of the four possible combinations (definition of NII and specification of the metric), the EBA has determined, using data from the December 2020 Quantitative Impact Study (QIS), what the corresponding thresholds should be. Their starting point has been to make the SOT for NII as stringent as the SOT for EVE. Effectively, they reverse engineered the threshold to achieve a similar number of outliers under both measures. We expect that the proposed threshold for any of the four possible combinations will not be constraining for the majority of banks. The resulting proposed thresholds are included in the table below:
Table 1 – Comparison of the proposed thresholds for each combination of metric and scope
The impact of including Fair Value changes seems arbitrary as it increases the threshold for the capital-based metric and decreases the threshold for the P&L-based metric. Also, from a comparability and computational perspective, the narrow definition of NII may be preferred. Furthermore, the capital-based metric is less intuitive for NII than it is for EVE, and consequently, the P&L-based one may be preferred. It is also noted in the consultation paper that if the shocked NII after the correction for administrative expenses (the numerator) is negative, it will also be considered an outlier.
In the past years, many banks have invested heavily in their IRRBB framework following the 2018 update of the IRRBB Guidelines. Once again, an investment is required. Even though there are not many surprises in the proposed updates related to the SOTs, small and large banks alike will need to carefully assess how the changes to the existing SOT and the introduction of the new SOT will impact their interest rate risk management. Banks still have the opportunity to respond to all three consultation papers until 4 April 2022.
MuniFin is one of Finland’s largest financial institutions, specialized in financing local government and state-subsidized social housing production.
As MuniFin has been growing fast in recent years, the bank is now under the supervision of the European Central Bank (ECB). This means complying with the corresponding regulations, particularly in the field of asset and liability management (ALM). How does the organization deal with the new ALM challenges?
MuniFin, the shortened name for Municipality Finance Plc, aims to promote welfare in Finland through the financing of municipal projects related to basic infrastructure, healthcare, education and the environment. Therefore, a significant portion of its lending is used for socially responsible projects such as building hospitals, healthcare centers, schools, day care centers and homes for the elderly. Finland’s local government sector is characterized by a high degree of autonomy over financial matters and strong credit quality, which is reflected in the high quality of MuniFin’s loan portfolio.
Pyry Happonen, head of ALM at MuniFin
MuniFin operates domestically, but is an international player, says Pyry Happonen, head of ALM at MuniFin: “We do all of our lending in Finland, but we fund our operations through international capital markets. Traditionally we have been very flexible in terms of funding. Each year we do 200 to 300 transactions in the funding market, in almost 20 different currencies. This results in quite a bit of complexity.”
In the meantime, MuniFin’s balance sheet has grown significantly in the last few years, to approximately EUR 35 billion. Simultaneously, the number of people working at MuniFin has increased to 149. As a result, the bank moved from domestic supervision to European supervision. Together with many developments in the financial markets, this has brought new challenges for MuniFin. European supervision raises the bar continuously regarding risk management.
“We therefore need to stay on top of things”, says Pasi Heikkilä, head of Treasury at MuniFin. “Not just by checking the boxes and fulfilling the requirements. To maintain our profitability and reduce risks, we need to improve the way we work too.”
According to Heikkilä, the changes bring both challenges and opportunities. “We’ve been directly regulated by the ECB since 2016 and our focus has been very much on complying with all ratios and liquidity requirements. We also want to put more focus on the long-term profitability side. The external requirements and our internal goals can strengthen one another. Both encourage us to look at ALM in different ways and to manage our balance sheet more efficiently.”
In terms of interest rate risk management, MuniFin is compliant. “We can manage our economic value of equity (EVE) and our net interest income (NII),” Happonen explains. “But we also wanted to dive a bit deeper than ticking the boxes and to find an optimal way to manage this risk. We wanted to enhance the capabilities and at the same time, we were looking for a third party to share and discuss our thoughts on our interest rate risk strategy. We therefore engaged with Zanders; to review the strategy and to ensure that we are optimally managing our profitability with regards to interest rate risk. Furthermore, we want to ensure we are fully leveraging the increased data and modeling capabilities.”
