Blueprint
FORM 6-K
SECURITIES AND EXCHANGE COMMISSION
Washington D.C. 20549
Report of Foreign Private Issuer
Pursuant to Rule 13a-16 or 15d-16
of the Securities Exchange Act of 1934
For
August 31, 2018
Commission
File Number: 001-10306
The
Royal Bank of Scotland Group plc
RBS,
Gogarburn, PO Box 1000
Edinburgh
EH12 1HQ
(Address
of principal executive offices)
Indicate
by check mark whether the registrant files or will file annual
reports under cover of Form 20-F or Form 40-F.
Form
20-F X Form 40-F
___
Indicate
by check mark if the registrant is submitting the Form 6-K in paper
as permitted by Regulation S-T Rule 101(b)(1):_________
Indicate
by check mark if the registrant is submitting the Form 6-K in paper
as permitted by Regulation S-T Rule 101(b)(7):_________
Indicate
by check mark whether the registrant by furnishing the information
contained in this Form is also thereby furnishing the information
to the Commission pursuant to Rule 12g3-2(b) under the Securities
Exchange Act of 1934.
Yes ___
No X
If
"Yes" is marked, indicate below the file number assigned to the
registrant in connection with Rule 12g3-2(b): 82-
________
The following information was issued as Company announcements
in London, England and is furnished pursuant to General Instruction
B to the General Instructions to Form
6-K:
NatWest Markets N.V.
Interim Results 2018
NatWest Markets N.V.
Interim results for the half year ended 30 June 2018
Profit attributable to controlling
interests was €34
million compared with a loss of €158 million in H1 2017. This
increase was due to total income of €113 million compared
with total loss of €134 million H1 2017. Operating expenses
were stable at €32 million.
Net interest income was a loss of €1 million compared with a net
income of nil in H1 2017, reflecting lower interest receivable due
to the overall run-down of banking book assets. This was offset by
lower interest payable, mainly due to a reduction in subordinated
liabilities.
Non-interest income increased by €248 million to €114
million compared with loss of €134 million in H1 2017. Income
from trading activities was €70 million (H1 2017 - €22
million loss), primarily in relation to mark-to-market movements on
derivatives and the run-down of trading book liabilities and also
included €46 million received in respect of a distribution to
successful plaintiffs in the Madoff related class action. H1 2017
included foreign exchange losses of €173 million, reported in
income following the repatriation of the proceeds from the disposal
of foreign operations. H1 2017 represents the cumulative exchange
movement recorded in equity during the lifetime of those foreign
operations that were the subject of a net investment hedge. Other
operating income was stable at €63 million, compared with
€60 million in H1 2017.
Operating expenses remained stable at €32 million in H1
2018. Administrative expenses were €26 million, compared
with an expense of €28 million in H1 2017. Premises and
equipment costs increased by €3 million to €4 million,
compared with an expense of €1 million in H1 2017. Staff
costs remained stable at €2 million (H1 2017 - €3
million) in H1 2018.
Impairment losses were
€6 million compared with a release of €2 million in H1
2017.
Tax charge for H1 2018 was
€41 million compared with a tax credit of €6 million in
H1 2017.
Balance sheet
●
|
Total
assets were €5.6 billion at 30 June 2018, a decrease of
€0.5 billion, or 8%, compared with €6.1 billion at 31
December 2017, mainly driven by a decrease in loans and advances to
banks and derivative assets.
|
●
|
Loans
and advances to banks decreased by €0.2 billion, or 8%, to
€2.8 billion at 30 June 2018, with the majority of the
balance, €2.4 billion, being with fellow
subsidiaries.
|
●
|
Loans
and advances to customers were €83 million, compared with
€93 million, reflecting continued repayments and business
run-down.
|
●
|
Subordinated
liabilities decreased by €0.2 billion, or 20%, to €0.8
billion primarily due to maturities in the period.
|
●
|
Derivative
assets decreased by €0.1 billion, or 14%, to €0.7
billion, and derivative liabilities decreased by €0.1
billion, or 17%, to €0.5 billion. €0.4 billion of the
assets and €0.3 billion of the liabilities are balances with
fellow subsidiaries.
|
●
|
Total
equity increased by 2%, to €2.9 billion, reflecting the
attributable profit for the period, which was partly offset by
the
€29
million charge in relating to the implementation of IFRS 9 on 1
January 2018, which included €32 million in relation to
interests in associates (refer to Note 2).
|
Alawwal
Alawwal announced in 2017 that it was entering into merger
discussions with SABB and in May 2018 announced a merger ratio
applicable to Alawwal shareholders. Discussions continue over
the details of the proposed combination and further announcements
are expected in due course. In the meantime NatWest Markets N.V.
continues to consider Alawwal to be an associate. There were no
material cash flows between the company and Alawwal during H1 2018
or H1 2017.
Name change
In H1 2018 the Bank was renamed NatWest Markets N.V. (formerly The
Royal Bank of Scotland N.V.).
Financial review
Outlook(1)
The Group continues to implement its plan to be operationally ready
to serve our European Economic Area (EEA) customers ahead of 29
March 2019, the date the UK is due to leave the European Union, in
the event that there is a loss of access to the EU Single Market.
In relation to this plan the Group is currently going through a
declaration of no objection process with the regulator the DNB. The
Group is expected to become a subsidiary of NatWest Markets Plc
(NWM Plc), subject to regulatory approvals. The Group is currently
an indirect subsidiary of RBSG plc. In parallel, work continues to
decrease the Group's legacy assets and liabilities
further.
The table below provides the current profile of NatWest Markets
N.V.
|
30 June 2018
|
CET1 %
|
|
30.0%
|
Total tier 1 %
|
|
30.0%
|
Total capital %
|
|
31.3%
|
RWA
|
|
€9.2bn
|
- of which Alawwal
|
|
€6.6bn
|
Funded assets (2)
|
|
€2.5bn
|
As part of the plan to ensure the RBS Group can continue to serve
EEA customers after Brexit, the intention is to transfer the
in-scope EEA component of business from UK entities to NatWest
Markets N.V.
The activities planned to transfer primarily relate to Markets and
Corporate Lending portfolios for EEA customers currently served
from NatWest Markets Plc and the ring-fenced bank. These plans and
the actions to be taken to achieve it, remain subject to, amongst
other factors, additional regulatory, Board and other approvals.
All such actions and their respective timings may be subject to
change, or additional actions may be required, including as a
result of external and internal factors including further
regulatory, corporate or other developments.
Based on planning, the Group anticipates the profile of NatWest
Markets N.V. to change during 2019 to reflect the transfer of
business activities into the entity and continued wind-down of
existing legacy positions (incl. Alawwal).
NatWest Markets N.V is planned to be a well-capitalised entity with
strong levels of loss absorbency and support from its parent,
including down-streamed internal MREL and intra-group funding from
NatWest Markets Plc.
NatWest Markets N.V. plans to manage towards similar profiles for
capital and balance sheet metrics as are being targeted for the
NatWest Markets Plc Group.
The table below provides the expected profile of NatWest Markets
N.V. in 2020
|
|
NatWest
Markets
N.V.
|
CET1
|
|
|
>14%
|
Total capital
|
|
|
>28%
|
RWA
|
|
|
~€9bn
|
Funded assets (2)
|
|
|
~€16bn
|
Notes:
(1)
|
The targets
and expectations discussed in this section represent management's
current expectations and are subject to change, including as a
result of the "Risk Factors" described on pages 17 and 18 of this
document and on pages 112 to 127 of the Group's 2017 Annual Report
and Accounts, and the "Risk Factors" described on pages 31 and 32
of the NatWest Markets Interim Results 2018 and on pages 189 to 222
of the NatWest Markets Plc 2017 Annual Report and Accounts
(formerly Royal Bank of Scotland plc). By their nature, these
targets and expectations rely on certain planning assumptions and
involve known and unknown risks, uncertainties and other factors as
they relate to events and depend on circumstances that may or may
not occur in the future. In addition, there are regulatory, legal,
operational and commercial risks (including but not limited to
funding, liquidity and credit ratings) inherent in the proposed
transfers and the anticipated business model for NatWest Markets
N.V., such that the targets and expectations presented herein may
be subject to change and/or may not materialise.
|
(2)
|
Funded
assets are total assets less derivative mark to market and
intragroup assets.
|
Financial review
Capital
Capital ratios and risk-weighted assets (RWAs) on the CRR
transitional basis are set out below.
|
30 June
|
31 December
|
|
2018
|
2017
|
Capital ratios
|
%
|
%
|
CET1
|
30.0
|
24.9
|
Tier 1
|
30.0
|
24.9
|
Total
|
31.3
|
25.9
|
|
|
|
Risk-weighted assets
|
€m
|
€m
|
|
|
|
Credit risk
|
8,397
|
10,052
|
Market risk
|
345
|
418
|
Operational risk
|
478
|
674
|
|
|
|
Total RWAs
|
9,220
|
11,144
|
|
|
|
of which Alawwal
|
6,573
|
7,445
|
|
|
|
The CET1 ratio increased by 510 basis points in H1 2018 primarily
due to the decrease in RWAs (€1.9 billion) which mainly
reflected continued balance sheet reduction, the settlement of
business sale and a large reduction in exposures from investments
in associates.
Condensed consolidated income statement for the half year ended 30
June 2018 (unaudited)
|
Half year ended
|
|
30 June
|
30 June
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Interest receivable
|
9
|
16
|
Interest payable
|
(10)
|
(16)
|
|
|
|
Net interest income
|
(1)
|
-
|
|
|
|
Fees and commissions receivable
|
2
|
2
|
Fees and commissions payable
|
(2)
|
(1)
|
Income from trading activities
|
70
|
(22)
|
Foreign exchange gains and losses related to net
investment
|
|
|
hedges reclassified to income following disposals of foreign
operations (1)
|
(19)
|
(173)
|
Other operating income
|
63
|
60
|
|
|
|
Non-interest income
|
114
|
(134)
|
|
|
|
Total income
|
113
|
(134)
|
Operating expenses
|
(32)
|
(32)
|
|
|
|
Profit/(loss) before impairment losses
|
81
|
(166)
|
Impairment (losses)/releases
|
(6)
|
2
|
|
|
|
Operating profit/(loss) before tax
|
75
|
(164)
|
Tax (charge)/credit
|
(41)
|
6
|
|
|
|
Profit/(loss) for the period attributable to controlling
interests
|
34
|
(158)
|
Note:
(1)
Reclassified foreign exchange gains and losses are recognised on
the repatriation of the proceeds of disposals. Such income includes
gains and losses in respect of disposals in prior
periods.
