1. The National Bank, an enterprise keeping pace with a changing world
This chapter of the Corporate Report should be read in the light of the developments and trends described in the 2019 Report on economic and financial developments and prudential legislation and supervision. Similarly, it may prove useful to refer to the list of abbreviations contained in that Report when reading this chapter.
9 “We are preparing for tomorrow”
The National Bank of Belgium opened its doors on It aims to continue responding to the community’s 2 January 1851. Almost 170 years have elapsed since expectations and looks to the future with confidence then, and in that time, the Bank has lived through and an open mind. two world wars, various economic and financial crises, and major socio-economic and technological changes. Accordingly, a strategic exercise was launched at the It has also taken part in one of the most ambitious beginning of 2019 involving all the staff in one way or European projects : the Eurosystem. The Bank has another. A short while ago, a new internal slogan was always assigned a central position to social issues and introduced to lead the way for the Bank in this pro‑ has managed to adapt to its changing environment. cess of change : “We are preparing for tomorrow”.
To be a modern central bank at the service of society, at the heart of the Eurosystem
MISSIONS
To ensure fi nancial To guarantee safe To provide economic To safeguard price stability stability and supervise cash and effi cient and fi nancial data the fi nancial system payment systems and analyses
1. Engagement with stakeholders and society To be relevant 2. Ambassadorship and serve as a reference 3. Effi ciency, cost and performance management 4. Risk management 5. Ability to execute change
To act thoughtfully 6. Enterprise Data Management and effi ciently 7. Digital transformation 8. Innovation 9. Corporate social responsibility STRATEGIC GOALS STRATEGIC To be a great place 10. IMMO to work, open to change and socially 11. Culture / New Ways of Working responsible 12. Human capital management / employer branding
Socially Independent With respect and Open-minded responsible experts in confi dence
VALUES
10 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report The Bank’s vision stems from Sometimes these data are available, and sometimes its missions and determines its they have to be collected. For that reason, the Bank strategic goals gives third parties access to the many sets of statistics that it collects and the many studies that it conducts The purpose of the strategic exercise launched at the on the country’s economy. beginning of 2019, actively involving not only the man‑ agement but also the members of staff, was to define As was the case during most of its history, the Bank a vision. The chosen wording illustrates what the Bank wants to continue to be relevant and serving as a aims to be and remain : “A modern central bank at reference in the future. It makes it a point of honour the service of society, at the heart of the Eurosystem”. to perform its tasks correctly in order to deserve its status as a monetary and financial authority and en‑ To be “at the service of society” is the reason for a sure that its research and recommendations carry real central bank’s existence. If the Bank is to continue weight in the public debate. playing a credible role in the public debate, it needs to maintain its excellence and the relevance of its recom‑ The Bank intends to take efficient and carefully mendations, and must be accountable. It must adapt considered action. The managers and their staff to changes in society and place its expertise at the fine-tune their measures and consider how best to service of social debate. It aims to be an organisation proceed and achieve results. Attention to detail is in geared towards change, the Bank’s DNA. both within the Bank and Serving society is the raison in relation to the outside d’être for any central bank The Bank also aims to be world. Its Directors and a great place to work, staff need to maintain top-quality expertise and skills, open to change and act in a socially responsible notably in order to continue influencing the European way. It constantly strives to improve its structures and decision-making process. working methods. It is central to society and aims to act sustainably and with due care. Central banks traditionally operate in four areas of activity, which are also the four main reasons for the National Bank’s existence.
In accordance with the Treaty on the Functioning of the European Union, the main objective of the Eurosystem, of which the Bank is a committed member, is to safeguard price stability. That gives citizens and businesses the necessary assurance to plan their future.
Financial stability and sound financial institutions are essential to ensuring well-being. That is why the Bank’s second mission is to ensure financial stability and supervise the financial system.
The Bank also has a duty to guarantee safe cash and efficient payment systems. Payments need to operate smoothly and people must have complete confidence in them so that the economy functions as it should, as that affects the quality of everyone’s life.
The Bank’s fourth mission is to provide economic and financial data and analyses. It is necessary to have data in order to study problems, make in‑ formed recommendations, and pursue good policies.