Ensuring compliance and simultaneously striving for improved internal risk management has influenced MuniFin’s strategy, says Heikkilä: “It’s an iterative process, a constant development which happens in cycles. For a relatively small company like ours, additional support is welcome. We continuously have active dialogues with our peers. But not all information is open; market participants cannot always share all information. So, in some cases we consult experts like Zanders, to help us with gap analyses so that we can figure out what to further improve on.”
In the current regulatory environment, managing a balance sheet efficiently is not a trivial task, Heikkilä explains. “Balance sheet profitability and risk need to be managed and optimized while considering multiple metrics, like the liquidity coverage ratio (LCR), the net stable funding ratio (NSFR) and the leverage ratio. To ensure liquidity is priced correctly and to have a sustainable profit margin, a robust funds transfer pricing (FTP) framework is required. At the same time, this needs to be done in a cost-efficient manner and with good data and systems.”
To meet these requirements, MuniFin is significantly improving its data and modeling capabilities too, to provide the company with reliable information on a daily basis.
Pasi Heikkilä, head of Treasury at MuniFin
“Latency is decreasing”, says Happonen. “We can do analyses and calculations more frequently. In Finland the big banks are investing hundreds of millions in their IT and systems. They are getting rid of legacy systems and bringing in new software, in order to improve quality of data and modeling capabilities to enable good decision-making. This is key in going forward in ALM; subpar data and Excel files no longer cut it. We are also proactive on this front, investing in our data collection and modeling capabilities for better analyses on a more frequent basis, with up-to-date data. And of course, technology helps us to make better strategic choices too, concerning managing interest rate risk, net interest income and so on.”
In terms of the future strategy, green finance is a very important topic in MuniFin’s plans. The bank offers green financing, funded by green bonds, for projects that promote the transition to low-carbon and climate resilient growth. Sustainability initiatives and climate change ambitions are increasingly key in financing, according to Happonen.
Pyry Happonen, head of ALM at MuniFin
“Green finance is a very big thing for us. We are lending to a lot of domestic green projects, like public transportation. And we report the impact of the green financing we’ve done. On the global bond market many investors are craving for green bonds. The better our ALM strategy, the more optimal our profitability and risk return profile are and the more we can contribute to sustainability too. It means that we need to be sustainable in all senses, so both financially and environmentally.”
Sustainable balance sheet management: Running a sustainable business model requires maintaining a sustainable balance sheet. A stable profit margin and a risk profile that is in line with the risk appetite is essential. Finding the balance between risk and profitability can be a challenging task that requires continuous monitoring and steering. On the one hand, long lending with short funding results in high margins and therefore great profitability, in the short run. However, such a position yields significant risks in the longer run. As interest rates increase, more expensive funding is required, potentially resulting in a negative margin. Only by making the right trade-off between risk and profitability, and therefore between the short-term view and the long-term view, can a sustainable balance sheet be maintained.
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The insurance company VIVAT was looking for a flexible tool to perform standard model calculations according to Solvency II directives. It decided to use the existing risk-initiated ALM tool which led to some challenges but which now offers various advantages.
VIVAT is a commercial financial service provider with insurance brands whose names are more familiar than that of the parent company: REAAL, Zwitserleven, Zelf, Route Mobiel (roadside assistance), and Proteq Dier & Zorg (insurance for pets). ACTIAM is the asset manager. On its website, the insurance company gives the impression of being a strong socially-motivated company; the very different brands together have the goal of helping people increase their empowerment. In the summer of 2015, VIVAT was taken over by Anbang Insurance Group, which is well known for its strong technology-based services.
In 2009, the Solvency II directive was implemented as a harmonious European regulatory framework for insurers, with the goal of insurers having enough capital in reserve to prevent bankruptcy. Since 2011, the European Authority for Insurance and Company Pensions (EIOPA) regulates these insurance companies. The starting date at which the Solvency II directives actually came into force was changed several times. Finally, the directives became effective on 1 January 2016.