Condensed consolidated statement of comprehensive income for the
half year ended 30 June 2018 (unaudited)
|
Half year ended
|
|
30 June
|
30 June
|
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Profit/(loss) for the period
|
34
|
(158)
|
|
|
|
Items that qualify for reclassification
|
|
|
Profit/(loss) on fair value of credit in financial liabilities
designated
|
|
|
at fair value through profit or loss due to own credit
risk
|
41
|
(37)
|
Fair value through other comprehensive income
|
(2)
|
-
|
Currency translation
|
19
|
95
|
Other comprehensive income after tax
|
58
|
58
|
|
|
|
Total comprehensive income/(loss) for the period attributable to
controlling interests
|
92
|
(100)
|
Note:
(1) Refer
to Note 2 for further information on the impact of IFRS 9 on
classification and basis of preparation, half year ended 30 June
2018 prepared under IFRS 9 and half year ended 30 June 2017 under
IAS 39.
Condensed consolidated balance sheet as at 30 June
2018 (unaudited)
|
|
|
|
30 June
|
31 December
|
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Assets
|
|
|
Cash and balances at central banks
|
86
|
68
|
Loans and advances to banks
|
2,772
|
2,998
|
Loans and advances to customers
|
83
|
93
|
Amounts due from the ultimate holding company
|
129
|
125
|
Debt securities and equity shares
|
424
|
514
|
Settlement balances
|
-
|
4
|
Derivatives
|
657
|
761
|
Interests in associates
|
1,255
|
1,214
|
Prepayments, accrued income and other assets
|
205
|
299
|
|
|
|
Total assets
|
5,611
|
6,076
|
|
|
|
Liabilities
|
|
|
Deposits by banks
|
939
|
1,132
|
Customer accounts
|
62
|
64
|
Debt securities in issue
|
2
|
27
|
Settlement balances
|
-
|
13
|
Derivatives
|
458
|
549
|
Provisions, accruals and other liabilities
|
371
|
392
|
Deferred tax
|
40
|
22
|
Subordinated liabilities
|
792
|
993
|
|
|
|
Total liabilities
|
2,664
|
3,192
|
Equity attributable to controlling interests
|
2,947
|
2,884
|
|
|
|
Total liabilities and equity
|
5,611
|
6,076
|
Condensed consolidated statement of changes in equity for the half
year ended 30 June 2018 (unaudited)
|
Half year ended
|
|
30 June
|
30 June
|
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Share premium account
|
|
|
At beginning and end of period
|
7,024
|
7,092
|
|
|
|
Fair value through other comprehensive income (FVOCI)
reserve
|
|
|
At beginning of period
|
4
|
-
|
Unrealised losses
|
(2)
|
(1)
|
Realised gains
|
-
|
1
|
|
|
|
At end of period
|
2
|
-
|
|
|
|
Cash flow hedging reserve
|
|
|
At beginning and end period
|
-
|
(1)
|
|
|
|
Foreign exchange reserve
|
|
|
At beginning of period
|
(42)
|
(120)
|
Losses arising
|
-
|
(78)
|
Foreign exchange gains and losses related to net investment hedges
reclassified
|
|
|
to income following disposals of foreign
operations
|
19
|
173
|
|
|
|
At end of period
|
(23)
|
(25)
|
|
|
|
Retained earnings
|
|
|
At beginning of period
|
(4,102)
|
3,926
|
Implementation of IFRS 9 on 1 January 2018
|
(29)
|
-
|
Profit/(loss) attributable to controlling interests
|
34
|
(158)
|
Changes in fair value of credit in financial liabilities designated
at fair value through profit or loss
|
41
|
(37)
|
|
|
|
At end of period
|
(4,056)
|
(4,121)
|
|
|
|
Total equity at end of period
|
2,947
|
2,945
|
|
|
|
Condensed consolidated cash flow statement for the half year
ended 30 June 2018 (unaudited)
|
Half year ended
|
|
30 June
|
30 June
|
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Operating activities
|
|
|
Operating profit/(loss) before tax from continuing
operations
|
75
|
(164)
|
Adjustments for non-cash items
|
47
|
(307)
|
|
|
|
|
122
|
(471)
|
Changes in operating assets and liabilities
|
123
|
156
|
|
|
|
Net cash flows from operating activities before tax
|
245
|
(315)
|
Income taxes paid
|
-
|
(14)
|
|
|
|
Net cash flows from operating activities
|
245
|
(329)
|
|
|
|
Net cash flows from investing activities
|
(2)
|
465
|
|
|
|
Net cash flows from financing activities
|
(179)
|
(394)
|
|
|
|
Effects of exchange rate changes on cash and cash
equivalents
|
10
|
(31)
|
|
|
|
Net increase/(decrease) in cash and cash equivalents
|
74
|
(289)
|
Cash and cash equivalents at beginning of period
|
422
|
1,016
|
|
|
|
Cash and cash equivalents at end of period
|
496
|
727
|
Notes
1. Basis of preparation
The Group's condensed consolidated interim financial
statements have been prepared in
accordance with IAS 34 'Interim Financial Reporting'.
Theyshould be read in
conjunction with the 2017 Annual Report and Accounts which were
prepared in accordance with International Financial Reporting
Standards issued by the International Accounting Standards Board
(IASB) and interpretations issued by the International Financial
Reporting Interpretations Committee (IFRIC) of the IASB, as adopted
by the European Union (EU) (together IFRS).
The condensed consolidated interim financial statements are
unaudited. In the opinion of management, all relevant disclosures
necessary for an understanding of the changes in the consolidated
financial position and performance of the Group since the end of
the last annual reporting period have been made.
Going concern
The risk factors which could materially affect the Group's future
results are described on pages 17 to 18.
Having reviewed the Group's forecasts and projections and
considered the interim results of the RBS Group for the half year
ended 30 June 2018, approved on 2 August 2018, which were prepared
on a going concern basis, together with evidence that the RBS Group
will continue to provide sufficient resources to the Group, the
directors have a reasonable expectation that the Group will
continue in operational existence for the foreseeable future.
Accordingly, the interim financial statements for the half year
ended 30 June 2018 have been prepared on a going concern
basis.
2. Accounting policies
In July 2014, the IASB published IFRS 9 'Financial instruments'
with an effective date of 1 January 2018. For further details see
pages 57 and 58 of the Group's 2017 Annual Report and Accounts and
the Appendix, which is consistent with the RBS Group February 2018
IFRS 9 Transition report. There has been no restatement of accounts
prior to 2018. Adoption of IFRS 9 on 1 January 2018 released a net
of €3 million of credit losses in financial assets and
reduced the Group's interest in associates by €32
million.
The Group's principal accounting policies are as set out on pages
50 to 55 of the Group's 2017 Annual Report and Accounts. The
accounting policies have been updated to reflect the adoption of
IFRS 9 on 1 January 2018, as mentioned above. Other than in
relation to IFRS 9, the other amendments effective for 2018, which
include IFRS 15 'Revenue from contracts with customers', IFRS 2
'Share-based payments' and IAS 40 'Investment Property', have not
had a material effect on the Group's 2018 Interim
results.
Critical accounting policies and key sources of estimation
uncertainty
The judgements and assumptions that are considered to be the most
important to the portrayal of the Group's financial condition are
those relating to provisions for liabilities, loan impairment
provisions and fair value of financial instruments. These critical
accounting policies and judgements are described on pages 56 to 57
of the Group's 2017 Annual Report and Accounts. From 1 January
2018, the previous critical accounting policy relating to loan
impairment provisions has been superceded on the adoption of IFRS 9
for which details are included in the Appendix, which is consistent
with the details included in the RBS Group February 2018 IFRS 9
Transition report.
Notes
3. Impairment
provisions
The table below analyses the impairment provisions under IFRS 9/IAS
39.
|
|
|
30 June
|
31 December
|
|
2018
|
2017
|
€m
|
€m
|
|
|
|
Loans and advances
|
39
|
37
|
Securities
|
23
|
22
|
|
|
|
Total
|
62
|
59
|
The closing provision of €62 million is predominately in
stage 3, the impact of the adoption of IFRS 9 on 1 January 2018 was
a net release of €3 million in relation to financial assets
and the other movement in the impairment provisions related to the
charge in the period of €6 million due to changes in risk
parameters.
4. Credit protection arrangements
At 30 June 2018, €0.2 billion (31 December 2017 - €0.2
billion) of assets measured at amortised cost were covered by the
remaining credit protection agreement between the Group and NWM
Plc.
Full details of the Group's credit protection arrangements are
included in the 2017 Annual Report and Accounts.
5. Taxation
The actual tax (charge)/credit differs from the expected tax
(charge)/credit computed by applying the standard Dutch corporation
tax rate of 25% as follows:
|
Half year ended
|
|
30 June
|
30 June
|
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Profit/(loss) before tax
|
65
|
(164)
|
|
|
|
Expected tax (charge)/credit
|
(16)
|
41
|
Losses in period where no deferred tax asset
recognised
|
(18)
|
(14)
|
Foreign profits taxed at other rates
|
1
|
1
|
Non-taxable items (including recycling of foreign exchange
reserve)
|
9
|
(28)
|
Losses brought forward and utilised
|
-
|
2
|
Reduction in carrying value of deferred tax (asset)/liability in
respect of associates
|
(17)
|
7
|
Adjustments in respect of prior periods
|
-
|
7
|
Other
|
-
|
(10)
|
|
|
|
Actual tax (charge)/credit
|
(41)
|
6
|
Notes
6. Segmental analysis
Geographical segments
The geographical analyses in the tables below have been compiled on
the basis of location of office where the transactions are
recorded.
|
Netherlands
|
UK
|
RoW
|
Total
|
30 June 2018
|
€m
|
€m
|
€m
|
€m
|
Net interest income
|
(4)
|
-
|
3
|
(1)
|
Net fees and commissions
|
-
|
-
|
-
|
-
|
Income from trading activities
|
(15)
|
84
|
1
|
70
|
Foreign exchange gains and losses related to net
investment
|
|
|
|
|
hedges reclassified to income following disposals of foreign
operations
|
(19)
|
-
|
-
|
(19)
|
Other operating income
|
24
|
3
|
36
|
63
|
Total income
|
(14)
|
87
|
40
|
113
|
|
|
|
|
|
Operating (loss)/profit before tax
|
(29)
|
66
|
38
|
75
|
Total assets
|
2,518
|
547
|
2,546
|
5,611
|
Total liabilities
|
1,402
|
507
|
755
|
2,664
|
Net assets attributable to equity owners
|
1,116
|
40
|
1,791
|
2,947
|
|
|
|
|
|
30 June 2017
|
|
|
|
|
Net interest income
|
(12)
|
-
|
12
|
-
|
Net fees and commissions
|
-
|
2
|
(1)
|
1
|
Income from trading activities
|
(19)
|
(19)
|
16
|
(22)
|
Foreign exchange gains and losses related to net
investment
|
|
|
|
|
hedges reclassified to income following disposals of foreign
operations
|
(173)
|
-
|
-
|
(173)
|
Other operating income
|
(12)
|
-
|
72
|
60
|
Total income
|
(216)
|
(17)
|
99
|
(134)
|
|
|
|
|
|
Operating (loss)/profit before tax
|
(240)
|
(15)
|
91
|
(164)
|
|
|
|
|
|
31 December 2017
|
|
|
|
|
Total assets
|
3,049
|
555
|
2,472
|
6,076
|
Total liabilities
|
1,797
|
558
|
837
|
3,192
|
Net assets/(liabilities) attributable to equity owners
|
1,252
|
(3)
|
1,635
|
2,884
|
|
|
|
|
|
The Managing Board, as chief operating decision maker manages the
Group as a single reportable segment.