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 11 The Bank wants to put its values mutual relationships evolve, etc. An institution in‑ into practice capable of adapting will become obsolete after a time. That is why the Bank’s staff feel involved in The Bank is founded on four values which reflect its society. They take an interest and are keen to learn, DNA and its corporate culture. They are a means of they are open to new prospects and responsive to enabling all staff to find their place in its vision, its change. They stand ready to adapt. That implies four missions and its three strategic objectives. anticipating, sometimes speeding up, sometimes slowing down, listening and talking openly. The Bank’s staff serve society, but they are also players. They are consistently committed to a stable The Bank’s staff spend much of their working time and sustainable economic and financial environment. with their colleagues. It is therefore important for Current topics such as sustainable development, di‑ everyone to feel comfortable. Diversity and inclusion versity and inclusion are also an essential component enhance the quality of the work done. The fourth of the Bank’s operations. Hence the first of its four value, “with respect and in confidence”, there‑ values : “socially responsible”. fore forms the cornerstone of a humane and col‑ legiate organisation. The Bank is synonymous with reliability and acces‑ sible expertise. Its staff know that professionalism, In conclusion, the essence of these four values can be neutrality and integrity are essential. Their critical expressed in an obvious slogan for everyone working thinking and their knowledge and skills – which at the Bank : “We are preparing for tomorrow”. may lead them, if necessary, to defend an oppos‑ ing position – form the foundation of the second There are sixteen strategic, transversal themes which value : “independent experts”. In many respects, will support the Bank’s strategy and ensure its im‑ the Bank is no different from other businesses or plementation in the years ahead. There is a working institutions, but its autonomy – guaranteed by the group for each of these themes. legislature – renders it unique. The corollary to that autonomy is, of course, the obligation to be publicly Thus, there is a separate working group for each of the accountable for its measures and decisions. four missions. Other themes, such as communication, efficiency, cost management and performance man‑ The third value of the Bank’s staff is “open- agement, data management, real estate, human re‑ minded”. “Panta rhei” said the Greek philosopher sources management tools, the digital transformation Heraclitus in around 500 B.C., meaning “every‑ and New Ways of Working, have already formed the thing is constantly changing”. People change, so‑ subject of transversal working groups. In addition, there ciety alters, instruments and tools are redesigned, will be new working groups of the same type focusing
12 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report on the Bank’s representation in external organisations, The conclusions of these working groups, which its flexibility and its ability to implement changes, its make recommendations and propose practical meas‑ risk management, its role of monitoring developments ures, must be promptly translated into action and and innovation, and its social responsibility. clear decisions.
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 13 Abolition of the Board of Censors, reform and getting more women on the Council of Regency
The year 2020 will also see the form the Council of Regency will implementation of a number of increase from 10 to 14. While changes in the organisational the Council of Regency and the The Governor, Pierre Wunsch, receives the ECB President, Christine Lagarde, structure. In the fourth quarter of Board of Censors together had at the Hôtel du Gouverneur. 2018, there was extensive media a total of 26 members, the new comment on the composition of Council of Regency will have the Bank’s management bodies. only 20. The Remuneration and Visit by One of the problems discussed Appointments Committee, which Christine Lagarde, was the under-representation of used to consist of two Regents, women in those bodies. The issue two Censors and the representa‑ President of the ECB was also debated at political level. tive of the Minister of Finance, will from now on comprise Regents On 8 November, one week after tak‑ In March 2019, following these and the Minister’s representative. ing over from Mario Draghi as the head discussions, the majority in the of the European Central Bank (ECB), Chamber of Representatives ta‑ At least one-third of the Council of Christine Lagarde visited the National Bank. bled various amendments to the Regency members must be of the draft Law containing miscellane‑ opposite sex from the other mem‑ Following a bilateral meeting with the ous financial provisions when it bers. It will no longer be chaired Governor, Mrs Lagarde met the mem‑ was still under parliamentary scru‑ by the Governor but by another bers of the Board of Directors to discuss tiny, with a view to amending the of its members appointed by Royal the Bank’s activities and current projects : Bank’s Organic Law. These amend‑ Decree, who must be of the oppo‑ the strategic exercise, the reform of hu‑ ments were passed and they site sex from the Governor. In prac‑ man resources policy, etc. The Governor will lead to a remodelling of the tice, the Council of Regency will and Director Tom Dechaene, a mem‑ Bank’s bodies with effect from the therefore be chaired by a woman ber of the ECB Supervisory Board, also General Meeting of Shareholders from 18 May 2020. talked to her about the activities of the scheduled for 18 May 2020. Governing Council. The Board of Censors will cease The Board of Directors and the staff of to exist. Its auditing responsibili‑ the Bank wish Mrs Lagarde every suc‑ ties will be taken over by the cess in her new job. Audit Committee formed with‑ in the Council of Regency. The number of Regents who, together with the members of the Board of Directors,
