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Operator
Good morning ladies and gentlemen and welcome to the investor and analyst conference call for HSBC Holdings PLC's interim results 2016. For your information, this conference is being recorded. At this time, I'll hand the call over to your host, Mr. Douglas Flint, Group Chairman.
Douglas Flint - Chairman
Thank you very much. Good afternoon in Hong Kong, good morning in London and welcome to the 2016 HSBC interim results call. I'm Douglas Flint, Group Chairman, and I'm speaking from London. Stuart Gulliver, the Group Chief Executive, and Iain Mackay, Group Finance Director, are in Hong Kong.
Before we start, I'd like to say a word on behalf of the Board. The first half of 2016 was characterized by spikes of uncertainty which greatly impacted business and market confidence. This was reflected in lower volumes of customer activity and higher levels of market volatility. We came through this period securely as our diversified business model and geographic profile again demonstrated resilience in difficult market conditions.
It is evident that we're entering a period of heightened uncertainty where economics risks being overshadowed by political and geopolitical events, but we're entering this environment strongly capitalized and highly liquid.
Amidst all this turbulence our strategic direction remains clear. Nothing that has happened casts doubt on the priorities we laid out just over a year ago, although in some areas events have impacted the timescales in which we can meet them. We remain well positioned for all of the major global long-term trends and the achievements of the last 12 months have only served to strengthen that position.
Earnings per share was $0.32. Our first two dividends in respect of the year of $0.20 in aggregate were in line both with our plans and the prior year. In light of the uncertain environment but recognizing the resilience of the Group's operating performance, the Board is planning on sustaining the annual dividend at its current level for the foreseeable future.
Let me now hand over to Stuart to talk about the context around our results before Iain takes a more detailed look at performance. Stuart will then give an update on the implementation of our nine strategic actions. Stuart, over to you.
Stuart Gulliver - Group Chief Executive
Thanks Douglas. Turning to slide 2, we performed reasonably well in the first half in the face of considerable uncertainty. Profits were down against a strong first half of 2015 but our highly diversified universal banking business model helped to drive growth in a number of areas. We also captured market share in many of the product categories that are central to our strategy.
Revenue was down on an adjusted basis. Global banking markets weathered a large reduction in client activity in January and February, particularly in equities and foreign exchange, but staged a partial recovery in the balance of the half.
Retail banking and wealth management was also affected by reduced client activity. This led to lower revenue in our wealth businesses, albeit against last year's strong second quarter, which was boosted by the Shanghai-Hong Kong Stock Connect. There was also revenue growth through higher lending balances in Mexico and increased customer deposits in all but one region.
Commercial banking revenue grew on the back of targeted loan growth in the UK and in Mexico and higher client balances in global liquidity and cash management which is the new name for payments and cash management.
We also continued to make material progress in cutting costs. Adjusted operating expenses were down 4%, thanks to our tight cost control and the accelerating impact of our cost savings plans. We are on track to hit the top end of our $4.5 billion to $5 billion cost savings target.
Our loan impairment charges increased, mainly in the oil and gas and metals and mining sectors and in Brazil due to weaknesses in the Brazilian economy. We however remain confident of our credit quality.
In July we were named as the world's best investment bank and the world's best bank for corporates at the Euromoney Excellence Awards. The important point here is that these awards specifically recognize the benefits of our diversified, differentiated business model and the increased collaboration between our businesses. The citation describes HSBC as one of the most joined-up firms in the industry and a growing force in areas such as high yield debt, M&A and equity capital markets. Both awards are a direct consequence of the improvements we've made over the last few years.
We completed the sale of our business in Brazil to Banco Bradesco in July. This transaction will reduce Group risk weighted assets by around $40 billion and will increase the Group's Common Equity Tier 1 ratio from 12.1% at June 30 to 12.8%.
In the first half of the year we also removed another $48 billion of risk weighted assets from the business, $33 billion of which came in the second quarter. This takes us more than 60% of the way towards our target, and actually including Brazil, more than 75% of the way towards our target, and keeps us on track to deliver the reductions we promised by the end of 2017.
Our strong capital position and stable earnings mean that we are able to retire some of the equity that we no longer require to support the business in Brazil. Having received the appropriate regulatory clearances, we will therefore execute a $2.5 billion share buyback in the second half of this year.
Our US business achieved a non-objection to the capital plan it submitted as part of this year's Federal Reserve CCAR and this included a proposed dividend payment to HSBC Holdings in 2017 which would be the first payment to the Group from our US business since 2007.
Iain will now talk you through the numbers.
Iain Mackay - Group Finance Director
Thanks Stuart. Looking quickly at some key metrics for the first half, the reported return on average ordinary shareholders' equity was 7.4%, the reported return on average tangible equity was 9.3% and on an adjusted basis we had a negative jaws of 0.5%. The movement in jaws was due to a 4.5% decline in adjusted revenue which exceeded a 4% fall in adjusted costs.
This slide takes us from reported to adjusted numbers. Reported profit before tax of $9.7 billion for the first half included a $1.2 billion gain for fair value on our own debt relating to credit spread, a $580 million gain on the disposal of our membership interest in Visa Europe, $1 billion of costs to achieve, an $800 million goodwill impairment in global private banking in Europe, and $723 million of legal settlements and provisions.
Allowing for these items leaves an adjusted profit before tax of $10.8 billion for the first half. You'll find more detail on these adjustments in the appendix. We'll focus on the adjusted numbers for the remainder of the presentation.
The next few slides will provide a rundown of our performance in the second quarter. Adjusted profit before tax was $607 million lower than the second quarter of 2015 due to lower revenue and higher loan impairment charges. Operating expenses were $584 million lower than the same period last year.
We've split out Brazil from the rest of the Group to show the impact of the sale of the business on the second quarter numbers. The biggest impact is on loan impairment charges, $414 million of which came from Brazil.
Slide 6 analyzes revenue. In principal retail banking and wealth management revenue was $422 million or 7% lower than the second quarter of 2015. This was due to a drop in wealth management revenue which contrasted with a strong performance in the second quarter of last year.
To put that into context, last year's second quarter benefited from positive market sentiment, the removal of dealing caps by Chinese regulators and large flows of funds associated with the Shanghai-Hong Kong Stock Connect. By contrast, total stock market turnover in Hong Kong was down 62% in this year's second quarter, with an associated impact on revenue.
Non-wealth management related revenue increased by 3%, largely from greater deposits in Hong Kong and the UK and from higher personal lending in Mexico.
The standout performance in the quarter came from commercial banking which continued to grow in spite of the slowdown in global trade. This was driven by higher lending and deposit balances in the UK on the back of market share gains.
Client-facing global banks and markets and balance sheet management recovered in the second quarter after a difficult start to the year. Revenue was 3% up in the first quarter. Against last year's second quarter revenue was down by $234 million or 5%. This was largely caused by a fall in equities revenue due to market volatility which reduced client activity.
There were increases in revenue in global liquidity and cash management and rates and $114 million increase in balance sheet management.
Loan impairment charges were $394 million higher than the second quarter of 2015 but stable compared to the first quarter of this year. $188 million of the increase on last year's second quarter came from Brazil due to deterioration of the economy there.
Charges in wholesale were up by $263 million, mainly in global banking and markets in the United States. The second quarter included a single significant charge on a metals and mining related exposure as well as charges in the oil and gas sector.
Following the outcome of the UK referendum there has been a period of volatility and uncertainty which is likely to continue for some time. We're actively monitoring our portfolio to quickly identify any areas of stress; however, it's still too early to tell which parts may be impacted and to what extent. In the meantime, it's worth noting that the LTV ratio on new mortgage lending in the UK was 59% compared with the average of 41% for the total mortgage portfolio. There's a detailed overview of our oil and gas, metals and mining, UK lending and mainland China exposures in the appendix.
Adjusted operating expenses excluding Brazil were $583 million or 7% lower than the second quarter of 2015 and broadly level with the first quarter of 2016. We achieved this reduction while also absorbing inflation and continue to invest in regulatory programs and compliance.
We delivered $497 million of cost savings in the second quarter, which was $132 million more than we delivered in the first. We were therefore able to achieve positive jaws in the second quarter, despite the difficult revenue environment. On a run rate basis we have now achieved more than $2 billion of cost savings, which represents nearly 40% of the overall savings required to achieve our 2017 exit rate. We remain confident of achieving this target.
Slide 9 gives you a sense of the difference that some of these cost savings are making. In the last 12 months we've reduced the number of manual payments by 64%, increased the number of customers using our digital channels by 6%, shortened average client onboarding time by 30% and reduced the number of branches in our six largest markets by 7%.