|
Notes
7. Financial instruments: classification
The following tables analyse the Group's financial assets and
liabilities in accordance with the categories of financial
instruments in IFRS 9/IAS 39. Assets and liabilities outside the
scope of IFRS 9/IAS 39 are shown within other assets and other
liabilities.
|
|
|
Amortised
|
Other
|
|
|
MFVPL (1,2)
|
FVOCI (3)
|
cost
|
assets
|
Total
|
Assets
|
€m
|
€m
|
€m
|
€m
|
€m
|
|
|
|
|
|
|
Cash and balances at central banks
|
-
|
-
|
86
|
|
86
|
Loans and advances to banks
|
-
|
-
|
-
|
|
-
|
- amounts due from fellow banks
|
-
|
-
|
2,361
|
|
2,361
|
- other
|
-
|
-
|
411
|
|
411
|
Loans and advances to customers
|
10
|
-
|
73
|
|
83
|
Amounts due from the ultimate holding company
|
-
|
-
|
129
|
|
129
|
Debt securities and equity shares
|
12
|
412
|
-
|
|
424
|
Derivatives
|
657
|
-
|
-
|
|
657
|
Other assets
|
-
|
-
|
-
|
1,460
|
1,460
|
|
|
|
|
|
|
30 June 2018
|
679
|
412
|
3,060
|
1,460
|
5,611
|
|
|
Other
|
Total
|
|
HFT (1,4)
|
DFV (5)
|
AFS (6)
|
LAR (7)
|
assets
|
|
€m
|
€m
|
€m
|
€m
|
€m
|
€m
|
|
|
|
|
|
|
|
Cash and balances at central banks
|
-
|
-
|
-
|
68
|
|
68
|
- amounts due from fellow banks
|
-
|
-
|
-
|
2,643
|
|
2,643
|
- other
|
3
|
-
|
-
|
352
|
|
355
|
Loans and advances to customers
|
10
|
-
|
-
|
83
|
|
93
|
Amounts due from the ultimate holding company
|
-
|
-
|
-
|
125
|
|
125
|
Debt securities and equity shares
|
5
|
95
|
414
|
-
|
|
514
|
Settlement balances
|
-
|
-
|
-
|
4
|
|
4
|
Derivatives
|
761
|
-
|
-
|
-
|
|
761
|
Other assets
|
-
|
-
|
-
|
-
|
1,513
|
1,513
|
|
|
|
|
|
|
|
31 December 2017
|
779
|
95
|
414
|
3,275
|
1,513
|
6,076
|
|
|
|
|
|
|
|
|
|
Amortised
|
Other
|
|
|
HFT(1,4)
|
DFV(5)
|
cost
|
liabilities
|
Total
|
Liabilities
|
€m
|
€m
|
€m
|
€m
|
€m
|
|
|
|
|
|
|
Deposits by banks
|
6
|
-
|
933
|
|
939
|
Customer accounts
|
4
|
-
|
58
|
|
62
|
Debt securities in issue
|
-
|
2
|
-
|
|
2
|
Derivatives
|
458
|
|
|
|
458
|
Subordinated liabilities
|
-
|
544
|
248
|
|
792
|
Other liabilities
|
-
|
-
|
-
|
411
|
411
|
30 June 2018
|
468
|
546
|
1,239
|
411
|
2,664
|
|
|
|
|
|
|
Deposits by banks
|
7
|
-
|
1,125
|
|
1,132
|
Customer accounts
|
6
|
-
|
58
|
|
64
|
Debt securities in issue
|
-
|
27
|
-
|
|
27
|
Settlement balances
|
-
|
-
|
13
|
|
13
|
Derivatives
|
549
|
|
|
|
549
|
Subordinated liabilities
|
-
|
592
|
401
|
|
993
|
Other liabilities
|
-
|
-
|
-
|
414
|
414
|
31 December 2017
|
562
|
619
|
1,597
|
414
|
3,192
|
Notes:
(1)
|
Includes
derivative assets held for hedging purposes of €4 million (31
December 2017 - €14 million) and derivative liabilities held
for hedging purposes of €51 million (31 December 2017 -
€3 million).
|
(2)
|
Mandatory
fair value through profit or loss.
|
(3)
|
Fair
value through other comprehensive income.
|
(4)
|
Held-for-trading.
|
(5)
|
Designated
as at fair value through profit or loss.
|
(6)
|
Available-for-sale.
|
(7)
|
Loans
and receivables.
|
With the exception of changes to IFRS 9 from IAS 39 on 1 January
2018, there were no other reclassification in either the half year
ended 30 June 2018 or the year ended 31 December 2017.
Credit exposure within the scope of the IFRS 9 expected credit loss
framework includes assets held at amortised cost and securities
held at FVOCI, other than equity shares which are out of scope of
the framework (30 June 2018 - €133 million). At 30 June
2018 credit exposure with RBS Group companies is all in stage 1;
approximately 80% of the other exposures under the scope of the
IFRS 9 expected credit loss framework as shown in the table above
is in stage 1 and 10% is in each of stages 2 and 3.
Notes
7. Financial instruments: carried at fair value - valuation
hierarchy
Disclosures relating to the control environment, valuation
techniques and related aspects pertaining to financial instruments
measured at fair value are included in the 2017 Annual Report and
Accounts. Valuation and input methodologies at 30 June 2018 are
consistent with those described in Note 9 of the 2017 Annual Report
and Accounts.
The following tables show financial instruments carried at fair
value on the Group's balance sheet by valuation hierarchy - level
1, 2 and 3.
|
30 June 2018
|
|
31 December 2017
|
|
Level 1
|
Level 2
|
Level 3
|
Total
|
|
Level 2
|
Level 3
|
Total
|
|
€bn
|
€bn
|
€bn
|
€bn
|
|
€bn
|
€bn
|
€bn
|
|
|
|
|
|
|
|
|
|
Assets
|
|
|
|
|
|
|
|
|
Debt securities and equity shares
|
0.4
|
-
|
-
|
0.4
|
|
0.5
|
-
|
0.5
|
- of which are FVOCI (5)
|
0.4
|
-
|
-
|
0.4
|
|
-
|
-
|
-
|
Derivatives
|
-
|
0.6
|
0.1
|
0.7
|
|
0.8
|
-
|
0.8
|
|
|
|
|
|
|
|
|
|
|
0.4
|
0.6
|
0.1
|
1.1
|
|
1.3
|
-
|
1.3
|
|
|
|
|
|
|
|
|
|
Proportion
|
36.4%
|
54.5%
|
9.1%
|
100%
|
|
100%
|
-
|
100%
|
|
|
|
|
|
|
|
|
|
Liabilities
|
|
|
|
|
|
|
|
|
Derivatives
|
-
|
0.3
|
0.2
|
0.5
|
|
0.5
|
0.1
|
0.6
|
Subordinated liabilities
|
-
|
0.5
|
-
|
0.5
|
|
0.6
|
-
|
0.6
|
|
|
|
|
|
|
|
|
|
|
-
|
0.8
|
0.2
|
1.0
|
|
1.1
|
0.1
|
1.2
|
|
|
|
|
|
|
|
|
|
Proportion
|
-
|
80.0%
|
20.0%
|
100%
|
|
91.7%
|
8.3%
|
100%
|
Notes:
(1)
|
Level
1: valued using unadjusted quoted prices in active markets, for
identical financial instruments. Examples include G10 government
securities, listed equity shares and certain US agency
securities.
Level
2: valued using techniques based significantly on observable market
data. Instruments in this category are valued using:
(a) quoted
prices for similar instruments or identical instruments in markets
which are not considered to be active; or
(b) valuation
techniques where all the inputs that have a significant effect on
the valuations are directly or indirectly based on observable
market data.
Level
3: instruments in this category have been valued using a valuation
technique where at least one input which could have a significant
effect on the instrument's valuation, is not based on observable
market data. Where inputs can be observed from market data without
undue cost and effort, the observed input is used. Otherwise, the
Group determines a reasonable level for the input.
|
(2)
|
Transfers between levels are deemed to have occurred at the
beginning of the quarter in which the instruments were transferred.
During 2018 debt securities and equity shares of €0.4
billion transferred from Level 2 to Level 1. Transfers
between level 2 and level 1 in the period represent improved market
liquidity in certain portfolios.
|
(3)
|
The
Group does not have any material liabilities measured at fair value
that are issued with an inseparable third party credit
enhancement.
|
(4)
|
Level 3
instruments were €0.1 billion for assets and €0.2
billion for liabilities (31 December 2017 - nil for assets and
€0.1 billion for liabilities). The increase in assets
in 2018 relates to transfers in of €0.1 billion and the
increase in liabilities in 2018 relates to transfers in of
€0.1 billion (H1 2017 - The decrease in assets primarily
related to €0.1 billion sales and a loss on the income
statement of €0.1 billion and the decrease in liabilities
related to a gain on the income statement of €0.1 billion for
liabilities).
|
(5)
|
Refer
to Note 2 for further information on the impact of IFRS 9 on
classification and basis of preparation, half year ended 30 June
2018 prepared under IFRS 9 and year ended 31 December 2017 under
IAS 39.
|
Notes
7. Financial instruments: Fair value of financial instruments not
carried at fair value
The following table shows the carrying value and fair value of
financial instruments carried at amortised cost on the balance
sheet.
|
30 June 2018
|
|
31 December 2017
|
|
Carrying value
|
Fair value
|
|
Carrying value
|
Fair value
|
|
€m
|
€m
|
|
€m
|
€m
|
|
|
|
|
|
|
Financial assets
|
|
|
|
|
|
Loans and advances to banks
|
2,772
|
2,780
|
|
2,995
|
2,994
|
Loans and advances to customers
|
73
|
56
|
|
83
|
48
|
Amounts due from the ultimate holding company
|
129
|
185
|
|
125
|
192
|
|
|
|
|
|
|
Financial liabilities
|
|
|
|
|
|
Deposits by banks
|
380
|
380
|
|
695
|
695
|
Customer accounts
|
58
|
67
|
|
55
|
64
|
Subordinated liabilities
|
248
|
315
|
|
401
|
466
|
The table above excludes short-term financial instruments for which
fair value approximates carrying value: cash and balances at
central banks, items in the course of collection from and
transmission to other banks, settlement balances, certain deposits
and notes in circulation.