14 How are decisions taken in Frankfurt ? What role does the Bank play ?
Most of the decisions announced by the European taken according to the principle of “one mem- Central Bank (ECB) are actually taken by the ber, one vote”. Governing Council, which is the main decision- making body of both the ECB and the Eurosystem, The national central banks of the Eurosystem are the latter comprising the ECB and the 19 central also involved in the preparation of these decisions, banks of the countries which have the euro as essentially via the committees comprising one or their currency. two experts from each central bank and the ECB. These experts hold several meetings a year on The Governing Council comprises the six each area of expertise. members of the ECB Executive Board and the Governors of the 19 central banks of the euro Having the decisions prepared by committees area. They meet in Frankfurt about once every does not only permit improvements to the pro- three weeks and take decisions on subjects posals made by the ECB teams but also offers ranging from mone- the opportunity to tary policy to payment Expert groups prepare decisions verify their feasibility systems, and includ- to be taken by the Eurosystem in the light of specific ing the management national characteris- of the reserves and foreign exchange, the grant tics and to test the degree of support for a of liquidity to banking groups in difficulty, etc. proposal before submitting it for the approval of The Governing Council assesses economic and the Governing Council. monetary developments and takes its monetary policy decisions every six weeks. At the other Apart from the decisions of the Eurosystem it- meetings, it mainly examines questions relating self, the national central banks are also involved to the other tasks and responsibilities of the ECB in decisions relating to financial stability via the and the Eurosystem. Supervisory Board – for the supervision of in- dividual financial institutions (microprudential Every member of the Governing Council has supervision), and the European Systemic Risk the same say in the decision-making process, Board which deals with everything relating to regardless of the size of the member’s country, financial stability in the broad sense (macro economy or financial sector. The members in prudential supervision). fact attend the meetings totally independently and in a personal capacity, and decisions are
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 15 16 Interview
MISSION : Monitoring financial stability and supervising the financial system
ALEXANDRA JESPERS / Financial stability, AML supervision and prudential policy for banks
Monitoring financial stability is one of the Bank’s principal tasks. The latest financial crisis demonstrated very clearly that an individual approach by institutions was not enough to guarantee financial stability and that it was necessary to strengthen the supervision of the financial system as a whole. In April 2014, the Bank was officially designated as the macro‑ prudential authority. One of its tasks is to limit the accumulation of systemic risks. Those risks arise, for example, because of interdependence between insti‑ tutions, or because multiple financial institutions have similar exposures. In addition, the Bank has to ensure that financial institutions have adequate buffers to absorb the impact of these risks if necessary, so that the operation of the financial system is not disrupted.
17 Interview
Detecting and combating We follow general trends “systemic risks” and new developments
In my job as a member of the “Macroprudential super‑ and check the extent to vision” team, I take part in the macroprudential analysis which they represent a of the Belgian banking sector : in practice, this means that I analyse data, such as the many prudential reports risk for financial stability from banks, which I link with the changes in the macro financial environment in which the banks operate. This makes it possible to take note of general trends and new developments, and to check the extent to which able to keep a close watch on the development, these trends and developments represent a risk for implementation and follow-up of various measures. financial stability. If the Bank considers that there is a I find it very satisfying to see that my work contrib‑ systemic risk, it can take the necessary macroprudential utes to practical measures designed to guarantee the measures to combat the increased accumulation of risk stability of the financial system. or to reduce the financial institutions’ vulnerability to the risk. International dimension For instance, the Bank has already taken various measures in relation to the Belgian financial sector’s Macroprudential policy and supervision are still very exposure to the residential property market. Apart largely a national responsibility, but since the end from the vulnerabilities inherent in the residential of 2010, the European Systemic Risk Board (ESRB) and commercial property markets, we keep watch has coordinated the conduct of macroprudential for other systemic risks, such as the macrofinancial policy within the European Union. My job therefore impact of the low interest rate environment and the also has an international dimension ; as a member search for yield, but also the risks associated with of permanent working groups and on account of climate change and the transition to a low-carbon temporary work flows, I can take part in macro economy. Since starting this job in 2015, I have been prudential analysis at European level and gain a great deal of expertise.