Slide 10 breaks down adjusted profit for the first half of the year by global business and geography. These profits were achieved in challenging market conditions and relative to a strong first half of 2015. The main business drivers were lower revenue and higher loan impairment charges, which exceeded the 4% reduction in costs.
Turning to capital, the Group's Common Equity Tier 1 ratio was 12.1% on June 30 compared with 11.9% at the end of 2015. Roughly half of this increase came from profit generation, the rest came from a reduction in risk weighted assets, partially offset by movements in foreign currency translation differences.
Total risk weighted assets decreased by $21 billion in the first half of the year. This was caused by $48 billion of reductions due to RWA initiatives and $9 billion of foreign exchange movements, partially offset by a $15 billion increase from book quality and a $19 billion increase in book size.
We recognized $33 billion of risk weighted asset reductions in the second quarter, bringing total reductions for 2016 so far to $48 billion. Risk weighted asset reductions in the first half included $23 billion from global banking and markets, $12 billion from CML run-off portfolios and $11 billion from commercial banking. These reductions include global banking and markets legacy reductions, better linking of collateral and guarantees to facilities, client facility reductions and moving exposures from a standardized to an IRB approach.
The total reduction since the start of 2015 now stands at $172 billion, around 55% of which came from global banking and markets. This takes us more than 60% of the way towards our target. These numbers exclude the reduction in risk weighted assets from the sale of Brazil as it closed after the end of the half. That will remove an additional $40 billion of risk weighted assets. We remain on track to hit our risk weighted assets reduction target.
I'll now hand back to Stuart.
Stuart Gulliver - Group Chief Executive
Thanks. It's been just over a year since we presented our actions to improve returns and get the most from our international network. For the rest of this presentation we'll bring you up to date with what we've done and how far we've come.
Now we showed you a version of slide 14 at the start of our investor update in June 2015 and these are the three core strengths that anchor the investment case for owning HSBC. We continue to build on these intrinsic strengths for our strategic actions and they continue to underpin the strategy of the firm. We've maintained a highly diversified Group with stable earnings built on prudent low-risk lending, and we've continued to strengthen our capital ratio in the last 12 months.
Slide 15 shows the progress we've made in implementing our actions in the first half. On the right-hand side we've added a status update column which tells you which actions are due to be completed on time. As you've already heard, our risk weighted asset reduction program and cost savings programs are both well on track. We've made further progress on both in the first half of the year and we're confident of hitting our targets.
Mexico is also on track. We've made good progress rebuilding the business, increasing revenue, controlling costs and recapturing market share. Our shares of the Mexican payroll and personal loans markets are up significantly and we've increased volumes and market share in both cards and mortgages. We also have double-digit revenue increases from retail banking and wealth management and commercial banking in Mexico.
Our pivot to Asia is moving ahead, despite the difficulty in reallocating the risk weighted assets that we've saved. The proportion of Group revenue that Asia provides has actually continued to rise and we've made market share gains as a consequence of the investment in our Asia businesses.
Having said that, we've not reallocated assets as fast as we wanted, due to the state of the global economy, but we continue to develop our Asia businesses and to build on our existing operations. But we're not going to accelerate this program until it is in the interests of shareholders to do so.
We also remain on track to set up the UK ring-fenced bank by 2018 and we continue to implement global standards throughout HSBC.
Some of our other actions are taking longer to complete. The US business isn't performing as well as we wanted, due mainly to changes in the external environment. Revenue was up in the principal businesses but not by as much as we hoped, and the credit environment continues to be difficult, especially in oil and gas. Given these circumstances, it's unlikely that the US business will hit its targeted return on risk weighted assets by the end of 2017.
That said, we have made good progress in reducing risk weighted assets in the US. We received a no objection from the Federal Reserve to the capital plan submitted through the CCAR process. This included a proposal to pay a dividend from the US business back to the Group in 2017. This is a consequence of the progress we've made in winding down the legacy CML portfolio over the last 12 months and if it goes ahead it will be the first dividend from the US business since 2007.
Now the slowdown in global trade has hampered our ability to deliver growth above GDP from our international network. However, revenue from our transaction banking is down just 1% on the same period as last year, despite a drop in global trade volumes of more than 8%. This reflects the market share gains we've made since last June and it's a good indicator of the potential of the business when trade volumes start to recover.
And we're also behind on our revenue target for RMB internationalization, again due to external conditions. We still expect to hit our revenue target but later than originally planned.
Slide 16 shows we've built up a healthy capital position over the last five years. We've done that through a combination of strong profit generation, a reduction in low return activities and selling businesses that don't deliver value for the Group. We now have a Common Equity Tier 1 ratio of 12.1% which would rise to 12.8% excluding Brazil. This is well within our 12% to 13% target range.
In the current environment there are limited options to reinvest the proceeds from the Brazil transaction into higher return opportunities, and we are confident of our ability to sustain the dividend. At the same time, the sale of the business in Brazil means we no longer need all the equity that supported it. So we therefore have applied for, and received permission, for a $2.5 billion share buyback following the Brazil transaction, which we'll execute in the remainder of this year.
We intend to carry out further share buybacks as and when appropriate, subject to the execution of targeted capital actions and of course regulatory approval.
In summary, and as slide 17 shows, we've made a lot of progress since last June. The revenue environment continues to be difficult but we're delivering on costs and achieved positive jaws in the second quarter. We've maintained our leadership position in transaction banking and we've captured market share in some of our key Asian markets and businesses.
We sold the business in Brazil and intend to buy back shares to retire some of the equity that supported that business. The Fed has no current objection to the US business paying capital back to the Group in 2017, which includes the proceeds of the sale of the US credit card business and the upstate New York branches in 2012.
We also continue to generate capital. Now the economic and geopolitical environment remains uncertain. Negative rates and the likely deferral of interest rate rises put increasing stress on banks. Since 2007 we've seen our net interest margins contract from 2.9% to 1.8% which we largely compensated for with around a 33% growth in interest-earning assets.
We continue to see higher margin business roll off with heightened competition for new lending, and in light of this we will not now hit our return on equity target of more than 10% by the end of 2017. However, the above 10% target remains both intact and appropriate.
We have confidence in our ability to sustain the annual dividend at current levels through the long-term earnings capacity of the business and our ability to generate capital. There is much obviously still to do but we are making progress in all of the areas within our control. In the meantime, our balanced and diversified business model, strong liquidity and strict cost management make us highly resilient in the current operating environment.
Stuart Gulliver - Group Chief Executive
We'll now take questions. The Operator will explain the procedure and introduce the first question. Operator?
Operator
Thank you Mr. Gulliver. (Operator Instructions). Alastair Ryan, Bank of America.
Alastair Ryan - Analyst
Thank you. Good morning, good afternoon. I'll be greedy with two big questions if I may. First, loan growth in the first half, as you alluded to Stuart, was disappointing; it was down a bit. Net of continued run-off in GBM do you think that loans will actually grow over the next six to nine months or the environment doesn't allow for that is the first question.
And then secondly, on the capital returns, obviously the US is a very big number down the road. So you've characterized the share buyback today as a discrete thing relative to Brazil. Clearly the US, the capital trap there has been a very big drag on Group cash flows for the last several years, could I try and drill you on the quantity of dividends you might get out of that? You mentioned the disposals but I'd imagine you wouldn't have asked for the ability to pay all of that out upfront but that you'd have started small and be scaling that later, but it could be quite material free cash flow for the Group over time. Thank you.
Stuart Gulliver - Group Chief Executive
So on the loan growth, one of the ways to look at it is the AD ratio is one of the lowest it's been. So we've got an AD ratio kind of sitting at more or less 68% or thereabouts. And we obviously have got within the advances several moving parts. We're also continuing to run down, as you say, the lower returning stuff in GBM; we're considering to dispose of pieces in the CML portfolio. And opportunities to get accretive loans on the book have been hard to come by.
My preference in terms of correcting the AD ratio back to above 70% is to increase the advances rather than turn deposits away. But it's very hard for me to categorically sit here and say that we will see that outcome. What I would say to you is that CMB, RBWM and GBM are all basically focused on trying to win new business. So it is possible that in the second half we'll see net loan growth because that is what we're trying to do. Actually commercial banking has been successful in doing it and the positive growth in RBWM actually came from lending because it was the wealth piece that was affected by the tough stock markets of the first two months.
So that's what we're trying to do and we're trying to get the AD ratio back up to 70% by growing the A as opposed to some kind of complexity around pushing deposits away. We continue to grow deposits; we continue to basically see a flight to quality. And therefore it's for us to kind of push on the advances side. But as I say, there are two or three, as you know, moving parts in terms of RWA reductions, which clearly means that we're exiting a bunch of lending, the CML disposals et cetera.