The fair value is the price that would be received to sell an asset
or paid to transfer a liability in an orderly transaction between
market participants at the measurement date. Quoted market values
are used where available; otherwise, fair values have been
estimated based on discounted expected future cash flows and other
valuation techniques. These techniques involve uncertainties and
require assumptions and judgements covering prepayments, credit
risk and discount rates. Furthermore, there is a wide range of
potential valuation techniques. Changes in these assumptions would
significantly affect estimated fair values. The fair values
reported would not necessarily be realised in an immediate sale or
settlement.
|
|
|
8. Contingent liabilities and commitments
|
|
|
|
30 June
|
31 December
|
|
2018
|
2017
|
|
€m
|
€m
|
|
|
|
Guarantees and assets pledged as collateral security
|
4,355
|
4,453
|
Other contingent liabilities
|
703
|
1,019
|
Standby facilities, credit lines and other commitments
|
65
|
78
|
|
|
|
Contingent liabilities and commitments
|
5,123
|
5,550
|
|
|
|
Contingent liabilities arise in the normal course of the Group's
business; credit exposure is subject to the Group's normal
controls. The amounts shown do not, and are not intended to,
provide any indication of the Group's expectation of future
losses.
Notes
9. Litigation, arbitration, investigations and reviews
NatWest Markets N.V. and certain members of RBS Group are party to
legal proceedings and the subject of investigation and other
regulatory and governmental action in the Netherlands, the United
Kingdom (UK), the European Union (EU), the United States (US) and
other jurisdictions.
The Group recognises a provision for a liability in relation to
these matters when it is probable that an outflow of economic
benefits will be required to settle an obligation resulting from
past events, and a reliable estimate can be made of the amount of
the obligation. While the outcome of these matters is inherently
uncertain, the directors believe that, based on the information
available to them, appropriate provisions have been made in respect
of the matters as at 30 June 2018.
In many proceedings and investigations, it is not possible to
determine whether any loss is probable or to estimate reliably the
amount of any loss, either as a direct consequence of the relevant
proceedings and investigations or as a result of adverse impacts or
restrictions on the Group's reputation, businesses and operations.
Numerous legal and factual issues may need to be resolved,
including through potentially lengthy discovery and document
production exercises and determination of important factual
matters, and by addressing novel or unsettled legal questions
relevant to the proceedings in question, before a liability can
reasonably be estimated for any claim. The Group cannot predict if,
how, or when such claims will be resolved or what the eventual
settlement, damages, fine, penalty or other relief, if any, may be,
particularly for claims that are at an early stage in their
development or where claimants seek substantial or indeterminate
damages.
In respect of certain matters described below, we have established
a provision and in certain of those matters, we have indicated that
we have established a provision. The Group generally does not
disclose information about the establishment or existence of a
provision for a particular matter where disclosure of the
information can be expected to prejudice seriously the Group's
position in the matter.
There are situations where the Group may pursue an approach that in
some instances leads to a settlement agreement. This may occur in
order to avoid the expense, management distraction or reputational
implications of continuing to contest liability, or in order to
take account of the risks inherent in defending claims or
investigations even for those matters for which the Group believes
it has credible defences and should prevail on the merits. There
are also situations where it may be in the interests of members of
the Group to settle adverse claims, including involving significant
amounts, on a commercial basis in order to facilitate the
achievement of a wider commercial or strategic objective. The
uncertainties inherent in all such matters affect the amount and
timing of any potential outflows for both matters with respect to
which provisions have been established and other contingent
liabilities.
The future outflow of resources in respect of any matter may
ultimately prove to be substantially greater than or less than the
aggregate provision that the Group has recognised. Where (and as
far as) liability cannot be reasonably estimated, no provision has
been recognised.
Other than those discussed below, no member of the Group is or has
been involved in governmental, legal or regulatory proceedings
(including those which are pending or threatened) that are expected
to be material individually or in aggregate.
RBS Group is involved in ongoing litigation, investigations and
reviews that are not described below but are described on pages 32
to 43 in RBS Group's H1 2018 Results. RBS Group expects that in
future periods, additional provisions, settlement amounts and
customer redress payments will be necessary, in amounts that are
expected to be substantial in some instances. While the Group may
not be directly involved in such RBS Group matters, any final
adverse outcome of those matters may also have an adverse effect on
the Group.
For a discussion of certain risks associated with the Group's
litigation, investigations and reviews see the Risk Factor relating
to legal, regulatory and governmental actions and investigations
set out on page 117 of the Group's Annual Report and Accounts
2017.
Notes
9. Litigation, arbitration, investigations and
reviews continued
Madoff
NatWest Markets N.V. is a defendant in two actions filed by Irving
Picard, as trustee for the bankruptcy estates of Bernard L. Madoff
and Bernard L. Madoff Investment Securities LLC, in bankruptcy
court in New York. In both cases, the trustee alleges that certain
transfers received by NatWest Markets N.V. amounted to fraudulent
conveyances that should be clawed back for the benefit of the
Madoff estate.
In the primary action, filed in December 2010, the trustee seeks to
recover US$75.8 million in redemptions that NatWest Markets N.V.
allegedly received from certain Madoff feeder funds and US$87.5
million that NatWest Markets N.V. allegedly received from certain
swap counterparties (in August 2018, the trustee dismissed, without
prejudice to-refiling, one of the claims that the trustee had
asserted in the primary action relating to US$74.6 million that
NatWest Markets N.V. allegedly received from a Madoff feeder fund).
In the second action, filed in October 2011, the trustee seeks to
recover an additional US$21.8 million. In November 2016, the
bankruptcy court dismissed the second case on international comity
grounds, and that decision is currently on appeal to the United
States Court of Appeals for the Second Circuit. The primary case
remains pending before the bankruptcy court, where it will be
subject to a further motion to dismiss.
Australian Bank Bill Swap Reference Rate (BBSW)
In August 2016, a class action complaint was filed in the United
States District Court for the Southern District of New York against
certain RBS Group companies (including NatWest Markets N.V.) and a
number of other financial institutions. The complaint alleges that
the defendants conspired to manipulate the BBSW and asserts claims
under the U.S. antitrust laws, the Commodity Exchange Act, RICO
(Racketeer Influenced and Corrupt Organizations Act), and the
common law. This matter is subject to a motion to dismiss that is
currently pending.
Fondazione Monte dei Paschi di Siena
A claim for €285.9 million was brought by Fondazione Monte
dei Paschi di Siena (FMPS) in July 2014 against former directors
and 13 syndicate banks, including NatWest Markets N.V., in
connection with an Italian law-governed term facility agreement for
€600 million dated 4 June 2011. The claim is a civil action
based on a non-contractual liability arising from the alleged
breach of the by-laws of FMPS which set a 20 per cent
limit for its debt to equity ratio (the Ratio). The lenders
are alleged to have aided and abetted the former directors of FMPS
to breach the Ratio. It is alleged that as sophisticated financial
institutions, each lender should have known FMPS's financial
situation, including its debt to equity ratio, and that putting the
facility in place would cause it to breach the Ratio. NatWest
Markets N.V. will defend the claim, which has been transferred
to the Florence courts. A hearing on certain preliminary
issues is due to begin on 27 September 2018.
US Anti-Terrorism Act litigation
NatWest Markets N.V. and certain other financial institutions are
defendants in an action pending in the United States District Court
for the Eastern District of New York, filed in November 2014, by a
number of US nationals (or their estates, survivors, or heirs),
most of whom are or were US military personnel, who were killed or
injured in more than 90 attacks in Iraq between 2004 and
2011.
The attacks were allegedly perpetrated by Hezbollah and certain
Iraqi terror cells allegedly funded by the Islamic Republic of
Iran. According to the plaintiffs' allegations, NatWest Markets
N.V. and the other defendants are liable for damages arising from
the attacks because they allegedly conspired with Iran and certain
Iranian banks to assist Iran in transferring money to Hezbollah and
the Iraqi terror cells, in violation of the US Anti-Terrorism Act,
by agreeing to engage in 'stripping' of transactions initiated by
the Iranian banks so that the Iranian nexus to the transactions
would not be detected. On 27 July 2018, a magistrate issued a
report to the district court recommending that the district court
deny the defendants' pending motion to dismiss. NatWest Markets
N.V. anticipates requesting that the district court grant the
motion to dismiss notwithstanding the magistrate's
recommendation.
An additional set of plaintiffs filed a second, substantially
similar action against NatWest Markets N.V. and other financial
institutions in November 2016. That case was pending in the United
States District Court for the Eastern District of New York until
October 2017, when the plaintiffs, instead of responding to
defendants' motion to dismiss, voluntarily dismissed their claims
without prejudice to re-filing at a later date.
Notes
9. Litigation, arbitration, investigations and
reviews continued
In November 2017, a third set of plaintiffs filed an action against
NatWest Markets N.V., NatWest Markets Plc, and others in the United
States District Court for the Southern District of New York. The
allegations are substantially similar to the allegations contained
in the complaints described above and concern 55 attacks in Iraq
between 2003 and 2011. The defendants have made a motion to dismiss
this matter which is currently pending.
Interest rate swap claim by Ville d'Aubagne
Ville d'Aubagne, a French local authority, filed a claim in April
2013 against NatWest Markets N.V. and NatWest Markets Plc in
respect of two structured interest rates swaps, which were entered
into between Ville d'Aubagne and NatWest Markets N.V., and novated
to NatWest Markets Plc in 2009. In the same year, they were
terminated early and a rescheduling agreement was entered into
under which payments were rescheduled over 28 years. Ville
d'Aubagne sought retroactive cancellation of the swaps and the
rescheduling agreement. The amount claimed was approximately
€65 million (which was subject to fluctuations in market
value from time to time). The bank was successful in its defence of
the claim, winning at first instance in November 2015. An appeal of
that decision was dismissed by the French Court of Appeal in
January 2018. Ville d'Aubagne has now appealed to the French
Supreme Court.
Investigations and reviews
RBSH Group's businesses and financial condition can be affected by
the actions of various governmental and regulatory authorities in
the Netherlands, the UK, the EU, the US and elsewhere. RBS Group
has engaged, and will continue to engage, in discussions with
relevant governmental and regulatory authorities, including in the
Netherlands, the UK, the EU, the US and elsewhere, on an ongoing
and regular basis, and in response to informal and formal inquiries
or investigations, regarding operational, systems and control
evaluations and issues including those related to compliance with
applicable laws and regulations, including consumer protection,
business conduct, competition/anti-trust, anti-bribery, anti-money
laundering and sanctions regimes.