VIVAT is a commercial financial service provider with insurance brands whose names are more familiar than that of the parent company: REAAL, Zwitserleven, Zelf, Route Mobiel (roadside assistance), and Proteq Dier & Zorg (insurance for pets). ACTIAM is the asset manager. On its website, the insurance company gives the impression of being a strong socially-motivated company; the very different brands together have the goal of helping people increase their empowerment. In the summer of 2015, VIVAT was taken over by Anbang Insurance Group, which is well known for its strong technology-based services.
In 2009, the Solvency II directive was implemented as a harmonious European regulatory framework for insurers, with the goal of insurers having enough capital in reserve to prevent bankruptcy. Since 2011, the European Authority for Insurance and Company Pensions (EIOPA) regulates these insurance companies. The starting date at which the Solvency II directives actually came into force was changed several times. Finally, the directives became effective on 1 January 2016.
From that date, VIVAT Insurances also had to be Solvency II-compliant. The company needed a flexible tool with which it could calculate required capital in line with the Solvency II directive. The solution was found in an existing risk-initiated asset & liability management (ALM) tool. “From a risk standpoint, we wanted certain management information such as interest risk sensitivity,” recounts Erwin Charlier, head of modeling at VIVAT. “With the ALM tool, we were able to access information which gave us better insight into the risks. Then we thought: since we already have the tool, let’s expand it to the Solvency II-standard model. So we now use it to calculate the figures which go to the DNB and which are in our annual report.”
The insurance company VIVAT was looking for a flexible tool to perform standard model calculations according to Solvency II directives. It decided to use the existing risk-initiated ALM tool which led to some challenges but which now offers various advantages.
With this increased scope, the tool has become a bigger and more widely applicable model for VIVAT. Besides the different components for risk reporting, other departments now also use the tool. “For example, for valuation of certain assets by our asset manager and by Balance Sheet Management, for controlling the balance sheet,” says Kees Smit, manager of risk balance sheet reporting at VIVAT and thereby senior user and ‘owner’ of the tool. “The tool is used for management as well as for accountability and therefore fulfills a central role in the model landscape for risk management.”
With one owner and several ‘clients’, the ALM tool demands a great deal of internal co-ordination and good ‘stakeholder management’. “Priorities for the tool are carefully agreed and weighed up with the various departments”, says Smit. “Sometimes that leads to difficult decisions, but since we manage the tool ourselves and a small dedicated team handles it, we always find a solution.” At the same time there also arose a need for structure and process management. Charlier says: “We had insufficient capacity for this internally and so we looked around externally and came across Zanders.”
Adding extra functions to the ALM tool starts with a Request for Change (RfC). The tool’s functionalities have to be documented in this as clearly as possible. “
Erwin Charlier, head of modeling at VIVAT.
“It is important that the RfC is of high quality, so that we know what we can do with it and what has to happen to the tool. We need people who know down to the last detail what its intention is, people who model or implement, and if all goes to plan it is part of a release process and then users can actually start using it.”
Where the tool is solely used within the risk function to generate certain information, it can be set up according to your own pragmatic ideas. “But as soon as it becomes a formal tool – which is used for external reporting – then you have to formalize all sorts of things,” says Charlier. “To be in control you no longer want that degree of flexibility. And that then means other people get involved.” On top of this, the department that delivered the Solvency II-reporting then became the senior user. This led to other demands and wishes because the intent of the tool changed. “Initially, the tool was not set up to be our Solvency II-tool. If you decide to do that later, the organization has to ensure it has the people and the means to achieve a high standard,” says Charlier.
“One of the goals of the project was to have the change process take place in a very structured way,” says Zanders consultant Mark van Maaren. “This means a clear standardized process which is then followed.” Changes that other users don’t know about can cause problems. “The process comprises different phases,” adds Zanders’ Stef van Wessel. “From development, testing, acceptance, and production. In order for everything to run smoothly, the previous phase has to be completed before you start the next one. In the production phase only the owner and his team are involved. In other words: the people who have written the code can no longer change it when it’s in production – to avoid different changes by people in different places having a negative impact on one another.”