On the capital returns, I'll start and I'll let Iain talk a little bit more. One of the ways to think about what's been in the US is the proceeds of the businesses that we sold in 2012, 2013 were kept in the United States. So the credit card business and the upstate New York branches, the proceeds of those were left in the United States. And this would be the first time that we get some of that released.
And just as we said about Brazil that actually if we don't have the business we don't need the shares that supported the business, you can imagine that some of that logic is sitting behind our thinking in terms of the fact that there is shares that supported that credit card business and shares that supported those upstate New York branches which equally aren't therefore needed anymore.
Now you'd be wrong to assume that it's the full amount that's sitting in there that will be coming out and I'd like Iain to in a very mystical way describe without giving any numbers what we think may be coming to us in the first quarter.
Iain Mackay - Group Finance Director
So Alastair, we've talked on these calls in the past about the quantum of capital that's possibly been trapped in the US over the last few years and Stuart's informed the factors that contribute to that. As we put the capital plan together as part of CCAR this year we had, as you would expect, quite detailed conversations with the Federal Reserve Board.
There are two windows for capital planning, the next four quarters and then the five quarters that come after that. So there's a nine-quarter planning scenario within the US capital plans for CCAR. And in that conversation what the Federal Reserve recommended we do is put a substantial dividend in the second five-quarter window, so 2017, and we've popped that into the first half of 2017. And it is a substantial number.
As Stuart says, it's not all of the capital that would be released from those dispositions but it's a big number that certainly, were we to again get approval from the Federal Reserve in next year's CCAR, conceivably could lead -- could lead, so a bit of conditionally around this, but could lead to another buyback from an HSBC perspective. So it is a substantial proportion that we are talking about.
Alastair Ryan - Analyst
Thank you. Very helpful.
Stuart Gulliver - Group Chief Executive
Thanks Alastair. Next please?
Operator
Rohith Chandra-Rajan, Barclays.
Rohith Chandra-Rajan - Analyst
Morning. Thanks. I've got a couple as well please. The first one, just returning to capital return, I guess from a slightly different angle. You just talked about the shares no longer being needed to support businesses that you no longer own, but thinking about it from a Group capital perspective, I guess post the Brazil sale and the share buyback CET1 looks like it would be around 12.5%, which is the middle of your -- sorry?
Iain Mackay - Group Finance Director
12.6%.
Rohith Chandra-Rajan - Analyst
12.6%, so the middle of the target range. I'm just wondering how we should -- is that at a capital level above which we should think that share buybacks will be considered in the future, so surplus capital above that level? Or is that being too specific about the CET1 ratio? So that was the first question.
And the second one, just in terms of the ROE outlook, 10% not achievable in the current environment. I'm just wondering what you think is achievable in the current operating environment and to what degree there might be additional cost reductions. You've already talked about being at the top end of the $4.5 billion to $5 billion range. I'm just wondering to what degree near or medium term there might be scope to exceed that. Thanks.
Stuart Gulliver - Group Chief Executive
Iain and I will both interject at points in answering your questions. So there isn't room to increase the cost program beyond the $5 billion between now and the end of 2017, which is 18 months. And we'll deliver the top end of that $4.5 billion to $5 billion. But obviously you would expect if there is not a pick-up in revenue we would need to look at further cost actions and we'd need to look at capital actions in order to get to that 10%. So there's a path dependency here; it's either revenue or it's capital or it's costs, and we're fully aware of how the math works. But we'll get the $4.5 billion to $5 billion out.
If we were to accelerate more now we'll damage our compliance, global standards, our customer service, and actually ultimately therefore our revenue. So the $4.5 billion to $5 billion we'll deliver, we'll deliver the top end of that, and then my expectation is we will continue into 2018 and 2019 with a further program of cost management.
Iain, to talk broadly about the range of Core Equity Tier 1?
Iain Mackay - Group Finance Director
Yes. Again, we're already sitting in that 12% to 13% range. I think we've always talked about feeling more comfortable in the upper half of that range. The Brazilian transaction after the effect of this buyback will put us in the upper half of that range and we have every expectation we'll continue to accrete capital from operations and ongoing capital actions as we work through the remainder of this year and into next year.
I think, as you are well aware, there are still a number of uncertainties out there with respect to regulatory capital -- regulatory capital measurement, notwithstanding the broader base of uncertainty with respect to geopolitics and how it might affect the economy. But I think where we find ourselves post-buyback is a good place to be. I think it also clearly reflects the fact that the PRA has given us approval to do this buyback. It would suggest that the PRA has some confidence in terms of the strength of our capital ratios and the ability to meet capital requirements and generate capital from operations.
So it's sitting around 12.5%, which is really the level at which we modeled incidentally the 10% return on equity from an input equity perspective, is a good place to be. If we find ourselves higher than that as we work through the remainder of this year we won't be particularly uncomfortable about it.
What may inform future buybacks yes will be our capital sufficiency and meeting regulatory capital requirements, but it will also be very closely aligned to specific capital actions that we take that mean that we are carrying capital that is no longer necessary to support the businesses that it underpinned in the first place.
So there is absolutely an intention to be in a position to do further buybacks but it will be very much linked to specific capital actions that we will continue to undertake within the business.
Rohith Chandra-Rajan - Analyst
Okay. Thank you.
Stuart Gulliver - Group Chief Executive
Thank you.
Operator
Raul Sinha, JPMorgan.
Raul Sinha - Analyst
Morning, afternoon gents. Can I maybe have two as well, just the first one following up on divvies. Am I reading too much into it but if I look at the $2.5 billion buyback that you've talked about that's broadly similar to the scrip element of your overall dividend. And so this is one of the things that you wanted to do in the past. Should we think about potentially the dividend as you're effectively adjusting it to make it a full cash dividend rather than have a substantial scrip element that leads to a rise in the share count? So the first question is, are you looking to manage the share count impact of the scrip through the buyback? Is that an intention at all?
The second one I have is on interest rate gearing. On page 80 you've given us the disclosure on the various moving parts across different blocks. The exposure to the sterling block has come down over the last 18 months and so I just wanted to get your thoughts on what is driving that negative impact being lower now at $442 million compared to what it was before in the last two periods, and maybe if you could touch upon what mitigating actions you could take against the (inaudible) that would be useful. Thank you.
Iain Mackay - Group Finance Director
Okay. On the buyback, it is not -- it is very directly linked to Brazil. It is not -- and you shouldn't read too much into this -- about specifically trying to manage down the impact of the scrip. Clearly one of the factors that we are focused on is the share count. Obviously in terms of the long-term sustainability of our dividend is to a not insignificant degree informed by managing dilution that comes from the scrip. But to be very, very clear, this buyback relates to the Brazilian transaction and if that then over time allows us through other capital actions to execute further buybacks that manage down the impact of dilution, then we'll be very happy to do that, and it is absolutely a goal for the organization.
But don't link this directly or indirectly in any way to the scrip, and we'll certainly keep you informed as time goes forward as to any actions we may or may not take with respect to scrip.
In terms of NII sensitivity, specifically on the sterling block, I think there's not really a great deal. What we've very much done within sterling, both from a capital management and more broadly the balance sheet, is where there's been an opportunity to hedge exposures within the sterling block we have taken those opportunities progressively over the course of the last 18 to 24 months and we'll continue to do so. And I think that's probably the main impact that you're seeing of slightly less influence coming through the sterling block from a rate sensitivity standpoint.
Stuart Gulliver - Group Chief Executive
I also think that what you're looking at as the position matures, because if you look at what you're examining, basically January to December this year you have this [135] impact if rates went up, which obviously is not what we're expecting. And then actually in July 2016 to June 2017, so looking forward, the impact is less. That actually suggests to me there's simply a maturity of the position, nothing more remarkable than that quite honestly.
Raul Sinha - Analyst
Okay. And in terms of mitigating actions, what actions could you take to perhaps reprice some of the business in the UK?
Stuart Gulliver - Group Chief Executive
We think that the impact of a 25 basis point cut will be about $100 million to the net interest margin per annum.
Iain Mackay - Group Finance Director
That's for the remainder of this year Stuart, so per half year basically.
Stuart Gulliver - Group Chief Executive
Yes. So about $200 million over each year, which is obviously the impact of further inability to price deposits. It's a competitive landscape. It really depends on effectively what margins are across the industry. There aren't any magic buttons on this. I guess if this is code for would we charge people to put deposits with us, we already have with our business clients written to them in terms of foreign currency earlier in the year to indicate where -- a non-sterling where interest rates were to go negative we would pass on the cost of that to business accounts and to corporates. In foreign currency we're already doing that with banks and non-bank financial institutions. I guess that protocol would read across to the UK if sterling rates became negative.