Publications
I also work on a number of the Bank’s publications, such as the Annual Report. Every year, our Service also publishes the Financial Stability Report (FSR), reviewing the work that we have done in the past year. The FSR describes recent developments in the macroeconomic environment and in the financial sector, and their implications for financial stability. For a number of years now, the Bank has been pub‑ lishing a report on non-bank portfolio management and financial intermediation (shadow banking), for which we work not only with various services at the Bank but also with the FSMA.
To sum up, my work at the Bank has given me the opportunity to learn a huge amount in a short time, in an interesting and motivating environment. I enjoy being able to contribute to financial sector policy and supervision at both national and international level.
18 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report The Bank performs various prudential tasks and acts as the resolution authority
The Bank performs various tasks relating to prudential supervision, which involves monitoring the stability of the financial system and compliance by financial institutions with the rules imposed on them, notably in order to ensure that they remain sound. As the Belgian macroprudential authority, the Bank makes sure that interactions between financial institutions do not result in mutual contagion in the event of a problem. Under the single supervisory mechanism (SSM), it exercises microprudential supervision over individual credit institutions, but it is also the supervisory authority for insurance undertakings, financial market infrastructures and payment institutions. In addition, the Bank is responsible for various tasks connected with the fight against money-laundering and terrorist financing. It also acts as the resolution authority via the Resolution College which was set up at the Bank.
Various operational aspects of these technical and regulatory tasks, as well as the developments seen in 2019, are discussed in detail in the 2019 Report on economic and financial developments and prudential regulation and supervision.
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 19 New measures concerning mortgage loans
The property market On 5 September 2019, having Belgium. In practical terms, the has been a focus of found that the lending criteria ap‑ Bank set thresholds for a range plied by the banks had deteriorated of indicators, to serve as bench‑ attention for the Bank again, the Bank announced new marks for sound, prudent mort‑ for many years in view expectations concerning new mort‑ gage lending. The indicators of the potentially serious gage loans ; those expectations were used include the loan-to-value repercussions on financial published on 25 October 2019. ratio (LTV), which relates the stability that could be With this new step, the Bank aims amount of the loan to the value to improve the quality of the loans of the property being financed. triggered by any major granted by reducing the proportion A borrower who suffered a loss shock on that market. of very risky loans in new mortgage of income might no longer be lending. It thus intends to safeguard able to guarantee repayment of financial stability and ensure that, the loan and it might be necessary even in the case of a serious shock, to sell the property. A reason‑ the financial system can continue able LTV ratio enables the bank to to perform its financial intermedia‑ recover the outstanding amount tion role. of the capital. Conversely, if high LTV ratios became widespread, a crisis leading to higher unem‑ New Circular spelling ployment, for example, could out expectations to jeopardise financial stability and banks and insurance cause a slump in property prices. undertakings Although the Bank is not adopt‑ ing that as its baseline scenario The Bank spelt out its expecta‑ for the years ahead, in the context tions in a new Circular – avail‑ of its macroprudential mandate able on its website – addressed it has to ensure that the risks to credit institutions and insur‑ – including those which are un‑ ance undertakings operating in likely but would have a potentially
20 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report significant impact, also known as these meetings and the points expectations. In so doing, it “tail risks”, are adequately cov‑ raised in the financial sector’s of‑ wishes to allow financial institu‑ ered. The prudential expectations ficial response, obtained at the tions some leeway, notably via are set out in more detail in a end of September, on completion the “comply or explain” mecha‑ box in the Economic and financial of the consultation procedure. nism which enables an institution developments part of the Bank’s – e.g. one with a very specific Annual Report 2019. business model – to deviate from An early, initial the expectations if it can dem‑ The mortgage market is highly response to a onstrate that its lending policy is competitive. The Bank therefore recommendation to sound and does not lead to the needs to ensure that the measures the Finance Minister accumulation of systemic risks on which it adopts are applied in the the market. Of course, the Bank same way to all the entities con‑ On the basis of these expecta‑ will take additional measures if cerned, so as not to cause undue tions, the Bank was therefore necessary. Those measures could distortion of competition and to able to provide an early, initial take various forms : a recommen‑ preserve a level playing field. The response to a Recommendation dation to the microprudential prudential expectations and the by the European Systemic Risk authorities, an additional macro definitions of the various indica‑ Board (ESRB), the institution re‑ prudential measure or, in the tors therefore formed the subject sponsible for the coordination of event of a widespread tendency, of a consultation procedure with macroprudential policy in the EU. a recommendation to the govern‑ the sector. Meetings were held in That Recommendation, addressed ment on activating legally-binding mid-September with the Belgian to the Finance Minister and the measures. In his official response banking federation (Febelfin) and Bank, concerned the activation to the ESRB Recommendation, the insurers’ union (Assuralia) of measures having a direct im‑ the Finance Minister also men‑ in order to clarify any doubtful pact on the profile of new lend‑ tioned that if the Bank’s measures points. In finalising its prudential ing. Although the ESRB referred were not sufficiently effective, the expectations, the Bank took ac‑ to legally-binding measures, the government could consider acti‑ count of the comments made at Bank initially opted for prudential vating additional measures.