In the first phase of the project, the challenge was to make the tool Solvency II-compliant. Then the wish-list, which was not dependent on the required Solvency directives, was added to the tool. Completion is planned for the end of 2016. Charlier explains: “Solvency, though, has been faced with quite a few forward-looking perceptions, and these also have had to be taken into consideration.” Van Wessel adds: “But by standardizing the process, separating the roles within it, and setting up authorizations, many problems can be mitigated.” Over the past year that has been accomplished: a control framework which complies with the Solvency II-directives.
Initially, the management of the tool was the responsibility of Charlier’s modeling department. In the second phase of the project, it was decided to transfer a number of components to the IT department. “Each application has its own conditions and requirements, but we do not come up to the mark in all areas and to the standard IT would like,” Charlier related. “We have a great model, but perhaps we could improve a few things under the bonnet. For example: employees have certain skills, but the question is if this is an efficient use of resources. On the one hand, there is a heavy data component; via communication with other databases you retrieve all sorts of information to calculate with and then transfer to various areas. Setting up the data and reporting side takes a lot of time and could easily be done by IT. But the core, the calculation center, is for me typically something for the modeling department: how do you value the assets on your balance sheet, how do you handle yield curves in interest-rate risk measurement?” IT is positive about the division of roles. And we want to use our human capital as efficiently as possible.
A huge advantage of a tool developed in-house is that it offers VIVAT a lot of flexibility. “In addition, the tool is now completely in tune with our own wishes,” says Smit. “Under our own management, changes in the tool can be made quickly. That’s nice, since the required functionalities within risk management are constantly changing.” It also offers ‘double focus’ in one functionality. Charlier says: “That way we have developed the knowledge and ability to be able to take a detailed look under the hood. If something unexpected comes out of the model, we can see where it comes from. The only thing is that it takes some effort from the organization.”
The alternative for the insurer was to use separate tools for the various reports. “But the disadvantage of this is that you can have inconsistency problems which you have to reconcile,” Van Maaren explains. “For example, sometimes companies buy platforms and then expand on them – you see all sorts on the market. The ready-made package you buy which you can use straight away just doesn’t exist.”
Will the model be further expanded with more functions? Charlier is unsure: “As a real ALM tool I would like to be able to do more on the liability side. The liability side is included, but is covered by other sources of data. The focus of the tool is now more on the asset side; the L in ALM is not so prominent in the tool.”
In the future, Charlier foresees a number of great challenges. “I find the role split and efficient sharing of resources a very important focus point. Moreover, regulations won’t stand still and we will have to adapt to them,” he says. In the first year that insurers have to comply with the requirements of Solvency II, the solvency ratios are quite volatile. “But new demands give you, as an organization, the chance to adapt to the latest insights. It would be a lost opportunity to not act upon these. What would be really nice is if you could use the tool to project a number of years into the future. For example with stress tests or an operational plan to look further into the future.”
Would you like to know more? Contact us today.
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BNG Bank, established to offer low-rate loans to the Dutch government and public interest institutions, helps lower the cost of public amenities, but its balance sheet’s sensitivity to financial market fluctuations highlights the need for a robust interest rate risk framework.
BNG Bank was founded more than 100 years ago – firstly under the name Gemeentelijke Credietbank – as a purchasing association with the main task of bundling the financing requirements of Dutch local authorities so that purchasing benefits could be obtained on capital markets. In 1922, the name was changed to Bank voor Nederlandsche Gemeenten and even today the main aim is, in essence, the same. What has changed is the role of local authorities, says John Reichardt, a member of the Board of BNG Bank. He explains: “Over the past few years they have diversified. Many of their responsibilities are now independent or even privatized. Hospitals, electricity boards and housing companies, for example, were in the hands of local authorities but now operate independently. They are, however, still our clients because they provide public services.”
To satisfy the financing requirements of its clients, BNG Bank collects money on the international capital markets to realize ‘bundled’ purchasing benefits. “And we pass these benefits on to our customers,” says Reichardt. “While our customers have become more diverse over time, our product portfolio has widened. Some thirty years ago we became a bank, with a comprehensive banking license, and this meant we could take up short-term loans, make investments, and handle our customers’ payments. We try to be a full-service bank, but then only for services our customers need.”