Again for foreign currency we have not done it with personal clients and we have not at the moment even contemplated that for the UK. Given that Governor Carney has indicated on a number of occasions that he is not in favor of negative interest rates, and obviously it remains to be seen what action he takes tomorrow, we have not reached the stage which I think RBS have of writing out to people on this.
But as I say, the expectation would be if you've got negative interest rates, yes we would apply it to companies and we'd apply it immediately to banks and non-bank financial institutions.
So if that's kind of what you're asking within that, yes we would do that, but I don't think there is going to be a repricing from a credit spread point of view.
Raul Sinha - Analyst
Okay. Thanks very much.
Stuart Gulliver - Group Chief Executive
Thank you.
Operator
Michael Helsby, Bank of America.
Michael Helsby - Analyst
Thank you. Just on the dividend. So obviously you've dropped the prospective dividend guidance and I was just wondering if you could talk about maybe joining it all up. Because you're left in an unusual situation where obviously your dividend -- your ordinary dividend is barely covered at the Group level yet your Core Tier 1, as you say, is going to be at the top end of your range and you've got these discrete buckets of capital, the US being one, maybe things in China in the future. So how should we think about that? I'm just conscious that clearly there's an expectation in the market that you're going to cut your ordinary dividend at some point in the future so I was just wondering how we should think about that and how you think about the cash flows going forward? So that would be question one.
And then just on the ROE, I appreciate -- and thank you for the commentary -- that you don't see it as being achievable next year. Can I draw you on whether you think a 10% return on tangible equity would be achievable next year? Thank you.
Iain Mackay - Group Finance Director
On divvies Michael, I would take our guidance literally. Our focus is on sustaining the dividends at the current level. Your point on coverage is taken and well understood; we clearly would be paying out in 2016 and 2017 at a higher rate than we have historically. That is influenced by a couple of factors. One, we've obviously got the impact of the Brazilian accounting in the second half of the year that will come through. We have the impact of about $1 billion so far year to date of our cost to achieve, which includes restructuring and other costs, to ensure that we deliver on risk weighted asset reduction, cost savings, overall improvements in the operating efficiency of the firm.
We continue to have obviously the impact of a fairly lofty bank levy coming through and impacting holding company cash flows as well as higher tax rates in the United Kingdom. So as you can imagine, there are lots and lots of moving parts. But when we look at the profit generating capability of the business, the ability of our subsidiaries to continue to dividend the parent substantial cash flow, that supports our dividend, albeit at higher payout ratios.
Now why would we be comfortable with higher payout ratios? And it really goes to some of Stuart's earlier comments that the ability to take capital and reinvest it profitably in growth opportunities presently is somewhat muted, as I think we all see in the various markets in which we operate around the world. And consequently, because we're sitting at the higher end of the Common Equity Tier 1 ratio that we've got, that we've targeted and that's certainly based on approvals received, it would suggest that our regulators are happy with how we're progressing in that regard.
It seems not the best use of the shareholders' resources to keep it on our balance sheet but actually to put it back in their pockets in the form of dividends and when circumstances allow in the form of buybacks. And that is where we're headed right now. So I would take the guidance on divvies as literally as we have put it to you.
Stuart Gulliver - Group Chief Executive
Just one small point I'd add as well Michael, our PBT, our profit before tax, is a lot less volatile than others. So if you go back over 10, 15 years and look at what we make each year and then compare it to some other banks that have struggled to keep a dividend -- actually to keep any dividend, you'll see not only do we have a large -- all the things Iain said, and we've got big distributable reserves and so on, but actually we're a lot less volatile. It's because we're a global universal bank and very diversified by geography and customer group, which of course was seen as a big negative but actually is the reason why we've got the numbers we have. It also gives us confidence that, if you like, we can distribute more than others would for a couple of years.
Iain Mackay - Group Finance Director
And Michael, going to your return on tangible equity question, certainly when you look at some of the factors that impact return on equity, obviously the lower revenues, higher loan impairment charges in the current period impact the return on equity. When you then look at the cost to achieve, we've got significant cost to achieve coming through in each of 2015, 2016 and 2017, and as they start to fall away and as hopefully we start to see a slightly lower charge coming through on the bank levy for example -- though interestingly that's largely offset by the increased surcharge on bank taxes in the United Kingdom -- those factors absolutely contribute to moving the ROE in the right direction.
In terms of ROTE versus ROE, we certainly start getting a little bit closer to the numbers that we'd like in 2018 and 2019. We'll still fall a little bit short of our return on tangible equity of 10% in 2017. We will not make 10% return on tangible equity in 2017, although we're certainly getting closer to 10% by a different measure. But we don't really want to game you on the measure here.
Michael Helsby - Analyst
Thank you. That's very helpful. Thank you.
Stuart Gulliver - Group Chief Executive
Thanks Michael.
Operator
Chirantan Barua, Bernstein.
Chirantan Barua - Analyst
Morning guys. Most of my questions are answered. Just a quick one Iain on risk. The early delinquencies, especially one plus, is there an increase in June? It would be great if you could just give us some color on where those delinquencies are coming from? I think it's on page 7 of the presentation. The bars, $8 billion to $9.1 billion (multiple speakers).
Iain Mackay - Group Finance Director
Yes, absolutely, got you. No, this is in the US, principally in the corporate and commercial sector, and that really is just demonstrating some 30-day volatility that we see coming through short-term customer behavior. But that is influenced by a pretty small number of individual customers in the corporate sector in the US.
Chirantan Barua - Analyst
Got it. Thanks.
Stuart Gulliver - Group Chief Executive
Okay.
Operator
David Lock, Deutsche Bank.
David Lock - Analyst
Morning everyone. Three questions for me please. Firstly on risk weights, the risk weighting in the retail banking division looks like it fell about 2% quarter on quarter. I appreciate some of that is going to be driven by the US CML run-off but it looks like there was quite a big drop in Europe as well. So I'm just wondering if you could comment on what exactly is driving that and whether you see any risk around the low mortgage risk rate you have for the UK, which I think was about 5% at this quarter?
Second question is just on BSM. I think on the last call you gave an expectation of about $2.5 billion for this year. Clearly you're ahead of that in the first half so I just wondered if that was still the expectation for this year?
And then finally on cost of funds, I'm a little bit surprised to see that cost of funds is actually slightly up half on half from about [97 to 101]. I'm wondering if maybe an element of that was (inaudible) but if you could call out what was the driver of that, because obviously in the interest rate environment I'd have thought it would be falling not rising. Thank you very much.
Stuart Gulliver - Group Chief Executive
Thanks. So some of the cost of funds is TLAC.
Iain Mackay - Group Finance Director
Yes it's TLAC [81], so as you'll have noticed we did a significant amount of (multiple speakers).
Stuart Gulliver - Group Chief Executive
About [18.5] of TLAC and about [3] of non-capital in the first half.
Iain Mackay - Group Finance Director
Non-core capital.
Stuart Gulliver - Group Chief Executive
(Inaudible). BSM, $2.4 billion to $2.8 billion.
Iain Mackay - Group Finance Director
And risk weighted asset density in retail bank wealth management, you hit on the point which is continued significant reduction in the run-off CML portfolio in the US where in the first half we completed dispositions about GBP4.7 billion, GBP4.8 billion, and then in July we completed about another billion of dispositions from the same portfolio. But that's obviously not reflected in those numbers. There's nothing else of particular note with retail wealth -- retail-bank wealth management from an RWA density perspective.
David Lock - Analyst
Okay. And so what was the driver of the European [board]? It's just frankly quality of book, or, what do you think it was in the (multiple speakers)?
Iain Mackay - Group Finance Director
There is nothing significant within that. Certainly from an RWA-density perspective the book came down slightly in size, but that doesn't impact RWA density. Nothing notable.
David Lock - Analyst
Okay. Thank you very much.
Stuart Gulliver - Group Chief Executive
Thank you.
Operator
Jason Napier, UBS.
Jason Napier - Analyst
Hi. Good afternoon and good morning. Two please.
The first one, I appreciate the commentary in Douglas' statement around the necessity of trying to align public policy and regulatory policy. But I think while we probably all agree with that there's obviously the implication in there that your own QIS work signifies potentially very material changes there.
It's obviously a good sign that the PRA is allowing the buyback and your ratios are building in a very promising fashion. But I just wonder whether, given that there probably is material information inherent in this, whether you might give us a sense as to the distribution of QIS outcomes that you arrived at, what the bigger issues are.