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 21 Cooperation is essential to banking supervision
Since 2014, the prudential super‑ 13 Belgian credit institutions or One of the long-term aims is to vision of credit institutions has groups classed as significant (sig‑ maintain a critical approach to been transferred to the European nificant institutions – SIs). each case by preventing the ef‑ Central Bank in the form of the fects of work becoming too mun‑ SSM. The purpose of these tasks The Bank also exercised direct dane and fatigue setting in. entrusted to the ECB is to pro‑ supervision over 19 credit insti‑ mote both the security and the tutions, including three financial By enabling staff to switch be‑ soundness of credit institutions holding companies classed as less tween off-site supervision teams and the stability of the financial significant institutions (LSIs). and thus to learn about the spe‑ system in the EU, to have a good cific features of the various bank‑ overview of a banking group as ing structures and organisations, a whole and its general health, Belgian inspectors take these good practices give off-site and to reduce the risk of diver‑ part in numerous cross- staff the chance to develop their gent interpretations and contra‑ border inspections expertise and, indirectly, to ex‑ dictory decisions at the level of pand the opportunities for man‑ each entity. During 2019, cooperation be‑ aging their career. tween the Bank and the European The Bank is involved in the ECB’s System of Central Banks was fur‑ This rotation within the teams decisions as a member of the ther intensified via the exchange will also stimulate exchanges be‑ SSM Supervisory Board, not only of staff and the integration of tween colleagues in their various for Belgian credit institutions but trainees in the off-site prudential areas of expertise. also for all banks in the euro supervision teams. area. Notwithstanding this gen‑ In addition, in view of the digi‑ eral rule, if a credit institution In on-site prudential supervision, talisation of the banking sector, is not considered significant on this closer cooperation was also the Bank considered it a prior‑ the basis of the SSM criteria, the evident in the participation of ity to set up an intensive training ECB delegates responsibility for Belgian inspectors in numerous programme for its off-site staff in the prudential supervision of that cross-border inspections of credit order to enable them to perfect institution to the local supervisory institutions based in the euro area. their skills in analysis of the impact authority, i.e. the Bank. of digitalisation on banks’ business Another notable feature is the models and organisation, includ‑ In 2019, the Bank took part in rotation within off-site prudential ing the analysis of their cyber risks 13 Joint Supervisory Teams (JSTs) supervision teams, organised for and IT risks. set up by the ECB, which carried some of the staff from January out supervisory tasks concerning 2020 onwards.
22 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report Definite progress towards proportionality for the banks
The proportionality Aware of the problem that such also governance, inspection and principle, which aims in a plethora of requirements can monetary statistics. Analysis of represent for the smallest insti‑ these various points therefore en‑ particular to take account tutions, the EU law-makers and tailed the involvement of the vari‑ of the nature, scope and prudential supervisors in general ous Bank departments concerned. complexity of institutions’ wanted to strengthen the applica‑ activities in the legislation tion of proportionality in the new Wishing to respond effectively and its implementation, EU Regulation CRR2. Among oth‑ and gain a better idea of the er things, this led to the specifica‑ sector’s concerns, the Bank or‑ was high on the agenda tion of a category of “small, non- ganised a workshop attended again in 2019 at both complex” institutions. A number by representatives of the sector European and Belgian of simplified requirements were and its various departments con‑ level. Following the specified for institutions in that cerned. This gave the sector the category, making the legislation opportunity to clarify certain is‑ financial crisis, the more proportionate. sues, and enabled the Bank to in‑ regulatory arsenal was dicate possible approaches, taking expanded considerably The other measures in the CRR2 account of the growing number to mitigate the defects also included the mandates given of international standards. These to the European Banking Authority discussions identified a range of which had led to the crisis. (EBA) in order to reduce the costs measures to be taken. Consequently, over the involved in the various reporting past decade or so, there regimes. In that context, a dia‑ The measures described above has been a steady increase logue was also launched between represent a key step towards im‑ in the burden entailed the Bank and the financial sec‑ proving the incorporation of pro‑ tor at Belgian level. The financial portionality. In the future, there for credit institutions in sector drew up a list of points will most likely be further discus‑ meeting the prudential on which it wanted a more pro‑ sions to feed into the debate on requirements. portionate approach. Those points the international scene, notably as were many and varied. Examples regards reporting and the conduct include prudential reporting, but of supervision.