The state holds half of the shares and the remainder belongs to local authorities and provinces/counties. “Because of this we always have the dilemma: should we go for more profit and more dividend, or should our strong purchasing position be reflected immediately in our prices by means of a moderate pricing strategy? Our goal is to be big in our market – we think we should keep 35 to 50 percent of the total outstanding debt on our balance sheet. We are not striving for maximum profit, and that differentiates us from many other banks. Although we are a private company, we do also feel we are a part of the government,” says Reichardt.
BNG Bank has only one branch in The Hague, with 300 employees. The bank has grown considerably, mainly over the past few years. As of the start of the financial crisis, a number of services from other parties have disappeared, so BNG Bank was often called upon to step in. Now, partly as a result of this, it has become one of the systematically important Dutch banks. “From a character point of view, we are more of a middle-sized company, but as far as the balance sheet is concerned, we are a large bank. We earn our money by buying cheaply, but also by trying to pass this on as cheaply as possible to our customers – with a small commission. This brings with it a strong focus on risk management, including managing our own assets and the associated risks. These are partly credit risks, but we have fewer risks than other banks – because, thanks to the government, our customers are usually very creditworthy.”
BNG Bank also runs certain interest rate risks that have to be controlled on a day-to-day basis. “We have done this in a certain way for a long time, but in the meantime the world has changed,” says Hans Noordam, head of risk management at BNG Bank. “So we thought it was time to give the method a face-lift to test whether we are doing it right, with the right instruments and whether we are looking at the right things? We also wanted someone else to take a good look at it.”
So BNG Bank concluded that the interest rate risk framework had to be revised. “Our approach once was state of the art but, as always with the dialectics of progress, we didn’t do enough ourselves to keep up with changes in that respect,” Reichardt explains. “When we looked at the whole management of interest rate risk, on the one hand it was about the departments involved, and on the other hand the measurement system – the instruments we used and everything associated with them used to produce information which enabled decision-making on our position strategy. That is a big project.
Over the past few years various developments have taken place in the area of market risk. When BNG Bank changed its products and methods, various changes also took place in the areas of risk management and valuation, including extra requirements from the regulator. “So we started a preliminary investigation and formed one unit within risk management,” says Reichardt. At the end of 2012, BNG Bank appointed Petra Danisevska as head of risk management/ALM (RM/ALM). “We agreed not to reinvent the wheel ourselves, but mainly to look closely at best market practices,” she says.
Petra Danisevska, Head of risk management/ALM (RM/ALM) at BNG Bank
Noordam explains that they agreed on suggested steps with the Asset Liability Committee (ALCO), which also provided input and expressed preferences. A plan was then made and the outlines sketched. To convert that into concrete actions, Noordam says that a project was initiated at the beginning of 2014: Project Harry. “This gets its name from BNG Bank’s location, also the home of a Dutch cartoon character, called Haagse Harry. He was the symbol of the whirlwind which was to whip through the bank,” says Noordam.
“During the (economic) crisis, all sorts of things happened which influenced the valuation of our balance sheet,” Reichardt explains. “They also had many effects on the measurement of our interest rate risk. We had to apply totally different curves – sometimes with very strange results. Our company is set up in a way that with our economic hedging and our hedge accounting, we can buy for X and pass it on to our customers for X plus a couple of basis points, which during the period of the loan reverts to us. We retain a small amount and on the basis of this pay out a dividend – our model is that simple. However, since the valuations were influenced by market changes, we were more or less obliged to take measures in order to stay within our ALCO limits. These measures, with respect to managing our interest position, would not have been realizable under our current philosophy; simply because they weren’t necessary. We knew we had to find a solution for that phenomenon in the project. After much discussion we were able to find a solution: to be more reliable within the technical framework of anticipating market movements which strongly influence valuation of financial instruments. In other words: the spread risk and the rate risk had to be separately measured and managed from one another. The world had changed and our interest rate risk management, as well as reporting and calculations based upon it, had to as well.”
After revision of the interest rate risk framework, as of the second half of 2015, all interest-rate risk measurements, their drivers and reporting were changed. The market risks as a result of the changes in interest rate curves, were then measured and reported on a daily basis by the RM/ALM department. “There is definitely better management of the interest rate risk; we generate more background data and create more possibilities to carry out analyses,” Danisevska explains. “We now have detailed figures that we couldn’t get before, with which we can show ALCO the risk and the accompanying, assumed return.”