And, perhaps more specifically, if you could talk about what the discussion paper on UK mortgages and yesterday's release on PPI might mean for capital. Believe it or not, that's one question.
And then the second, just point of detail, I wonder whether you wouldn't mind giving us the legacy credit RWA number for GBM, just so we can see what's happening to the RWA deployment in that division in the second quarter. I think in the first quarter there was GBP25 billion of RWA left. I just wonder how that's evolved in the second?
Thank you.
Iain Mackay - Group Finance Director
Okay. So, in terms of revisions to Basel III, you'll have seen the same sort of commentaries that we have seen in terms of the governors and heads of supervision making quite strong statements around not having a significant impact on the overall capital requirements for the sector. We're obviously still quite a few months and a great deal of work away from having any final, calibrated, outcomes with respect to either credit risk or operational risk.
As you've probably also seen, the impact that the industry has estimated from a QIS perspective, particularly on credit risk, is very, very significant whether you viewed it from a UK perspective, a European perspective or a global perspective.
We obviously contribute to that. And I think it would be fair to say that across certainly operational risk and credit risk there is potential for where the guidance upon which consultation was sought implemented as stands today it would be very significant for the industry. And it would be significant for HSBC.
However, given our capital strength, given the number of capital levers that we have available to us, we have a resilience and a propensity to deal with this probably in a shorter timeframe than the wider industry would take. But, to be clear, were things implemented as it is today it would be very, very -- it would be very significant for the industry.
Going beyond that, you've read the various numbers that are out there and there's not much more that I can particularly add to that debate at this point.
From a PPI Plevin perspective, obviously we got another consultation from the FCA yesterday. That will run through until October 11, I believe it is. We'll obviously participate in that consultation.
I think our response to this consultation and how we reflect any possible impact in our numbers will be the same as it was in the last consultation. And that was that we took a view of the likely impact of PPI closing out in April of 2018. We'll now roll that forward to 2019 once we've understood exactly what it is that we are consulting on. And if that reveals that there's any increased requirement for remediation to customers necessary we'll make provision for that in the second half of the year.
But I think it's -- it will absolutely be informed with every provision we've made for PPI, which is incoming claims, the rate of uphold against those claims and the payment against those claims. And that is monitored operationally within our UK business on a day-by-day, week-by-week, basis.
You probably noticed that there wasn't a particularly material impact from our update for the earlier consultation. We'll -- and you've seen really nothing come through the last couple of quarters on that one. As and when we've worked through the detail you'll obviously see it in our financials; difficult to say until we've worked through the detail.
In terms of RWA density, from a legacy perspective within global bank and markets, the overall reported RWAs of GBP437 billion decreased by more than GBP3.5 billion by the -- but from the end of the year and a number of factors come in to that.
Reduction is about GBP27 billion. About GBP7 billion came in terms of legacy disposals from an RWA perspective. So, if you go back to the number you previously had of about GBP25 billion, GBP26 billion, there's about GBP7 billion has now come off that in terms of activities in the first half of the year. So, that's what's going on in legacy credit.
Jason Napier - Analyst
Thank you. And, sorry, just you -- you have one of the lower RWA densities in the UK mortgages. Do you have any comments on the -- on that discussion paper in particular?
Iain Mackay - Group Finance Director
I think that's probably got something to do with the quality of the UK mortgage book. I mean, if you go to -- well, we can get into this a little bit, because no doubt you'll want to ask a few questions about Brexit at some point and what that means for credit quality.
But if you look at buy-to-let exposures in the UK, for example, there's only 3% of our portfolio is buy-to-let exposure. When you look at geographical distribution London's about 28% of that and 86% of our London exposure has an LTV of less than 60%. If you look at the southeast of England, 13%, now that represents about 13% of our UK mortgages and 80% of that has an exposure of less than 60%. 2% of HSBC exposures have LTVs of greater than 85%.
So, I could keep reeling off these statistics, but what we've got is a conservatively underwritten, well-distributed book of business within the United Kingdom, where credit quality, certainly through the global financial crisis and today, remains very consistent and very stable.
And when you think about how our advanced models are built it's all about PDs, LGDs and EADs. And I think some of the data I've just provided you with would inform why we've got a relatively low RWA density in our UK retail mortgage.
Jason Napier - Analyst
Thanks very much.
Stuart Gulliver - Group Chief Executive
Thank you.
Iain Mackay - Group Finance Director
Okay, thank you.
Operator
Chris Manners, Morgan Stanley.
Chris Manners - Analyst
Good morning, guys.
(Multiple speakers)
Chris Manners - Analyst
Two questions, if I may. The first one was about BoCom. And I can see that the headroom of the BIU above the carrying value has decreased to about GBP800 million; just maybe if you could give us a few thoughts on that. And how close we are to essentially de-recognizing those earnings in the income statement and how we should think about that.
And the second question was actually just on UK and asset quality and also a little bit in terms of on your customer sentiment. What do you think about demand for credit in the UK? And I suppose also, I know this question was asked in brief, but is there any chance of firming asset margins in the UK? One of your peers was saying that banks should be more thoughtful about pricing for risk and that could give you a little bit of a bump to the margin in the low-rate environment.
Thanks.
Iain Mackay - Group Finance Director
Yes. On BoCom, Chris, main drivers of that reduction is payment of the annual dividend by BoCom. So, the way the accounting goes, is that the dividend flows through that discounted cash-flow model and the book-value impact. And the other main driver there is foreign exchange.
What does this really mean? It means we're several hundred million dollars closer to impairment than we were when we reported these numbers out to you at the first quarter. Our approach, and we've got disclosures obviously on this in the interim report in some detail, our approach to evaluating BoCom and the impairment -- the potential for impairment on BoCom has not changed in any significant regard. And the accounting treatment and the capital impact of BoCom has not changed either.
So, there are really -- other than some FX impact and receipt of our dividend there's nothing else to report in the BoCom front.
Stuart Gulliver - Group Chief Executive
So, in terms of credit, so we had a slowdown in SME activity basically kicking off from early June, which is still reasonably slow in terms of applications for new financing. But since the referendum we've had about 1100 -- actually precisely 1142 loans have been drawn down for customers in business banking, which is worth cumulatively about GBP150 million.
MME stuff, again, quite slow, so people have, I think, postponed getting financing for OpEx. But I imagine that come September we'll see that pick up again, because obviously the process of negotiation is going to take a number of years. So, I don't think that that OpEx will be postponed.
The large companies haven't missed a beat, because they're multinational and they're in many countries and, therefore, they have continued to operate at the previous levels.
In mortgages we've approved about 11,500 mortgages post-referendum, which is a total of about GBP2 billion, post the referendum. Actually, to be honest with you, the slowdown in UK mortgages was more pronounced around the stamp-duty increase, i.e. there was a lot in the first quarter that then fell off post-April, than anything we've honestly seen around the impact of the referendum.
So, there really isn't anything particularly pronounced other than, as I say, a slowdown in the SME business-banking sector.
I don't myself believe that there will be any opportunities to change credit-spread pricing. I think that, notwithstanding the often view that the UK market is not competitive, it's actually extremely competitive. And I would be surprised if actually credit spreads did move out, unless we're talking about some unforeseen event that results in credit spreads more generally for the UK moving out which, again, we're not building into any of our own planning assumptions at this moment.
Chris Manners - Analyst
Thank you.
Stuart Gulliver - Group Chief Executive
Thanks.
Operator
Tom Rayner, Exane.
Tom Rayner - Analyst
Yes, sirs. Good morning, afternoon, everybody.
Can I just ask you about your statement on regulatory policy aligning with public policy at the bottom of page 3? Some of the statements and, Iain, you have referred to these already, are quite strong; increased capital requirements would have a major impact on the availability of credit and go against the public-policy focus on boosting growth. And also, as you've said, you welcomed statements from the G20 and others that there'll be no broad-based increase in capital requirements.
So, on the back of those comments, I've got a couple of questions. Firstly, when you talk about 12.5% as the right sort of equity Tier 1 ratio when to consider buybacks, et cetera, are you now assuming there will be no impact on you from Basel IV, IFRS 9 and other things outstanding?
And my second question is to what extent are these comments part of the broader, industry-wide lobbying exercise, I guess, trying to encourage Basel maybe to look at the reality of the situation and maybe water down some of the proposals? Is that me dreaming again? Or is there some substance to that idea?
Thank you.
Douglas Flint - Chairman
So, (multiple speakers). Yes, Tom, Douglas. I wouldn't call it part of a lobbying exercise. I mean, a consultation process means two sides talk to each other. And I think that the proposals which were really all around risk sensitivity and then into operational risk and a number of other areas, the aggregate impact if you took the top end of the ranges, came to quite significant increases in capital.