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 23 Financial supervision of insurance and reinsurance undertakings
At the end of 2019, the Bank relatively considerable (over 10% give priority to monitoring the exercised supervision over 81 in‑ of total premium income). technical provisions, the quality stitutions (insurers, reinsurers and of the regulatory capital calcula‑ surety companies, as well as re‑ The Bank keeps a close eye on tions, and the nature of the firms’ gional public transport companies the quality of the financial re‑ asset portfolios. which bear part of their insurance ports submitted to it periodically. themselves). The number of un‑ It has developed validation tests In the long run, the persistence of dertakings subject to supervision which are applied automatically a low interest rate environment stabilised following the trend to‑ to the periodic financial reports. threatens to become a problem wards consolidation in the sector Accurate reporting is essential for some undertakings conduct‑ triggered by the entry into force of as it forms the cornerstone of ing life insurance business. The the new prudential regime. In ad‑ prudential supervision. The Bank situation of certain undertakings dition, there were 46 branches of contacted a number of under‑ is already requiring the Bank’s undertakings governed by the law takings for the correction of in‑ special attention owing to their of another EEA member country consistencies in their financial business model. The Bank is operating on the Belgian market, reports. The Bank will continue therefore exercising closer super‑ and just under 1 100 undertakings with this exercise in order to vision over undertakings with the accorded access under the rules constantly improve the quality of highest risk profile. on freedom to provide services. these reports. It is also working Of those, only 80 actually devel‑ hard on the establishment of a As part of the overall approach oped a business activity in Belgium. range of tools permitting more to supervision, on-site inspections The premium income generated detailed analysis of the data. remain an important tool for de‑ via the above channels became In that connection, the Bank will tecting weaknesses, particularly in
24 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report regard to insurers’ best estimates. auditors and to the professional the Belgian market. The study The process as a whole (from associations forms the starting showed that the profitability of identification of the need for an point for better communication the products depends on their inspection to establishment of the with the Bank, and should ulti‑ characteristics. In order to en‑ inspectors’ findings) prompted the mately improve the coordination sure a level playing field, firms supervision teams to take strin‑ between the work of the Bank were asked, when calculating gent measures against certain and that of the auditors. the best estimate and setting the undertakings. parameters, to carry out a num‑ In order to chart the profitabil‑ ber of sensitivity analyses. These ity of supplementary individual make it possible to assess the Examination of the health insurance, the Bank con‑ best estimates submitted by the compliance function ducted a horizontal analysis of undertakings. and the auditors’ work
The inspection teams conducted a transversal study of the or‑ ganisation and operation of the compliance function. This study Assessment of the IT risk revealed that undertakings gen‑ erally opt for an in-house com‑ Using a questionnaire completed during on-site meetings, the Bank pliance function so that it has a collected information from eleven significant insurers and reinsurers good knowledge of the undertak‑ on the IT risks that they face and how they manage them. ing’s activities. Risk analysis and work planning are areas where In this questionnaire, the assessment of a firm’s IT risk level is improvement is desirable to cre‑ based on the assessment of five sub-categories of IT risks (se‑ ate more transparency regarding curity, availability and continuity, change, outsourcing and data both the adequacy of the compli‑ integrity), while the assessment of the IT risk control framework is ance function’s coverage of the based on ten dimensions (IT governance, IT organisation and out‑ compliance risks facing the firm, sourcing, IT risk management, IT security management, IT opera‑ and the human resources neces‑ tions management, software acquisition, software development sary for the proper performance and project management, data quality management and data of the function. aggregation capacity, IT continuity management, and IT reports and internal IT audit). In 2019, cooperation with the accredited auditors contin‑ ued – within the framework of their duty to cooperate with the Bank as specified in an ad-hoc Circular – in order to obtain a sufficiently broad picture of their actual activities relating to a number of specific areas, such as the methods of assessing the best estimates. This resulted in a number of general findings which were examined in greater depth in dialogues with several firms of auditors, in which the latter ex‑ plained their method and provid‑ ed details of the audits conducted and the stringency of their tests. The feedback sent to the firms of