Noordam knew that Project Harry would involve a considerable effort. “The risk framework would inevitably suffer quite a lot. It had to be innovated on the basis of calculated conditions, while the implementation required a lot of internal resources and specific knowledge. Technical points had to be solved, while relationships had to be safeguarded; many elements with all sorts of expertise had to be integrated. The European Central Bank was stringent – that took up a lot of time and work. We had an asset quality review (AQR) and a stress test – that was completely new to us. Sometimes we were tempted to stay on known ground, but even during those periods we were able to carry on with the project. We rolled up our shirtsleeves and together we gained from the experience.”
Reichardt says: “It was a tough project for us, with complex subject matter and lots of different opinions. In total it took us seven quarters to complete. However, I think we have accomplished more than we expected at the beginning. With a combination of our own people and external expertise, we have managed to make up for lost ground. We have exchanged the rags for riches and we have been successful. Where do we stand now? As well as the required numbers, we have a clear view of what our thoughts are on ‘what is interest rate risk and what isn’t’. The only thing we still have to do is to fine-tune the roles: what can you expect from risk managers and risk takers, and how will they react to this? We will continue to monitor it. RM/ALM as a department is in any case a lot more proactive – that was an important goal for us. We can be more successful, but the department is really earning its spurs within the bank and that means profit for everyone.”
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Van Lanschot is staying ahead of the curve by developing advanced forecasting tools to navigate a rapidly changing financial landscape, ensuring better risk management and adaptability in an increasingly complex regulatory environment.
At more than 275 years old, Van Lanschot is the oldest independent private bank in the Netherlands. With an eye on the rapidly changing market, last year the bank decided to change its strategy. Evi Van Lanschot is now the young face of the oldest bank and is focusing on the wealthy client of the future.
2013 was an important turning point in Van Lanschot’s development. Under Karl Guha, the new CEO, the bank implemented its new strategy for the coming five years based on three key points: focus, simplification, and growth. “Focus means that we concentrate on what we are really good at, i.e., the retention and growth of our clients’ capital,” explains Martin Van Oort, Van Lanschot’s financial risk management director. “Over the past few years we have increasingly become a ‘small large bank’, with a business banking portfolio. As a result of consolidation in the sector, this will be scaled down even more. As a specialist and independent wealth manager, we think we can really make a difference for our clients.” Customers also wanted simpler and more transparent products. “And we want to extend this line through our organization, in our IT systems and in operations – it has to be simpler and more efficient,” Van Oort continues. “That means rigorous internal reorganization in order to serve our clients in the best possible way. The growth we strive for has to come from the capital management area.”
Van Lanschot and Kempen are strong labels, which enables the bank to offer a combination of private banking, asset management, and merchant banking. “This offers clients huge advantages; they enjoy an even more tailor-made service,” says Van Oort. The bank’s changed service concept is particularly visible from the outside. For the personal banking segment, Evi Van Lanschot is a clear proposition targeting starters on the capital markets. With the idea that there is private banking potential present, Evi’s entry threshold is much lower. Van Oort says: “Medical specialists and business professionals have differing requirements over the course of their careers and we can assist them in the best possible way over the whole cycle. The Evi bid is going very well; in the Netherlands and Belgium we have approximately €1 billion in savings and managed capital.”
At the same time, clients who currently belong to the personal bank but who require private banking services can – if they pay for it – choose this option. Finally, the bank has a Private Office for extremely wealthy clients. “They too of course profit from the synergy between Van Lanschot and Kempen,” adds Van Oort. Van Lanschot is parting company with another section of the bank – the corporate banking portfolio, which includes commercial real estate financing. “We will do that in a respectable and professional manner. By winding down slowly but retaining service levels, losses can be minimized and clients will have enough time to get a new roof over their heads. Running down this portfolio is going according to plan. We are taking leave of something which no longer fits in with our new strategy and we are putting a lot of effort into private banking. This gives direction and clarity to all of our stakeholders.”