Now, it's been said for some time by the regulatory community it was not the intention to have a broad-based capital increase. There was an expectation that outliers, those that had a very particularly low risk-weighted asset density, might find themselves more hit than others. But for the broad part of the industry there's -- it's been fairly consistent.
What I was trying to do in the statement is say that this consultation is underway, clearly is a significant matter to be addressed, resolved, in the second half of the year. And I think we are basing our future projections on the very clear statements that have been made by the central-bank governors and the G20 finance ministers as well as the Financial Stability Board and many elements of the regulatory community saying -- look, this is not designed to have a broad-based increase in capital.
So, what I was trying to do is say it's important. We're working on that basis and clearly it's important that that is delivered, because in a period of economic uncertainty any constraint on the ability of the industry to generate credit would lean against public policy objectives in terms of trying to stimulate better growth.
And so, it's not part of the lobby effort. It's really just pointing out to an important event in the second half of the year and to draw attention to the comfort that's being given by the G20 community.
Stuart Gulliver - Group Chief Executive
I think it's also --
Tom Rayner - Analyst
Okay, thank you.
Stuart Gulliver - Group Chief Executive
-- Tom, in terms of what do -- what are we assuming about our capital ratio, I turn it slightly around the other way. So, post the sale of Brazil, we're 12.8%. After this buyback we're 12.6%. And obviously to do the buyback the PRA had to approve the buyback. So, our main regulator obviously had to think about some of the things that you've just outlined in coming to the decision to give us that approval.
Tom Rayner - Analyst
I -- yes, I do understand. I understand that. But I guess that your main regulator, the PRA, will have to eventually take whatever the final Basel decisions are. I mean, it would be quite a step I think for a national regulator in the UK to actually unilaterally say -- this is -- well, we can all have our own view on it. But this is a silly thing to do, therefore we're not going to --
Stuart Gulliver - Group Chief Executive
No, no, I'm not saying that. Tom, we're not -- no, Tom, I'm not saying that the PRA is rejecting Basel IV. What I'm saying is the PRA has looked at our five-year capital plan and has decided that they are comfortable with us, having sold Brazil, retiring half the shares that supported Brazil knowing all that they know, you know and we know, about the likely regulatory change.
Iain Mackay - Group Finance Director
And I think what goes beyond this, Tom --
Stuart Gulliver - Group Chief Executive
That's all I'm saying, yes?
Iain Mackay - Group Finance Director
-- there's a point in time versus the propensity to generate capital and meet regulatory capital requirements over time. What we're not saying is that there is no impact from any refinements to the Basel regime at this point, because nobody knows.
Stuart Gulliver - Group Chief Executive
We don't know what they are.
Iain Mackay - Group Finance Director
And so I think, to Douglas' point, you've got to place some faith and reliance on the various statements coming from central-bank governors and heads of supervision. But, by the same token, as I'm sure many of you have, if you have conversations with some of those same heads of supervision they have a very, very significant piece of work to do over the next six months to try and come to an agreement as to what the Basel framework will look like, going forward. And it is a substantial piece of work.
So, no, we're not saying there is no impact here. But we are simply taking all the factors that are put in front of us from various sources, as clearly are our principle regulators, and that's informing decision-making.
Tom Rayner - Analyst
Okay. All right. Thank you very much for that.
Operator
Stephen Andrews, Deutsche Bank.
Stephen Andrews - Analyst
Yes. Hi.
I just wanted to come back to the question of capital trapped in North America. And just can you -- get a bit more guidance in terms of exactly how much capital you do have in North America, because obviously from the operating income in the accounts we can see Canada Finance Corporation and the Bank. When you talk about the proceeds from the card sale and the branch sale being held in North America is that being held at the North American Holdings Company level so we should -- to get a rough idea?
Stuart Gulliver - Group Chief Executive
It is, yes.
Stephen Andrews - Analyst
Okay. So, then in terms of how much capital is held?
Iain Mackay - Group Finance Director
Okay. Our consolidated Common Equity Tier 1 ratios in North America are north of 24%.
Stephen Andrews - Analyst
Okay. So, when we're looking at how much capital there is in North American Holdings, we should take those (multiple speakers)?
Iain Mackay - Group Finance Director
It's quite a lot.
Stuart Gulliver - Group Chief Executive
Yes. You should look at the US Holding Company.
Iain Mackay - Group Finance Director
You can't see it there. It's not published.
Stephen Andrews - Analyst
Okay.
Stuart Gulliver - Group Chief Executive
Which you can't see (multiple speakers).
Stephen Andrews - Analyst
Okay. That kind of helps answer the question.
Stuart Gulliver - Group Chief Executive
As Iain says, it's -- the capital ratio is in the mid-20%s, which is quite high.
Stephen Andrews - Analyst
Okay. No, that's helped there.
Stuart Gulliver - Group Chief Executive
We expect -- we hope and expect, that the dividend payment that we get back to Holdings will be a material sum. But we obviously aren't in a position to provide a number for that at this moment in time.
Stephen Andrews - Analyst
Okay. And then just a follow-up question on the US. I mean, if we look the remaining businesses on the NAFTA platform, as you call it, it looks like you've probably still got the best part of $30 billion, $35 billion, of capital tied up there. And although you've made a little bit of progress in Mexico, I mean, that's only $3 billion of that capital. And the rest of the businesses are really struggling to generate any return at all.
How far away are you from saying, okay, we need another plan, another way to free up that or generate a better return on that $30 billion? Because at a Group level at the moment even ex the stuff held at Holdings it's still a massive drag on Group returns.
Iain Mackay - Group Finance Director
So, if we take each component of NAFTA, you mentioned Mexico and we've talked on this call about the progress that we're making in Mexico, we are not there. We know we've got a lot more to do in Mexico but there's good traction and progress being made by Nuno and the team.
Canada is a business that continues to generate, even in higher loan-impairment charge environment coming from oil and gas sector, continues to generate an attractive return. And, on a normalized basis, that's a very attractive business for us. The challenge, and Stuart referenced this earlier in the call, is continuing to move performance within the US business.
Broadly speaking, outside the oil and gas sector, in metals and mining we've got fairly stable credit quality within the US business. We're making progress from a revenue and cost perspective as well. We obviously continue to execute against the various compliance objectives that apply to US but also the wider Group. And progress being made but more to do.
And then when you come to the surplus of capital sitting in the North American corridors, it is absolutely sitting in that US business. So, we come back to your earlier question, which is about getting the surplus -- the capital that's surplus to regulatory and to business requirements back to the Holding Company such that it can be distributed, either in terms of investing in the business, or returned to shareholders.
Stuart Gulliver - Group Chief Executive
Basically we've got to get the whole CML -- sorry, the whole CML piece has to come out; obviously the completion of the sale and dismantling of what was household and the legacy CML books. Then we need to basically get that capital out and the capital that basically has sat there from the sale of the card business and the upstate New York branches while restructuring the business.
Now, retail banking wealth-management estates is now breakeven. The global banking and markets business and CMB in the States, we did actually have an improvement in revenues and a fall in costs, but the LIC swallowed it up. So, there's a lot of restructuring work going on, as Iain says.
Once we've got the capital back out and with the restructuring work, we will get to a business that has a more accretive return than the one today. But we won't get there, as I said in my presentation, by the end of 2017.
But you can rest assured that we're highly focused on this. But we will always have a US business. We operate in parts of the world where the dollar is predominant, so two-thirds of HSBC's PBT comes from Asia Pacific and the Middle East. These are dollar-block economies. World trade is in dollars. Payments and cash management is -- 60% is in dollars. 80% of world trade's in dollars. Something like 80% of foreign-exchange trade one side settles in dollars.
The biggest economy in the world is the US. The biggest source of investable funds is the US. And actually we make about four times as much with the US companies outside the United States as we do in the United States. But that PBT falls in the legal entities or the countries in which that activity took place. So, if we do a transaction with an American company in the United Arab Emirates, the revenue is in the United Arab Emirates but actually the company's American.
So, the US business is not as unattractive as it looks at first blush. There are several pieces within it, which causes it to look a lot worse than it actually is. But we accept the fact that there is a ton of work still to do on it. And you can also rest assured that we are tweaking the plan, as you would expect, as we go along.
Stephen Andrews - Analyst
Okay. Thanks a lot.
Stuart Gulliver - Group Chief Executive
Thank you.
Operator
Manus Costello, Autonomous.
Manus Costello - Analyst
Good morning. Thank you. Just a couple of questions from me.
Firstly, just a point of clarification about the capital in the US. Can I just be clear that when you dividend this back up from the sale of the cards business, for example, which I think was about a 60 bps benefit, there isn't any benefit to the Group's consolidated ratios from that movement of capital.