The NatWest Markets business in particular has been providing
information regarding a variety of matters, including, for example,
the setting of benchmark rates and related derivatives trading,
conduct in the foreign exchange market, and various issues relating
to the issuance, underwriting, and sales and trading of fixed
income securities, including structured products and government
securities.
Any matters discussed or identified during such discussions and
inquiries may result in, among other things, further inquiry or
investigation, other action being taken by governmental and
regulatory authorities, increased costs being incurred by RBSH
Group, remediation of systems and controls, public or private
censure, restriction of RBSH Group's business activities and/or
fines. Any of the events or circumstances mentioned in this
paragraph or below could have a material adverse effect on RBSH
Group, its business, authorisations and licences, reputation,
results of operations or the price of securities issued by
it.
LIBOR and other trading rates
Certain members of RBS Group continue to co-operate with
investigations and requests for information by various governmental
and regulatory authorities into submissions, communications and
procedures around the setting of LIBOR and other interest rates and
interest rate trading.
Foreign exchange related investigations
Certain members of RBS Group continue to co-operate with
investigations and requests for information by various governmental
and regulatory authorities on certain issues relating to failings
in its FX business within its NatWest Markets
business.
Governance and risk management consent order
In July 2011, RBS Group agreed with the Board of Governors of the
Federal Reserve System, the New York State Banking Department, the
Connecticut Department of Banking, and the Illinois Department of
Financial and Professional Regulation to enter into a consent Cease
and Desist Order ('the Governance Order') to address deficiencies
related to governance, risk management and compliance systems and
controls in the US branches of NatWest Markets Plc and NatWest
Markets N.V.. RBS Group entities' obligations under the Governance
Order were terminated by the regulators in the first half of
2018.
Notes
10. Related party transactions
UK Government
During H1 2018 the UK Government's interest in the RBS Group
reduced from 70.1% to 62.4%.
Alawwal
The Groups 40% stake in Alawwal Bank (Alawwal) is the last
significant shared asset of the RFS Holding Consortium.
Alawwal announced in 2017 that it was entering into merger
discussions with Saudi British Bank and in May 2018 announced the
merger ratio applicable to Alawwal shareholders. Discussions
continue over the details of the proposed combination and further
announcements are expected in due course. In the meantime,
the Group continues to consider Alawwal to be an
associate. There
were no material cash flows between the company and Alawwal during
H1 2018 (December 2017: none).
Other related parties
There have been no material changes to the disclosures concerning
the Group's other related parties included in the 2017 Annual
Report and Accounts.
11. Date of approval
The interim results for the half year ended 30 June 2018 were
approved by the Supervisory Board on 31 August 2018.
12. Post balance sheet events
Professional indemnity insurance policies agreement
On 27 July 2018, the RBS Group reached an agreement with certain
insurers and third parties in respect of claims made under certain
2007 - 2009 insurance policies which provided coverage to RBS Group
subsidiaries for certain losses. As a result of the settlement, the
Group expects to recognise £218 million (€248 million)
of the aggregate settlement amount.
Other than as above there have been no significant events between
30 June 2018 and the date of approval of this announcement which
would require a change to or additional disclosure in the
announcement.
Risk factors
Summary of our principal risks and uncertainties
Set out below is a summary of certain risks which could adversely
affect the RBSH Group and NatWest Markets N.V.; it should be read
in conjunction with the Capital and risk management section of the
2017 Annual Report and Accounts. This summary should not be
regarded as a complete and comprehensive statement of all potential
risks and uncertainties or of RBSH's 2017 Annual Report and
Accounts risk factor disclosures. A fuller description of these and
other risk factors is included on pages 112 to 127 of NatWest
Markets N.V.'s 2017 Annual Report and Accounts.
● The RBSH Group is in a period of major business
transformation and structural change as it continues to wind down
certain legacy activities and seeks to repurpose the NatWest
Markets N.V. ("NWM N.V.") entity in order to maintain NatWest
Market Plc's ("NWM") European business and certain other Western
European business, in anticipation of Brexit. The UK is
scheduled to leave the EU on 29 March 2019. The terms of its
departure, including any transition period, and the resulting
economic, trading and legal relationships with both the EU and
other counterparties are currently unclear and subject to
significant uncertainty. The re-purposing of NWM N.V., as
currently planned, requires certain licences and permissions to be
granted by certain regulators. The fact of, and the timing
of, the approval of such licences and permissions cannot be
assured. There can be no certainty that NWM N.V. will be able
to effect these strategic plans in connection with Brexit on a
timely basis, particularly in the absence of a transition
period. Further changes to the RBSH Group's operations and
business may be required. These various transformation and
restructuring activities are costly and complex, with significant
execution, regulatory and operational risks.
● The continued viability of NWM N.V. will depend on
its ability to access sources of liquidity and funding, and to
receive continued financial and operational support from RBSG and
NWM Plc. NWM N.V.'s credit ratings depend significantly on
the credit ratings of RBSG and NWM. Any downgrades in the long-term
or short-term credit ratings of NWM N.V. could adversely affect its
continued viability by increasing the cost of funding, limiting the
range of counterparties and clients willing to enter into
transactions with the RBSH Group, and adversely affecting its
competitive position.
● The RBSH Group's operations are highly dependent
on its and the RBS Group's IT systems and the RBS Group and the
RBSH Group are exposed to cyberattacks. A failure of its or the RBS
Group's IT systems (including as a result of the lack of or
untimely investment) or a failure to prevent or defend itself from
cyberattacks (and provide notification of them) could adversely
affect the RBSH Group's operations, results of operations,
competitive position and reputation and could expose the RBS Group
or the RBSH Group to regulatory sanctions.
● The RBSH Group's ability to meet the targets and
expectations which accompany its own and the RBS Group's
transformation programme as well as its continued wind down of
legacy activities, including the sale of its interest in Alawwal
Bank, are subject to various internal and external risks and are
based on a number of key assumptions and judgments any of which may
prove to be inaccurate.
● The RBSH Group's businesses are exposed to the
effect of movements in interest rates and currency rates, which
could have a material adverse effect on the results of operations,
financial condition or prospects of the RBSH
Group.
● The RBSH Group is subject to a number of legal,
regulatory and governmental actions and investigations.
Unfavourable outcomes in such actions and investigations could have
a material adverse effect on the RBSH Group's operations, operating
results, reputation, financial position and future
prospects.
● Operational risks are inherent in the RBSH Group's
businesses and these risks are heightened as the RBSH Group
implements its transformation programme, including the continued
wind-down of legacy activities, against the backdrop of significant
legal and regulatory changes, including as a result of
Brexit.
● The RBSH Group's business and results of
operations may be adversely affected by increasing competitive
pressures and technological developments in the markets in which it
operates.
● Effective management of RBSH Group's capital is
critical to its ability to operate its businesses, comply with
regulatory obligations, pursue its transformation programmes and
current strategies and pursue its strategic opportunities. In the
context of the evolving regulatory framework relating to the
resolution of financial institutions in the EU, changes to the
funding and regulatory capital framework may require the RBSH Group
to meet higher capital levels than anticipated within its strategic
plans and affect the RBSH Group's funding costs. Failure by the
RBSH Group to comply with regulatory capital, funding, liquidity
and leverage requirements may result in intervention by its
regulators and loss of counterparty and investor confidence, and
may have a material adverse effect on the RBSH Group's results of
operations, financial condition and reputation.
Risk factors
Summary of our principal risks and
uncertainties continued
● As a result of the commercial and regulatory
environment in which it operates, the RBSH Group may be unable to
attract or retain senior management (including members of the
board) and other skilled personnel of the appropriate qualification
and competence. The RBSH Group may also suffer if it does not
maintain good employee relations.
● The financial performance of the RBSH Group has
been, and may continue to be, materially affected by customer and
counterparty credit quality, and deterioration in credit quality or
depressed asset valuations could arise due to prevailing economic
and market conditions and legal and regulatory developments
(including, for example, ongoing reforms with respect to IBORs and
other benchmark rates, including EURIBOR).
● The RBSH Group's businesses are subject to
substantial regulation and oversight, including from prudential and
competition authorities. Significant regulatory developments
(including, for example, ongoing reform with respect to IBORs and
other benchmark rates and the recent General Data Protection
Regulation, which came into effect in May 2018) and increased
scrutiny by regulators have had, and may continue to have, the
effect of increasing financial, operational, compliance and conduct
risks as well as related costs. These regulatory developments could
have a material adverse effect on how the RBSH Group conducts its
business, runs down its legacy activities and implements its
transformation plans and may affect its results of operations and
financial condition.
● The RBSH Group relies on valuation, capital and
stress test models to conduct its business, assess its risk
exposure and anticipate capital and funding requirements. Failure
of these models to provide accurate results or accurately reflect
changes in the micro and macroeconomic environment in which the
RBSH Group operates or findings of deficiencies by the RBSH Group's
regulators, including as part of mandated stress testing, may
result in increased regulatory capital requirements or management
actions and could have a material adverse effect on the RBSH
Group's business, capital and results.
● Reputational risk is inherent in the RBSH Group's
operations.
● The reported results of the RBSH Group are
sensitive to the accounting policies, assumptions and estimates
that underlie the preparation of its financial statements. The RBSH
Group's results in future periods may be affected by changes to
applicable accounting rules and standards.
● A failure in the RBSH Group's risk management
framework (including in respect of, but not limited to, conduct
risk) could adversely affect the ability of the RBSH Group to
achieve its strategic objectives.
● The value or effectiveness of any credit
protection that the RBSH Group has purchased depends on the value
of the underlying assets and the financial condition of the
insurers and counterparties.
● The legal demerger of ABN AMRO Bank N.V. (as it
was then named) has resulted in a cross liability that affects the
legal recourse available to investors.
Additional information
Contact
Matt
Waymark
|
Investor
Relations
|
+44 (0)
20 7672 1758
|
Presentation of Information
In the interim results and unless specified otherwise, the term
'Bank' means NatWest Markets N.V., the 'Group' or 'NWM N.V.' means
the bank and its subsidiaries. 'RBS Holdings' means RBS Holdings
N.V., the parent company of the Bank. 'RBSH Group' is the holding
company and its consolidated subsidiaries and associated
companies.
The Royal Bank of Scotland Group plc (RBSG) is the ultimate holding
company of NWM N.V.. RBS Group refers to RBSG and its consolidated
subsidiaries and associated companies. NWM plc refers to NatWest
Markets plc.
The terms 'Consortium' and 'Consortium Members' refer to RBSG,
Stichting Administratiekantoor Beheer Financiële Instellingen
(the Dutch State, successor to Fortis) and Banco Santander
S.A.(Santander) who jointly acquired RBS Holdings on 17 October
2007 through RFS Holdings B.V. (RFS Holdings).