All of the bank’s departments are occupied with change. “It’s going well. The shop is open during the reconstruction phase and so customer experience should also stay at a good level. Even the balance sheet ratios – solvability and liquidity – which are so important for the bank, are ahead of our anticipated long-range targets.”
The bank’s culture is changing as well: the traditional bank, where change sometimes appears to be dragging its feet, is becoming younger and more modern. Van Oort explains: “The Evi customer needs a transparent digital service, preferably with a handy fancy app on their mobile. You can see that the bank is also changing in that respect into one with a dynamic culture. For professionals who embrace change, it’s a really great and exciting time. We hear more often that people would like to work for Van Lanschot since so much is happening and we are in the thick of it. Lines are shorter and your ideas have an impact. The fact that it is going well on the personnel front is, of course, important as after all, it is the people who make the bank.”
Parallel to strategy changes, the bank is also investing a good deal in specialist staff functions. Last year it was decided to revise the bank’s risk management; as of March 2013 Van Oort is in charge of a new department – Financial Risk Management. The creation of this department, which was an amalgamation of various teams, was the first step towards further professionalizing risk management. “This second-line department is responsible for consolidated financial risk management within the bank,” he explains. “Besides setting limits and the integral monitoring of the bank’s risk position, this department is also a negotiating partner and advisor to the bank’s senior management.” The department is made up of a group of young and highly educated professionals who are extremely driven. Van Oort adds: “Our traineeships contribute a great deal to recruitment and internal dynamism.”
It is important that the bank is now capable of looking ahead to future developments with the use of forecasting tools. “The classic risk management function of monitoring, reporting and, if necessary, adjusting risk is possible using models and systems, but the world is changing fast – that is a huge challenge,” says Van Oort. “In addition, there is a mountain of rules and regulations that continue to descend on us and which has a great influence on the playing field. As a bank, you have to be more and more critical of the various balance sheet components. Partly because of the low interest rates, it depends on basis points and it is essential to look ahead using various scenarios to see what the impact on the balance sheet ratios and profit could be. The basic model Van Lanschot deployed has to be developed still further, last but not least because of the implementation of Basel III. Therefore, as of 2013, the development of a new forecasting tool was initiated which generates an integrated capital and liquidity forecast based on the expected balance sheet developments. “Zanders made an important contribution here. The good thing about Zanders is that they are real specialists with insight and a lot of practical know-how. But their pragmatic approach also appealed to me. It has resulted in a tool where we can detail the expected development of core ratios and where we can easily and quickly analyze the impact of mitigating measures on these ratios,” Van Oort says. “We are going to continue fine-tuning the good foundations we now have and by constantly carrying out back tests we can see if the forecasts tie in sufficiently. Where necessary, we will adapt the tool. After that, we will further integrate the tool with our ALM systems.”
Van Lanschot is listed on the stock exchange but a large proportion of the shares belong to large financial institutions. “We are active in the capital markets and rating agencies look critically at how our ratios develop and how we cope with risk management. The playing field has become more complicated and the supervisory body also makes its presence felt. Shareholders are of course critical and look at our figures differently to how they did in the past.” The question is whether or not the rapid regulation changes have not overshot their goal in some areas. Van Oort adds: “You see that in the current lending climate: the required growth of capital buffers puts the brakes on possible lending. A new balance has to be found. Extra regulations were necessary, but the amount and complexity of these regulations results in higher costs. Banks’ buffers have increased enormously and also the quality of these buffers has never been so high. The AQR (Asset Quality Review) has confirmed that most banks are on track on this point. Last year it was clear that this was also true of Van Lanschot.” The rating agencies have recently reconfirmed Van Lanschot’s rating, and S&P has upgraded its ‘negative outlook’ to ‘stable’. This is a clear sign that Van Lanschot is on the right track. “It is still closely monitoring the execution of the strategy, in which profitability will be an important factor. Wealth management strategy implies that the interest company reduces in value but is compensated for by increased commissions. In the meantime, we have to maintain our healthy capital and liquidity position. Over the next few years, we will have to prove that the new strategy has been a success.”