So, is what you're trying to say, if you are organically generating capital by the end of next year, for example, which means that you are above this 12.5% level, you'll now be technically able to return capital? Because I can't see why the dividend-ing up of capital from the US business would directly impact the consolidated Group and your ability to pay.
And my second question, just briefly in on BoCom, has there been any further discussion about changing the capital treatment of BoCom? I think in the past you've thought maybe about treating it as a material holding. Has there been any reopening of that debate?
Thank you.
Iain Mackay - Group Finance Director
Manus, you're absolutely right. It would have no impact on the Group's capital ratios. But what it does do is put the cash resources that back up those capital ratios at the Holding Company, which means it is now within -- it is then within our power to do either reattribution to other investment opportunities or return it to shareholders. But it has no impact on the Group's common equity or other capital ratios by simply moving it from the US to the parent Company.
On --
Manus Costello - Analyst
So, what you're really saying is, if you are able to organically generate capital between now and 2017, whenever you [allow this through], you would physically be able to pay it, whereas, historically that might not have been the case?
Stuart Gulliver - Group Chief Executive
Yes. Look, I mean, if the dividend is paid out of the Holding Company the Holding Company is a listed company. So, the cash has got to be in the Holding Company, either to fund the dividend or to fund the buyback.
Iain Mackay - Group Finance Director
Yes. The -- it all comes from cash from the subsidiaries in the form of dividends.
Stuart Gulliver - Group Chief Executive
So, think about it in cash terms, as opposed to purely in capital terms.
Manus Costello - Analyst
Okay.
Iain Mackay - Group Finance Director
So, capital generation, by whether it's HBAP or North America or Mexico or any of them, it all comes back in the form of dividends to the parent Company. So, it is absolutely vital that we have capital surpluses sitting at the parent Company to enable the most efficient capital allocation.
Manus Costello - Analyst
Got it. Thank you.
Iain Mackay - Group Finance Director
On BoCom the conversation and discussion with our principle regulator continues. It's a good conversation but it is ongoing.
Manus Costello - Analyst
Okay. Thank you.
Iain Mackay - Group Finance Director
Okay.
Operator
Fahed Kunwar, Redburn.
Fahed Kunwar - Analyst
Hi. I just have a quick question on slide 8. So, if I look at your discrete quarter cost growth versus the quarter cost growth taking out the regulatory program and compliance, it's been around 2% to 3% drag from regulatory compliance over the last four or five quarters. Whereas, this year -- or this quarter, sorry, the drag is substantially less.
I mean, can we -- and obviously you've done very well getting positive jaws, as well. Can we read that across as the drag from compliance, going forward now, won't be as high as it was for the last year, year and a half? Or is this a one-off thing where compliance spend has reduced in this quarter but could go up again in the next few quarters?
And my second question was just a point in clarification on the margin. Quarter-on-quarter and year-on-year for the quarter, what has the net interest margin actually done?
Thank you.
Iain Mackay - Group Finance Director
So, going to the investment in regulatory programs and compliance, I think we set out in 2015 in June quite clearly what we needed to do in terms of investment in this space. That investment is going ahead. Clearly there's been a huge amount done over the last three, three and a half, four years. There's quite a lot that still needs to be done.
So, the rate of growth in that investment is slowing. But there is still a broad range of investments to be completed between now and the end of 2017, which is the targeted date for us exiting our deferred-prosecution agreement with the United States and the FCA.
So, the work is going ahead, but the level of investment required remains absolutely consistent with previous guidance.
Fahed Kunwar - Analyst
Sorry, just to confirm, the drag of 2% to 3% from previously, can we expect it to go down, going forward? So, it will still be a drag, but it will reduce going forward?
Iain Mackay - Group Finance Director
There will still be an increased cost coming from reg, compliance programs, but the level of influence that has overall will decrease.
Fahed Kunwar - Analyst
Thank you.
Iain Mackay - Group Finance Director
Okay. And, sorry, your other question was --?
Stuart Gulliver - Group Chief Executive
What's happening to the net interest margin?
Iain Mackay - Group Finance Director
Oh, right, net interest margin.
Fahed Kunwar - Analyst
Just on the net interest margin for the quarter.
Iain Mackay - Group Finance Director
Oh, yes. Fabulous. So, look, from -- overall, from the Group perspective, interestingly a little bit of pressure going -- coming through the UK mortgage book where there's a very competitive environment in terms of pricing in that regard. So we see a little bit of pressure coming through the UK in that regard.
Stuart had mentioned earlier that there were higher costs of funding coming through from issuance of total loss-absorbing capacity qualifying instruments and qualifying Tier 1 and Tier 2, where spreads are certainly wider in the first half of the year than has historically been the case.
And that's really it. In terms of Asia Pacific, very, very stable. North America, very stable; a slightly muted impact with the continued run-off of the CML portfolio. And Latin America actually has strengthened a little bit with policy-rate increases in both Mexico and Argentina.
So, a little bit of pressure coming through TLAC in the UK, both in the Holding Company in terms of debt and capital-instrument issuance in the mortgage book. But, broadly speaking, beyond that influence, which is quite muted, it remains reasonably stable.
Fahed Kunwar - Analyst
Perfect. Thank you.
Iain Mackay - Group Finance Director
Thanks.
Operator
Martin Leitgeb, Goldman Sachs.
Martin Leitgeb - Analyst
Yes. Good morning also from my side.
My first question would be on Brexit and the impact on Brexit on in particular your UK business so far. And you hint that there was a [flight to quality] in terms of deposits. And I was just wondering if you could comment on the inflows of deposits you have seen in the -- particularly in the UK, since the outcome of the referendums in the past six weeks, whether you saw any change in customer behavior there.
And the second question in relation to Brexit is how do you think about UK-mortgage growth, going forward? You called UK mortgages out I think in the last call as one of the key growth areas for HSBC, going forward. And I think you also made some considerable investment in that operations. Do you still target to grow in absolute terms that business?
And then, lastly, just on your very strong loan-to-deposit ratio, which has been trending down obviously at least since we tracked it in our models since 2004 at least, if not much longer. At what point does the loan-to-deposit ratio become an issue? We have seen some of the US peers proactively addressing some part of their deposit book. I guess it's probably driven by leverage constraint.
Is it fair to assume for HSBC that the loan-to-deposit ratio wouldn't be an issue simply because you're constrained by a Core Tier 1 basis? Or does that differ across jurisdiction?
And then, lastly, in terms of investment of excess deposits and deployment of those excess deposits, could you shed a bit of light what strategy you have, given obviously the very low interest-rate environment, at present?
Thank you.
Stuart Gulliver - Group Chief Executive
Okay.
Iain Mackay - Group Finance Director
There's quite a lot in there, Martin.
The AD ratio is 69%, is that an issue? So, in terms of overall net interest income, profitability of the Group, I mean, you've seen us sitting around an AD ratio of between 73%, 70%, 71%, 72%, 73%. 69% just means that we've got a slightly more difficult task to do against what we've executed over the last, goodness knows how many years, in terms of profitably investing that surplus.
And the guidance that Stuart gave you with respect to balance-sheet management, which is the core group within the bank, which manages that corporate surplus around the world, I think the guidance on revenues and profits remains entirely appropriate. So, it's not really a constraint.
I think what we are doing, which is along with many other banks around the world, is we're looking at non-operational deposits, so deposits that exceed the operational requirements of our customers and have set operational deposit levels for all -- for certainly all of our corporate customers. And where they exceed those operational levels we're a little bit stricter with them in terms of our willingness to take any further amount of deposits from them. Or, in certain currencies, as Stuart pointed out, charging for those deposits being held at HSBC.
So, there's a very strong focus on managing operational -- deposits surplus to operational deposit requirements within the client base across the Group. That's functioned obviously on the ADR ratio, as well as that has a very direct impact on the bank levy, in terms of the impact that has on us at the end of the year.
In terms of deposit inflow in the UK, what we've tended to experience historically is in times of stress we tend to see a bit of deposit inflow. That's been the case both in Asia and in the UK over the course of the first six months of the year. Whether it's particularly related to Brexit it would be very difficult for me to say.
In terms of customer activity, Stuart?
Stuart Gulliver - Group Chief Executive
So, mortgages remains a priority in the UK, and actually we've got good growth. So, we've -- so, the direct approvals market share, we have a market share of about 24%, which is up 2% year-on-year. First-time buyer approvals increased by 45%, second quarter, 2016, versus second quarter, 2015.