Cautionary statement regarding forward-looking
statements
This document contains forward-looking statements within the
meaning of the United States Private Securities Litigation Reform
Act of 1995, including (but not limited to) those related to the
RBSH Group being in a period of major business transformation and
structural change (including the wind down of certain legacy
activities and the repurposing of NWM N.V.), the continued
viability of NWM N.V. (including its ability to access sources of
liquidity and funding, as well as to receive continued financial
and operational support, NWM N.V. being dependent on IT systems and
exposed to cyberattacks, NWM N.V.'s ability to meet targets and
expectations, NWM N.V.'s exposure to increasing competitive
pressures and technological developments, the effective management
of NWM N.V.'s capital, NWM N.V.'s exposure to political and
economic risks (including with respect to Brexit), operational
risk, reputational risk, interest rate and currency risk, customer
and counterparty risk, conduct risk, cyber and IT risk and credit
rating risk. In addition, forward-looking statements may include,
without limitation, the words 'expect', 'estimate', 'project',
'anticipate', 'commit', 'believe', 'should', 'intend', 'plan',
'could', 'probability', 'risk', 'Value-at-Risk (VaR)', 'target',
'goal', 'objective', 'may', 'endeavour', 'outlook', 'optimistic',
'prospects' and similar expressions or variations on these
expressions. These statements concern or may affect future matters,
such as RBS Group and NWM N.V.'s future economic results, business
plans and current strategies. Forward-looking statements are
subject to a number of risks and uncertainties that might cause
actual results and performance to differ materially from any
expected future results or performance expressed or implied by the
forward-looking statements. Factors that could cause or contribute
to differences in current expectations include, but are not limited
to, legislative, political, fiscal and regulatory developments,
accounting standards, competitive conditions, technological
developments, interest and exchange rate fluctuations and general
economic and political conditions. These and other factors, risks
and uncertainties that may impact any forward-looking statement or
NWM N.V.'s actual results are discussed in NWM N.V.'s 2017 Annual
Report and Accounts and in the RBS Group's 2017 Annual Report and
Accounts as well as in NWM N.V.'s Interim Results for H1 2018 and
the RBS Group's Interim Results for H1 2018. The forward-looking
statements contained in this document speak only as of the date of
this document and RBS Group and NWM N.V. do not assume or undertake
any obligation or responsibility to update any of the
forward-looking statements contained in this document, whether as a
result of new information, future events or otherwise, except to
the extent legally required.
Management's report on the interim financial
statements
Pursuant to section 5:25d, paragraph 2(c), of the Dutch Financial
Supervision Act (Wet op het financieel toezicht (Wft)), the members
of the Managing Board state that to the best of their
knowledge:
●
|
the
interim financial statements give a true and fair view, in all
material respects, of the assets and liabilities, financial
position, and profit or loss of NatWest Markets N.V. and the
companies included in the consolidation as at 30 June 2018 and for
the six month period then ended.
|
●
|
the
interim report, for the six month period ending on 30 June
2018, gives a true and fair view of the information required
pursuant to section 5:25d, paragraphs 8 and 9, of the Dutch
Financial Supervision Act of NatWest Markets N.V. and the companies
included in the consolidation.
|
NatWest Markets N.V. continues to implement its plan to be
operationally ready to serve our European Economic Area (EEA)
customers when the UK leaves the European Union on 29 March 2019,
in the event that there is a loss of access to the EU Single
Market. NatWest Markets N.V. is expected to become a subsidiary of
NWM Plc, subject to regulatory approvals. NatWest Markets N.V. is
currently an indirect subsidiary of RBSG plc.
Amsterdam
31 August 2018
Harm Bots
Chairman of the Managing Board
Cornelis Visscher
Chief Financial Officer
Appendix
IFRS 9 policies1
(1)
|
Consistent
with the RBS Group's IFRS 9 Transition report published on 23
February 2018
|
IFRS 9 Accounting policies
The RBS Group accounting policies that have been significantly
changed as a result of the implementation of IFRS 9, applicable
with effect from 1 January 2018, are set out below. The full
description of accounting policies is set out in the Group 2017
Annual Report and Accounts.
1. Presentation of accounts
As set out in the 2017 Annual Report and Accounts the accounts are
prepared on a going concern basis (see the Report of the directors,
page 112) and in accordance with International Financial Reporting
Standards issued by the International Accounting Standards Board
(IASB) and interpretations issued by the IFRS Interpretations
Committee of the IASB as adopted by the European Union (EU)
(together IFRS). The Group has opted to early adopt the IFRS 9
amendment on negative compensation with effect from 1 January 2018;
this is expected to be endorsed for use in the EU in early
2018.
14. Financial instruments
On initial recognition, financial instruments are measured at fair
value. Subsequently they are measured as follows: designated at
fair value through profit or loss; amortised cost, the default
class for liabilities; fair value through profit or loss, the
default class for assets; or financial assets may be designated as
at fair value through other comprehensive income. Normal purchases
of financial assets classified as amortised cost are recognised on
the settlement date; all other regular way transactions in
financial assets are recognised on the trade date.
Designated as at fair value through profit or loss
- a financial instrument may be designated as at
fair value through profit or loss only if such designation (a)
eliminates or significantly reduces a measurement or recognition
inconsistency; or (b) applies to a group of financial assets,
financial liabilities or both, that the Group manages and evaluates
on a fair value basis; or (c) relates to an financial liability
that contains an embedded derivative which is not evidently closely
related to the host contract. Financial assets that the Group
designates on initial recognition as being at fair value through
profit or loss are recognised at fair value, with transaction costs
being recognised in profit or loss, and are subsequently measured
at fair value. Gains and losses are recognised in profit or loss as
they arise.
Amortised cost assets - have to
meet both the following criteria:
(a) the asset is held within a business model whose
objective is solely to hold assets to collect contractual cash
flows; and
(b) the contractual terms of the financial asset are
solely payments of principal and interest on the outstanding
balance.
Amortised cost liabilities - all liabilities that are not subsequently measured
at fair value are measured at amortised cost.
Assets at fair value through other comprehensive income
- assets have to meet both the following
criteria:
(a) the asset is held within a business model whose
objective is both to hold assets to collect contractual cash flows
and selling financial assets; and
(b) the contractual terms of the financial asset are
solely payments of principal and interest on the outstanding
balance.
An equity instrument may also be designated irrevocably at fair
value through other comprehensive income; realised gains and losses
are not recognised in the income statement.
Fair value through profit or loss - a
financial liability is measured at fair value if it arises from:
a financial guarantee contract; a commitment to lend at below
market rates; an obligation arising from the failed sale of an
asset; or a contingent consideration for a business acquisition.
Fair value through profit or loss is the default classification for
a financial asset.
Reclassifications - financial liabilities cannot be
reclassified. Financial assets are only reclassified where there
has been a change in the business model.
Fair value - the
Group's approach to determining the fair value of financial
instruments measured at fair value is set out in the section of
Critical accounting policies and key sources of estimation
uncertainty entitled Fair value - financial
instruments.
Business model assessment - business models are assessed at portfolio level,
being the level at which they are managed. This is expected to
result in the most consistent classification of assets because it
aligns with the stated objectives of the portfolio, its risk
management, manager's remuneration and the ability to monitor sales
of assets from a portfolio. The criteria for classifying cash flows
as solely principal and interest are assessed against the
contractual terms of a facility, with attention to leverage
features; prepayment and extension terms; and triggers that might
reset the effective rate of interest.
IFRS 9 Accounting policies
15. Impairments
At each balance sheet date each financial asset or portfolio of
advances measured at amortised cost or at fair value through other
comprehensive income, issued financial guarantee and loan
commitment is assessed for impairment. Loss allowances are
forward-looking, based on 12 month expected credit losses where
there has not been a significant increase in credit risk rating,
otherwise allowances are based on lifetime expected losses.
Expected credit losses are a probability-weighted estimate of
credit losses. The probability is determined by the risk of default
which is applied to the cash flow estimates. On a significant
increase in credit risk, credit losses are rebased from 12 month to
lifetime expectations. A change in credit risk is typically but not
necessarily associated with a change in the expected cash
flows.
Where, in the course of the orderly realisation of a loan, it is
exchanged for equity shares or property, the exchange is accounted
for as the sale of the loan and the acquisition of equity
securities or investment property. Where the Group's interest in
equity shares following the exchange is such that the Group
controls an entity, that entity is consolidated.
The costs of loss allowances on assets held at amortised cost are
presented as impairments in the income statement. Allowances
in respect financial guarantees and loan commitments are presented
as other liabilities and charges recorded within impairments.
Financial assets held at amortised cost are presented net of
allowances except where the asset has been wholly or partially
written off.
17. Financial guarantee contracts
Under a financial guarantee contract, the Group, in return for a
fee, undertakes to meet a customer's obligations under the terms of
a debt instrument if the customer fails to do so. A financial
guarantee is recognised as a liability; initially at fair value
and, if not designated as at fair value through profit or loss,
subsequently at the higher of its initial value less cumulative
amortisation and any provision under the contract measured in
accordance with Accounting policy 12. Amortisation is calculated so
as to recognise fees receivable in profit or loss over the period
of the guarantee.
19. Derecognition
A financial asset is derecognised when the contractual right to
receive cash flows from the asset has expired or when it has been
transferred and the transfer qualifies for derecognition. A
transfer requires that the Group either (a) transfers the
contractual rights to receive the asset's cash flows; or (b)
retains the right to the asset's cash flows but assumes a
contractual obligation to pay those cash flows to a third party.
After a transfer, the Group assesses the extent to which it has
retained the risks and rewards of ownership of the transferred
asset. The asset remains on the balance sheet if substantially all
the risks and rewards have been retained. It is derecognised if
substantially all the risks and rewards have been transferred. If
substantially all the risks and rewards have been neither retained
nor transferred, the Group assesses whether or not it has retained
control of the asset. If the Group has retained control of the
asset, it continues to recognise the asset to the extent of its
continuing involvement; if the Group has not retained control of
the asset, it is derecognised.
Where contractual cash flows are modified, but there is no
derecognition event, the gross carrying amount is recalculated
using the original effective interest rate and a modification gain
/ loss is recognised. Where this modification arises on forborne or
defaulted assets this is booked within impairments.
A financial liability is removed from the balance sheet when the
obligation is discharged, or is cancelled, or expires. On the
redemption or settlement of debt securities (including subordinated
liabilities) issued by the Group, the Group derecognises the debt
instrument and records a gain or loss being the difference between
the debt's carrying amount and the cost of redemption or
settlement. The same treatment applies where the debt is exchanged
for a new debt issue that has terms substantially different from
those of the existing debt. The assessment of whether the terms of
the new debt instrument are substantially different takes into
account qualitative and quantitative characteristics including a
comparison of the present value of the cash flows under the new
terms with the present value of the remaining cash flows of the
original debt issue discounted at the effective interest rate of
the original debt issue.