In the new banking territory, Van Lanschot, with its new strategy, is focusing more than ever on the customer. “Customer satisfaction is up there on top, as it is a very competitive business and for our bank it is essential for us to be an excellent service provider and offer customer value. The strategy we have set out provides a clear answer to how we see ourselves in the future. Within the field of risk management and ALM we are looking for professionals who feel at home in a specialist and dynamic private bank. The added value of our department is to be a sparring partner and advisor to the bank, all the while keeping in mind our penchant for discerning risk. That is a role which will develop along those lines. With all these changes we have a wonderful challenging time ahead of us.”
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Over the past decades, banks significantly increased their efforts to implement adequate frameworks for managing interest rate risk in the banking book (IRRBB). These efforts typically focus
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Over the past year, the interest rates on intercompany financial transactions have come under closer examination by tax authorities. This intensified scrutiny stems from a mix of
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At Zanders, we are proud to announce the promotion of Tobias Westermaier as our newest partner. With a rich background in Corporate Finance and Treasury, he brings a wealth of experience and a
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Introduction: Faster, smarter, and future-proof In the fast-paced financial industry , speed and accuracy are paramount. Banks are tasked with the complex calculation of XVAs
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In the high-stakes world of Private Equity (PE), where exceptional returns are non-negotiable, value creation strategies have evolved far beyond financial engineering. Today, operational
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Médecins Sans Frontières (MSF)/Doctors Without Borders is an international humanitarian organization, best known for their medical assistance in conflict zones and in countries affected
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For many, December is the most magical time of the year. It is a season filled with the warmth of family members, the joy of hanging out with friends, and the coziness of gathering around the
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The near-final PRA Rulebook PS9/24 published on 12 September 2024 includes substantial changes in credit risk regulation compared to the Consultation Paper CP16/22. While these amendments
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The ECB Banking Supervision has identified deficiencies in effective risk data aggregation and risk reporting (RDARR) as a key vulnerability in its planning of supervisory priorities for the
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Recently, Zanders' own Sander de Vries (Director and Head of Zanders’ Financial Risk Management Advisory Practice) and Nick Gage (Senior VP: FX Solutions at Kyriba) hosted a webinar. During
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When UGI International, a supplier of liquid gases across Europe and in the US, faced challenges in obtaining real-time visibility on its cash positions, they partnered with Zanders to
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How do you get banks on board to provide you with financing on favorable terms when your modus operandi isn’t maximizing profit? Zanders helped Royal FloraHolland find the answer,
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The Right Payment Orchestration Strategy: A Critical Factor for Success The digitalization and globalization of payment infrastructures have significantly impacted businesses in
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In our previous article 'Navigating the Financial Complexity of Carve-Outs: The Treasury Transformation Challenge and Zanders’ Expert Solution' we outlined that in a carve-out, the TOM for
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In today's dynamic economic landscape, optimizing portfolio composition to fortify against challenges such as inflation, slower growth, and geopolitical tensions is ever more paramount. These
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Effective liquidity management is essential for businesses of all sizes, yet achieving it is often challenging. Many organizations face difficulties due to fragmented data, inconsistent
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There are risks in undertaking any big treasury transformation project, but the risks of not adjusting to the changing world around you can be far bigger. Recognizing the potential pitfalls of
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Exploring S/4HANA Functionalities The roundtable session started off with the presentation of SAP on some of the new S/4HANA functionalities. New functionalities in the areas of
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Accurately attributing changes in counterparty credit exposures is essential for understanding risk profiles and making informed decisions. However, traditional approaches for exposure
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However, CCR remains an essential element in banking risk management, particularly as it converges with valuation adjustments. These changes reflect growing regulatory expectations, which were
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The timelines for the entire exercise have been extended to accommodate the changes in scope: Launch of exercise (macro scenarios)Second half of January 2025First submission of results to
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In a continued effort to ensure we offer our customers the very best in knowledge and skills, Zanders has acquired Fintegral.
In a continued effort to ensure we offer our customers the very best in knowledge and skills, Zanders has acquired RiskQuest.
In a continued effort to ensure we offer our customers the very best in knowledge and skills, Zanders has acquired Optimum Prime.
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