We've got -- remember we did most of our stuff direct, but we've now started to add some brokers on. And so at the moment we added an additional three in the second quarter, so that means we're now working with five intermediary partners. And we're going to have brought another 10 brokers on by the end of the year.
The total book size year-on-year has increased by about 3% in mortgages. So, no, mortgages remains a focus. The LTVs and the credit standards will remain as high. And you've heard Iain go through various of the LTV measures and the mixture of where our exposure was around the country and our exposure to first-time buyers, buy-to-let, et cetera.
I don't think Brexit changes that. I don't think that Brexit will change the nature of the UK home-ownership market at all. So, I still think that that is a legitimate market-share gain that we can take, frankly, either in terms of absolute growth of the market or taking business off other banks. So, I remain confident that the UK bank can continue to grow and, indeed, has a priority and a focus on growing its lending book there.
We saw, and I said in answer to some earlier questions, some fall-off in loan demand in the -- particularly in the mass business and SME sector, basically starting from early June. It hasn't really recovered. This is more in terms of net new business, so in terms of application for fresh financing.
We haven't had people repay us. So, it's not that the book is shrinking. But I would expect that to pick up in September, because I don't think that people will postpone OpEx for very long. And most of this type of financing is short term and for OpEx. So, I don't see that as a negative, either, and the GBM business hasn't really missed a beat.
On managing the AD ratio, as Iain says, from an operating deposit point of view with banks, non-bank financing and institutions, we already have a protocol around other currencies like the euro and Swiss franc where interest rates are negative, which we'd have to look to port across. But I would rather solve the AD ratio challenge by lifting the A back up than rejecting the deposits. I think it would be very, very wrong for HSBC to change a model that we've had since 1865, which is to be a deposit-funded bank.
Now, clearly, the AD ratio at 68% and interest rates at the zero band is less attractive than when interest rates were 4% or 5%. But, as I say, the challenge for us is to get business on that we can write close to our cost of equity rather than to turn away deposits.
Martin Leitgeb - Analyst
Thank you very much.
Stuart Gulliver - Group Chief Executive
And on balance-sheet management, balance-sheet management will continue to manage the balance sheet as it always has done, which is basically it's taking interest-rate risk. So, within balance-sheet management we do not really take credit risk. It tends to own government bonds and sovereign super-national type of issuers.
I don't want to create a credit portfolio within BSM. And one of the reasons for that is I'd rather take credit risk out of global banking or out of commercial banking, because then you get the relationship benefit. If you simply buy someone's bonds in the secondary market there is no relationship benefit to that whatsoever.
I don't want to turn into investors in the same corporate credit to whom we're bankers. I want to be a banker to them, lend to them directly, and then harvest the ancillary revenue. And you don't get that if you're simply buying their fixed-income instruments.
Martin Leitgeb - Analyst
(Multiple speakers).
Stuart Gulliver - Group Chief Executive
We should be underwriting in the primary market -- we should be underwriting in the primary market their fixed income, not buying it blind in the secondary market.
Martin Leitgeb - Analyst
Is there anything you do different there in terms of the term structure of that balance-sheet management book at this stage? Or is that relatively (inaudible)?
Stuart Gulliver - Group Chief Executive
No. Look, it tends to be three years and under and I don't see any reason to particularly change that. Again, we're in an environment where if we can make GBP2.4 billion to GBP2.8 billion that's a reasonable requirement. It's very hard to call what the impact, say in the UK, two years out of the pound having fallen dramatically. One assumes that the governor will do some package of adjustments tomorrow.
We could have inflation at 3%, 4% in the UK and actually -- two, three, years out and find that interest rates are sharply higher. So, I don't really want to basically change a series of protocols that we developed over many, many, years and in markets in Asia Pacific where we've seen extreme moves happen much more often. Actually, we've seen pretty extreme moves happen in the west, actually.
So, no, I don't think there's a magic bullet for this. We just have to tough it out. The problem with magic bullets is the unintended consequences of what you didn't think through. So, I don't want to build up a massive credit portfolio managed by a couple of traders. I'd rather basically get the relationship managers out to build up the credit portfolio.
Martin Leitgeb - Analyst
Thank you very much.
Stuart Gulliver - Group Chief Executive
Thank you. So, we've got time for one last --
Operator
Ronit Ghose, Citigroup.
Ronit Ghose - Analyst
Great. Thank you. I just wanted to clarify a couple of points you've already mentioned.
Firstly on capital and buybacks, can you confirm if the buybacks, the shares, will be cancelled and, if so, when?
Secondly, you've talked a lot about the up-streaming of capital, potentially from the US. And I was looking at your Hong Kong Shanghai Banking Corporation legal entity, which generates most of your profits, and you've been paying up below 50% of earnings up to Hold Co. And I'm just wondering is there a reason why, given this large amount of capital that sits in your Hong Kong legal entity or APAC legal entity, is there any reason why you're not up-streaming more out of Asia?
And, linked to that, your NPLs are beginning to tick up, albeit from a very low level in Asia. I just wondered if there was any kind of color you wanted to add or any -- is there any sign of whether it's in state-owned Chinese companies or oil and gas exposure [in ASEAN]? Is there any sign of things looking a little bit more challenging, which may want you to hold back your payout ratio, your up-streaming up from Hong Kong Shanghai Banking Corporation?
Stuart Gulliver - Group Chief Executive
So, the shares will be held as treasury stock.
Iain Mackay - Group Finance Director
That's right.
Ronit Ghose - Analyst
Yes. They will be cancelled. Why is that?
Stuart Gulliver - Group Chief Executive
No, they'll be held as treasury stock.
Iain Mackay - Group Finance Director
And there's no accounting capital or any other benefit to cancelling them. There's no detriment to holding them as treasury stock. And in treasury stock it gives us some flexibility as to their future use and re-registration.
Stuart Gulliver - Group Chief Executive
Hong Kong Shanghai Banking Corporation's capital position?
Iain Mackay - Group Finance Director
Well, one of the reasons, and this will not be a shock to anybody, is that just as the rest of the world is implementing Basel III so Hong Kong is implementing Basel III. And also one of the other aspects is of all the markets in the world where we have reinvestment opportunity the Asian markets is it.
Stuart Gulliver - Group Chief Executive
This is the one.
Iain Mackay - Group Finance Director
And so we have had historically a very consistent payout ratio, between 50% and 60% from HBAP, up to the parent Company. And at the moment that would seem to be -- continue to be the proper thing to do. But HBAP, to be clear, is really no different to any other subsidiary in the Group in terms of the challenge we place for the management team there around the efficient management of the capital.
Stuart Gulliver - Group Chief Executive
Also remember what we've just said is that we've sold Brazil, so, we don't need the shares that support Brazil. And we sold the credit-card business in the US and the upstate New York branches some time ago and we don't need the shares that support that.
We actually haven't sold anything in Asia that we don't need the shares to support it. So, the payout ratios of the Hong Kong Shanghai Banking Corporation reflect a BAU approach to dividends as opposed to its holding stuff; that's the proceeds of the things we've sold in the past.
Ronit Ghose - Analyst
Sure. I get that. But it's your current capital levels in HBAP are in the mid-teens. And I'm just wondering if there's more scope to upstream there. Or do you think that the current earnings will come under pressure in HBAP from rising NPLs and rising loan losses?
Stuart Gulliver - Group Chief Executive
No, no, the -- what Iain's saying is the HKMA look at banks in Hong Kong.
Iain Mackay - Group Finance Director
(Multiple speakers).
Stuart Gulliver - Group Chief Executive
They have capital ratios in the mid-teens.
Iain Mackay - Group Finance Director
Yes. No, this is -- the capital management, the regulatory capital management in Hong Kong, is very much informed by dialogue with the HKMA around the implementation of Basel III and capital requirements within Hong Kong. There's a decent buffer that sits in Hong Kong of 2.5% for HSBC. And we obviously need that requirement.
But it's all about the quality of the conversation and capital requirements informed by the HKMA.
Ronit Ghose - Analyst
Got it. So, there's nothing in the NPL side that's keeping you awake at nights at the moment, in Asia?
Iain Mackay - Group Finance Director
No.
Stuart Gulliver - Group Chief Executive
No, absolutely not. I mean (multiple speakers).
Ronit Ghose - Analyst
Okay. Thank you guys.
Stuart Gulliver - Group Chief Executive
It's not -- it's Brazil, Canada, US, oil and gas. It's not China.
Ronit Ghose - Analyst
Okay, thanks. Clear.
Stuart Gulliver - Group Chief Executive
Thank you. Okay. If that brings the call to the end, thanks very much everyone.
Operator
Thank you, ladies and gentlemen. That concludes the call for the HSBC Holdings PLC's interim results, 2016. You may now disconnect.