20. Sale and repurchase transactions
Securities subject to a sale and repurchase agreement under which
substantially all the risks and rewards of ownership are retained
by the Group continue to be shown on the balance sheet and the sale
proceeds recorded as a financial liability. Securities acquired in
a reverse sale and repurchase transaction under which the Group is
not exposed to substantially all the risks and rewards of ownership
are not recognised on the balance sheet and the consideration paid
is recorded as a financial asset.
Securities borrowing and lending transactions are usually secured
by cash or securities advanced by the borrower. Borrowed securities
are not recognised on the balance sheet or lent securities
derecognised.
Cash collateral given or received is treated as a loan or deposit;
collateral in the form of securities is not recognised. However,
where securities borrowed are transferred to third parties, a
liability for the obligation to return the securities to the stock
lending counterparty is recorded.
IFRS 9 Accounting policies
21. Netting
Financial assets and financial liabilities are offset and the net
amount presented in the balance sheet when, and only when, the
Group currently has a legally enforceable right to set off the
recognised amounts and it intends either to settle on a net basis
or to realise the asset and settle the liability simultaneously.
The Group is party to a number of arrangements, including master
netting agreements, that give it the right to offset financial
assets and financial liabilities, but where it does not intend to
settle the amounts net or simultaneously, the assets and
liabilities concerned are presented gross.
22. Capital instruments
The Group classifies a financial instrument that it issues as a
liability if it is a contractual obligation to deliver cash or
another financial asset, or to exchange financial assets or
financial liabilities on potentially unfavourable terms and as
equity if it evidences a residual interest in the assets of the
Group after the deduction of liabilities. The components of a
compound financial instrument issued by the Group are classified
and accounted for separately as financial assets, financial
liabilities or equity as appropriate.
Incremental costs and related tax that are directly attributable to
an equity transaction are deducted from equity.
The consideration for any ordinary shares of the company purchased
by the Group (treasury shares) is deducted from equity. On the
cancellation of treasury shares their nominal value is removed from
equity and any excess of consideration over nominal value is
treated in accordance with the capital maintenance provisions of
the Companies Act. On the sale or reissue of treasury shares the
consideration received and related tax are credited to equity, net
of any directly attributable incremental costs.
23. Derivatives and hedging
Derivative financial instruments are initially recognised, and
subsequently measured, at fair value. The Group's approach to
determining the fair value of financial instruments is set out in
the section of Critical accounting policies and key sources of
estimation uncertainty entitled Fair value - financial instruments;
further details are given in Note 9 on the accounts.
Gains and losses arising from changes in the fair value of
derivatives that are not the hedging instrument in a qualifying
hedge are recognised as they arise in profit or loss. Gains and
losses are recorded in Income from trading activities except for
gains and losses on those derivatives that are managed together
with financial instruments designated at fair value; these gains
and losses are included in Other operating income.
The Group enters into three types of hedge relationship: hedges of
changes in the fair value of a recognised asset or liability or
unrecognised firm commitment (fair value hedges); hedges of the
variability in cash flows from a recognised asset or liability or a
highly probable forecast transaction (cash flow hedges); and hedges
of the net investment in a foreign operation.
Hedge relationships are formally designated and documented at
inception. The documentation identifies the hedged item and the
hedging instrument and details the risk that is being hedged and
the way in which effectiveness will be assessed at inception and
during the period of the hedge. If the hedge is not highly
effective in offsetting changes in fair values or cash flows
attributable to the hedged risk, consistent with the documented
risk management strategy, hedge accounting is discontinued. Hedge
accounting is also discontinued if the Group revokes the
designation of a hedge relationship.
Fair value hedge - in a
fair value hedge, the gain or loss on the hedging instrument is
recognised in profit or loss. The gain or loss on the hedged item
attributable to the hedged risk is recognised in profit or loss
and, where the hedged item is measured at amortised cost, adjusts
the carrying amount of the hedged item. Hedge accounting is
discontinued if the hedge no longer meets the criteria for hedge
accounting; or if the hedging instrument expires or is sold,
terminated or exercised; or if hedge designation is revoked. If the
hedged item is one for which the effective interest rate method is
used, any cumulative adjustment is amortised to profit or loss over
the life of the hedged item using a recalculated effective interest
rate.
IFRS 9 Accounting policies
Cash flow hedge - in a
cash flow hedge, the effective portion of the gain or loss on the
hedging instrument is recognised in other comprehensive income and
the ineffective portion in profit or loss. When the forecast
transaction results in the recognition of a financial asset or
financial liability, the cumulative gain or loss is reclassified
from equity to profit or loss in the same periods in which the
hedged forecast cash flows affect profit or loss. Otherwise the
cumulative gain or loss is removed from equity and recognised in
profit or loss at the same time as the hedged transaction. Hedge
accounting is discontinued if the hedge no longer meets the
criteria for hedge accounting; if the hedging instrument expires or
is sold, terminated or exercised; if the forecast transaction is no
longer expected to occur; or if hedge designation is revoked. On
the discontinuance of hedge accounting (except where a forecast
transaction is no longer expected to occur), the cumulative
unrealised gain or loss is reclassified from equity to profit or
loss when the hedged cash flows occur or, if the forecast
transaction results in the recognition of a financial asset or
financial liability, when the hedged forecast cash flows affect
profit or loss. Where a forecast transaction is no longer expected
to occur, the cumulative unrealised gain or loss is reclassified
from equity to profit or loss immediately.
Hedge of net investment in a foreign operation
- in the hedge of a net
investment in a foreign operation, the portion of foreign exchange
differences arising on the hedging instrument determined to be an
effective hedge is recognised in other comprehensive income. Any
ineffective portion is recognised in profit or loss. Non-derivative
financial liabilities as well as derivatives may be the hedging
instrument in a net investment hedge. On disposal or partial
disposal of a foreign operation, the amount accumulated in equity
is reclassified from equity to profit or loss.
Key IFRS 9 terms and differences to current accounting and
regulatory framework
Attribute
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IFRS 9
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IAS 39
|
Regulatory (CRR)
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Default / credit impairment
|
To determine the risk of a default occurring, management applies a
default definition that is consistent with the Basel/Regulatory
definition of default.
Assets that are defaulted are shown as credit impaired. RBS uses 90
days past due as a consistent measure for default across all
product classes. The population of credit impaired assets is
broadly consistent with IAS 39, though measurement differs because
of the application of MES. Assets that were categorised as
potential problems with no impairment provision are now categorised
as Stage 3.
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Default aligned to loss events, all financial assets where an
impairment event has taken place - 100% probability of default and
an internal asset quality grade of AQ10 - are classed as
non-performing.
Impaired financial assets are those for which there is objective
evidence that the amount or timing of future cash flows have been
adversely impacted since initial recognition.
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A default shall be considered to have occurred with regard to a
particular financial asset when either or both of the following
have taken place:- RBS considers that the customer is unlikely
to pay its credit obligations without recourse by the institution
to actions such as realising security;- the customer is past
due more than 90 days.
For Retail exposures, the definition of default may be applied at
the level of an individual credit facility rather than in relation
to the total obligations of a borrower.
|
Probability of default (PD)
|
PD is the likelihood of default assessed on the prevailing economic
conditions at the reporting date (point in time), adjusted to take
into account estimates of future economic conditions that are
likely to impact the risk of default; it will not equate to a long
run average.
|
Regulatory PDs adjusted to point in time metrics are used in the
latent provision calculation.
|
The likelihood that a customer will fail to make full and timely
repayment of credit obligations over a one year time
horizon. For Wholesale, PD models reflect losses that would
arise through-the-cycle; this represents a long run average view of
default levels. For Retail, the prevailing economic conditions at
the reporting date (point in time) are used.
|
Significant increase in credit risk (SICR)
|
A framework incorporating both quantitative and qualitative
measures aligned to the Group's current risk management framework
has been established. Credit deterioration will be a management
decision, subject to approval by governing bodies such as the Group
Provisions Committee.
The staging assessment requires a definition of when a SICR has
occurred; this moves the loss calculation for financial assets from
a 12 month horizon to a lifetime horizon. Management has
established an approach that is primarily informed by the increase
in lifetime probability of default, with additional qualitative
measures to account for assets where PD does not move, but a high
risk factor is determined
|
Not applicable.
|
Not applicable.
|
Forward-looking and multiple scenarios
|
The evaluation of future cash flows, the risk of default and
impairment loss should take into account expectations of economic
changes that are reasonable.
More than one outcome should be considered to ensure that the
resulting estimation of impairment is not biased towards a
particular expectation of economic growth.
|
Financial asset carrying values based upon the expectation of
future cash flows.
|
Not applicable.
|
Key IFRS 9 terms and differences to current accounting and
regulatory framework
Attribute
|
IFRS 9
|
IAS 39
|
Regulatory
|
Loss given default (LGD)
|
LGD is a current assessment of the amount that will be recovered in
the event of default, taking account of future conditions. It may
occasionally equate to the regulatory view albeit with conservatism
and downturn assumptions generally removed.
|
Regulatory LGD values are often used for calculating collective and
latent provisions; bespoke LGDs are also used.
|
An estimate of the amount that will not be recovered in the event
of default, plus the cost of debt collection activities and the
delay in cash recovery. LGD is a downturn based metric,
representing a prudent view of recovery in adverse economic
conditions.
|
Exposure at default (EAD)
|
Expected balance sheet exposure at default. It differs from
the regulatory method as follows:- it includes the effect of
amortisation; and
- it caps exposure at the contractual limit.
|
Based on the current drawn balance plus future committed
drawdowns.
|
Models are used to provide estimates of credit facility utilisation
at the time of a customer default, recognising that customers may
make further drawings on unused credit facilities prior to default
or that exposures may increase due to market movements. EAD cannot
be lower than the reported balance sheet, but can be reduced by a
legally enforceable netting agreement.
|
Date of initial recognition (DOIR)
|
The reference date used to assess a significant increase in credit
risk is as follows. Term lending: the date the facility became
available to the customer. Wholesale revolving products: the date
of the last substantive credit review (typically annual) or, if
later, the date facility became available to the customer. Retail
Cards: the account opening date or, if later, the date the
card was subject to a regular three year review or the date of any
subsequent limit increases. Current Accounts/ Overdrafts: the
account opening date or, if later, the date of initial granting of
overdraft facility or of limit increases.
|
Not applicable for impairment but defined as the date when the
entity becomes a party to the contractual provisions of the
instrument.
|
Not applicable.
|
Modification
|
A modification occurs when the contractual cash flows of a
financial asset are renegotiated or otherwise modified and the
renegotiation or modification does not result in
derecognition. A modification requires immediate recognition
in the income statement of any impact on the carrying value and
effective interest rate (EIR) or examples of modification events
include forbearance and distressed restructuring. The financial
impact is recognised in the income statement as an impairment
release/(loss).
|
Modification is not separately defined but accounting impact arises
as an EIR adjustment on changes that are not derecognition or
impairment events.
|
Not applicable.
|
Key elements of impairment provisions
IFRS 9 introduces additional complexity into the determination of
credit impairment provisioning requirements; however, the building
blocks that deliver an ECL calculation already existed within the
organisation. Existing Basel models have been used as a starting
point in the construction of IFRS 9 models, which also incorporate
term extension and forward-looking information.