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 25 Changes in the prudential supervision framework for the insurance sector
Solvency II, the new From the start, the Solvency II insurance undertakings. An initial prudential supervision framework has made provision detailed analysis of the set of pro‑ for a range of transitional meas‑ posals was then submitted to all framework, has applied ures to ensure a gradual transi‑ the stakeholders for consultation. to insurance and tion from Solvency I, plus revision In 2020, a holistic impact analy‑ reinsurance companies mechanisms permitting regulato‑ sis will also be conducted before since 1 January 2016. ry adjustments where necessary EIOPA finalises its opinion for the Unlike its predecessor, on the basis of past experience. European Commission. The revision scheduled for 2020 is Solvency I, Solvency II is a regarded as the main revision op‑ The points which might undergo risk-sensitive supervision portunity offered by the Directive revision vary widely. For instance, framework based on the itself. The cornerstone of this re‑ aspects currently being revised principle of valuing the vision work, in which the Bank include the assessment of the is closely involved, is the opinion long-term guarantees or the ap‑ balance sheet at market of the European Insurance and propriate capital requirements for price and the principle Occupational Pensions Authority long-term investments. The expe‑ of risk-based regulatory (EIOPA) on the revision of the rience gained by the supervisory capital. It covers a broad long-term guarantee meas‑ authorities since the entry into ures and equity risk measures. force of Solvency II will also play a range of quantitative and That opinion is to be submitted key role, for example in the con‑ qualitative requirements to the European Commission by tinuing refinement of the supervi‑ which modernise the the end of June 2020. At the sion of insurance activities under taking-up and pursuit of beginning of 2019, the European freedom to provide services, group the business of insurance Commission also asked EIOPA to supervision or prudential report‑ give a technical opinion on the ing. There are also proposals for and reinsurance. possible revision of a range of additional instruments in order to other points. That opinion was to ensure an adequate response to be supplemented by an analysis the macroprudential challenges of the potential impact of the and to create a framework for various alternative options and recovery and resolution measures approaches. In 2019, EIOPA in for the insurance sector. Although cooperation with the Bank and more than twenty points are being other national supervisory author‑ analysed in total, the aim of the ities therefore sent out a number revision is gradual evolution of the of requests for information and regulatory framework rather than impact analyses to a range of revolutionary changes.
26 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report Climate-related risks for the financial sector
Since climate change and At the end of 2018, in the con‑ recommendations addressed to the transition to a more text of its macroprudential man‑ the financial sector to encourage sustainable economy date, in order to gain a better it to take account of the threats idea in the short term of the scale and opportunities relating to cli‑ could have a considerable of the climate-related risks for the mate change and the transition impact on the economy as Belgian financial sector the Bank to a more sustainable economy. a whole, and therefore on sent financial institutions a ques‑ the financial system, too, tionnaire to determine the extent to which the institutions are al‑ The National Bank takes climate-related risks have ready taking account of climate- part in international already been a key focus related risks in their strategy and working groups of the National Bank’s their risk policy. In addition, the attention for a number Bank conducted a sectoral sur‑ However, there is no obvious vey to raise the financial sector’s way of identifying and assess‑ of years. awareness of the significance of ing the risks associated with cli‑ these risks and thus, at the same mate change (physical risks) and time, to encourage financial in‑ the transition to a more sustain‑ stitutions to monitor, assess and able economy (transition risks). manage the risks. The principal Those risks are, by definition, findings of that survey are set uncertain but they also depend out in a thematic article on cli‑ on future policy decisions, new mate-related risks and sustainable technological developments, and finance, published in the 2019 changes in the preferences and Financial Stability Report. That ar‑ behaviour of consumers and in‑ ticle also contains a number of vestors. Moreover, there are many