There are five key areas that could materially influence the
measurement of credit impairment under IFRS 9 - two of these relate
to model build and three to their application:
Model build:
●
The determination of
economic indicators that have most influence on credit loss for
each portfolio and the severity of impact (this leverages existing
stress testing mechanisms).
●
The build of term
structures to extend the determination of the risk of loss beyond
12 months that will influence the impact of lifetime loss for
assets in Stage 2.
Model
application:
●
The assessment of the
significant increase in credit risk and the formation of a
framework capable of consistent application.
●
The determination of asset lifetimes
that reflect behavioural characteristics whilst also representing
management actions and processes (using historical data and
experience).
●
The determination of a base case (or
central) economic scenario which has the most material impact (of
all forward-looking scenarios) on the measurement of loss (RBS uses
consensus forecasts to remove management bias).
Critical judgements relating to impairment loss and
determination
Policy elections or simplifications
In addition to the five critical judgments summarised above, which
are relevant from period to period, there is one further
significant judgment that is made as a one-off exercise to support
the day one implementation: this is the application of the new IFRS
9 models to the determination of origination date metrics. Since it
is not possible to determine the economic forecasts and alternative
scenarios going backwards in time it is necessary to use a series
of assumptions to enable this process. RBS has assumed a flat
forward view for all dates historically.
There are some other less significant judgments, elections and
simplification assumptions that inform the ECL process; these are
not seen as 'critical' in determining the appropriate level of
impairment but represent choices taken by management across areas
of estimation uncertainty. The main examples of these
are:
●
Models - e.g. in the
case of some low default portfolios, Basel parameter estimates have
been applied for IFRS 9.
●
Discounting of future
losses - the ECL calculation is based on expected future
cash-flows. These are discounted using the EIR - for practical
purposes, this is typically applied at a portfolio level rather
than being established and operated at an individual asset level;
and
●
MES - it is the
selection of the central (or base) scenario that is most critical
to the ECL calculation, independent of the method used to generate
a range of alternative outcomes and their probabilities. Different
approaches to model MES around the central scenario have all been
found of low significance for the overall ECL
impact.
IFRS 9 Credit risk modelling
IFRS 9 introduces lifetime ECL for the measurement of credit
impairment. This requires the development of new models or the
enhancement of existing Basel models. IFRS 9 ECLs are calculated
using a combination of:
●
Probability of default
(PD);
●
Loss given default (LGD);
and,
●
Exposure at default
(EAD).
In addition, lifetime PDs (as at reporting date and at date of
initial recognition) are used in the assessment of a significant
increase in credit risk (SICR) criteria.
IFRS 9 ECL model design principles
To meet IFRS 9 requirements for ECL estimation, PD, LGD and EAD
used in the calculations must be:
●
Unbiased - material
regulatory conservatism has been removed to produce unbiased model
estimates;
●
Point-in-time -
recognise current economic conditions;
●
Forward-looking -
incorporated into PD estimates and, where appropriate, EAD and LGD
estimates; and
●
For the life of the loan
- all models produce a term structure to allow a lifetime
calculation for assets in
Stages 2 and 3.
IFRS 9 requires that at each reporting date, an entity shall assess
whether the credit risk on an account has increased significantly
since initial recognition. Part of this assessment requires a
comparison to be made between the current lifetime PD (i.e. the
current probability of default over the remaining lifetime) with
the equivalent lifetime PD as determined at the date of initial
recognition.
For assets originated before IFRS 9 was introduced, comparable
lifetime origination PDs do not exist. These have been
retrospectively created using the relevant model inputs applicable
at initial recognition. Due to data availability two practical
measures have been taken:
●
Where model inputs were
not available at the point of initial recognition the earliest
available robust metrics are used. For instance, since Basel II was
introduced in 2008, the earliest available and reliable production
Basel PDs range from between December 2007 and April 2008 depending
on the portfolio; and
●
Economic conditions at
the date of initial recognition are assumed to remain constant from
that point forward.
IFRS 9 ECL model design principles
PD estimates
Wholesale Models
Wholesale PD models use the existing CCI based
point-in-time/through-the-cycle framework to convert one year
regulatory PDs into point-in-time estimates that reflect current
economic conditions across a comprehensive set of region/industry
segments.
One year point-in-time PDs are then extrapolated to multi-year PDs
using a conditional transition matrix approach. The conditional
transition matrix approach allows the incorporation of
forward-looking information by adjusting the credit state
transition probabilities according to projected, forward-looking
changes of credit conditions in each region/industry
segment.
This results in forward-looking point-in-time PD term structures
for each obligor from which the lifetime PD for a specific exposure
can be calculated according to the exposure's residual contractual
maturity.
Critical judgements relating to impairment loss and
determination
LGD estimates
The general approach for the IFRS 9 LGD models has been to leverage
the Basel LGD models with bespoke IFRS 9 adjustments to ensure
unbiased estimates, i.e. use of effective interest rate as the
discount rate and the removal of: downturn calibration, indirect
costs, other conservatism and regulatory floors.
For Wholesale, current and forward-looking economic information is
incorporated into the LGD estimates using the existing CCI
framework. For low default portfolios (e.g. Sovereigns) loss data
is too scarce to substantiate estimates that vary with systematic
conditions. Consequently, for these portfolios, LGD estimates are
assumed to be constant throughout the projection
horizon.
EAD estimates
For Wholesale, while conversion ratios in the historical data show
temporal variations, these cannot (unlike in the case of PD and
some LGD models) be sufficiently explained by the CCI measure and
are presumed to be driven to a larger extent by exposure management
practices. Therefore point-in-time best estimates measures for EAD
are derived by estimating the regulatory model specification on a
rolling five year window.
For loans in the Wholesale portfolio, amortisation profiles are
applied to the outstanding balances, rather than modelling the
future behaviour.
Initial analysis has indicated that there is minimal impact on EAD
arising from changes in the economy for all Retail portfolios
except mortgages. Therefore, forward-looking information is only
incorporated in the mortgage EAD model (through forecast changes in
interest rates).
Significant increase in credit risk
Exposures that are considered significantly credit deteriorated
since initial recognition should be classified within Stage 2 and
assessed for lifetime ECL measurement (exposures not considered
deteriorated carry a 12 month ECL). RBS has adopted a framework to
identify deterioration based primarily on movements in probability
of default supported by additional backstops. The principles
applied are consistent across the bank and align to credit risk
management practices.
The framework comprises the following elements:
●
IFRS 9 lifetime PD
assessment (the primary driver) - on modelled portfolios the
assessment is based on the relative deterioration in
forward-looking lifetime PD.
●
Qualitative high risk
backstops - The PD assessment is complemented with the use of
qualitative high risk backstops to further inform whether
significant deterioration in lifetime risk of default has occurred.
The qualitative high risk backstop assessment includes the use of
the mandatory 30+ days past due backstop, as prescribed by IFRS 9
guidance, and other features such as forbearance support,
heightened monitoring on Wholesale, adverse credit bureau on
Retail.
●
Persistence - Retail
only: The persistence rule ensures that accounts that have met the
criteria for PD driven deterioration are still considered to be
significantly deteriorated for a set number of months thereafter.
This additional rule enhances the timeliness of capture in Stage 2;
it is a Retail methodology feature and is applied to PD driven
deterioration only.
The criteria are based on a significant amount of empirical
analysis and seek to meet three key objectives:
●
Criteria effectiveness -
the criteria should be effective in identifying significant credit
deterioration and prospective default
population.
●
Stage 2 stability - the
criteria should not introduce unnecessary volatility in the Stage 2
population.
●
Portfolio analysis - the
criteria should produce results which are intuitive when reported as part of the
wider credit portfolio.
Primary economic loss drivers and base case scenarios used in IFRS
9 modelling
The forecasts applied for IFRS 9 are those used for financial
planning. Portfolio segmentation and selection of economic loss
drivers follow closely the approach already used in stress testing.
To enable robust modelling, the two or three primary economic
factors impacting loss for each portfolio are selected; this
involves empirical analysis and expert judgment.
Critical judgements relating to impairment loss and
determination
Alternative assumptions for the central base case scenario and
related key economic variables would result in different ECL
outcomes. To illustrate this potential for ECL variability, set out
below are the average over the five year planning horizon (2018 to
2022 inclusive) used in the most recent planning
cycle.
Table below provides summary of the average, minimum and maximum
for some of these key economic variables, updated in H1 2018
to reflect latest Bank of England variables:
Base case economic variables for 2018 - 2022
|
Average
|
Minimum
|
Maximum
|
ECB base rate (%)
|
0.57
|
0.00
|
1.32
|
World GDP - % change year on year
|
2.8
|
2.3
|
3.2
|
UK GDP - % change year on year
|
1.8
|
1.5
|
2.0
|
UK unemployment (%)
|
4.9
|
4.5
|
5.1
|
UK HPI - % change year on year
|
2.2
|
1.1
|
5.0
|
BOE base rate (%)
|
1.01
|
0.50
|
1.25
|
Note:
(1)
Unemployment rate (16 years and over seasonally
adjusted).
|
RBS's approach for multiple economic scenarios (MES)
The base scenario plays a greater part in the calculation of ECL
than the approach to MES.
Wholesale
The 'central scenario' is the bank's internal base case. The
methodology to model the impact of MES around the central scenario
is based on a Monte Carlo simulation approach. This involves
simulating a large number of alternative scenarios around the CCI
projection that corresponds to the central macro base case. The
resulting forward-looking PD and ECL projections are then averaged
across all simulated scenarios to form multi scenario expectations.
To ensure tractability the simulations are performed off-line and
applied in the form of adjustment scalars to the single base case
results in implementation.
The impact of MES on Wholesale portfolios was small (2.5% of Stage
1 and Stage 2 ECL).
The Royal Bank of Scotland Group Plc
2138005O9XJIJN4JPN90
NatWest Markets N.V. X3CZP3CK64YBHON1LE12
Date:31
August 2018
|
THE
ROYAL BANK OF SCOTLAND GROUP plc (Registrant)
|
|
|
|
By: /s/
Jan Cargill
|
|
|
|
Name:
Jan Cargill
|
|
Title:
Deputy Secretary
|