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 27 transmission channels which pass working on the drafting of risk and consultations with the finan‑ on these risks to numerous eco‑ indicators, methodologies and cial sector so that, together, they nomic players. The Bank takes scenarios for assessing the impact can soon gain an initial idea of an active part in several interna‑ of climate risks on financial sta‑ the main practical climate-related tional groups which are trying to bility. The European and interna‑ risks that Belgian financial institu‑ identify the various transmission tional supervisory authorities have tions face, and collect more data channels, as well as the risk in‑ also set up specific on this subject in dicators and the data needed for working groups to A minimum order to assess the the purpose of monitoring those examine the regu‑ energy efficiency scale of these risks. risks, devising scenarios and ex‑ latory initiatives requirement for A serious risk iden‑ amining whether these risks need needed in regard tified in this way is commercial and to be incorporated in the assess‑ to the supervision the potential, sud‑ ment of the macroprudential risks of banks and insur‑ residential buildings den introduction of and possibly in the capital require‑ ance companies. being imposed a minimum energy ments. For example, the Network Those groups are abruptly forms efficiency require‑ for Greening the Financial System, clearly tending to a major risk ment for commer‑ involving voluntary cooperation take account of cial and residential on the part of over fifty central not only climate risks but also all buildings. Such a requirement, banks and supervisory authorities, the risks relating to sustainabil‑ if imposed abruptly without ad‑ endeavours to support and accel‑ ity, namely the environment, so‑ ditional support measures, could erate the management of environ‑ cial issues and good governance have a significant impact on the mental and climate-related risks (Environment-Social-Governance). property sector and consequently in the financial sector, and the on the financial system, since real greening of the financial system. While awaiting the methodologies estate is used as collateral for At the same time, a joint working to be developed by the interna‑ mortgage loans, and financial in‑ group formed by the ECB and the tional working groups, the Bank stitutions also invest in the prop‑ European Systemic Risk Board is has already launched discussions erty sector.
28 The National Bank, an enterprise keeping pace with a changing world ¡ Corporate Report Cyber risks are escalating
Cyber risks to financial As a clear indication of the initiatives – both within the Bank infrastructures and the evolving challenges, the name and at international level – and of the Prudential Supervision launch joint awareness campaigns. supervision of payment of Market Infrastructures and services are requiring ever- Oversight Service has been In its 2019 Macroprudential increasing attention from changed to Supervision of Report, the Bank mentioned the National Bank. Market Infrastructures, Payment the extensive digitalisation, the Services and Cyber Risks. In ad‑ growing digital interconnection dition, the Bank set up an in‑ between various sectors of the ternal Cyber Security Committee economy, and the scale of the in 2019. The other Services re‑ resulting IT risks and cyber risks. sponsible for prudential supervi‑ Insurance and reinsurance un‑ sion are also represented on this dertakings and groups are thus Committee, plus the 2nd Line of becoming vulnerable on two Defence Department and the fronts : on the one hand, as in‑ 3rd Line of Defence (Internal Audit), stitutions they are subject to cy‑ and the Financial Markets and ber attacks and have to establish General Statistics Departments. sufficiently robust protection and The Committee’s main task is to detection systems ; they also feel ensure more efficient and struc‑ the repercussions of attacks suf‑ tured sharing of information re‑ fered by their customers, either lating to cyber security between by providing explicit cover (af‑ the various entities of the Bank. firmative cyber insurance), or by In practice, this means that the providing unintended cover (si‑ participating entities will exchange lent insurance or non-affirmative anonymised data on incidents or cyber insurance). The Bank used threats, conduct joint analyses, or‑ a questionnaire to poll the entire ganise internal training jointly, ex‑ Belgian insurance sector on these change information on regulatory two points.
NBB Report 2019 ¡ The National Bank, an enterprise keeping pace with a changing world 29 FinTech and InsurTech
Back in 2017, given the growing interest in FinTech, use a simple contact form available on the website the use of new technologies centred on the devel‑ of each of the two institutions to ask questions opment of financial processes and the associated about the regulatory framework. The aim of the questions for the sector, the Bank and the FSMA point of contact is to improve understanding of the decided to set up a FinTech single point of con‑ legislation on financial innovations and the expecta‑ tact (SPOC). Both start-ups and established firms can tions of the supervisory authorities.
In 2019, the number of approved payment institu‑ tions and electronic money institutions rose by 26 % against the previous year. In 2018, the number of Number of payment institutions (PIs) and approved institutions subject to prudential supervi‑ electronic money institutions (ELMIs) approved sion had fallen slightly, as some of them decided in Belgium to suspend their regulated activities on account of