ING Groep NV (ING) 2023 Q3 法說會逐字稿

Good morning. This is Jessica, welcoming you to ING's Third Quarter 2023 Conference Call. Before handing this conference call over to Steven van Rijswijk, Chief Executive Officer of ING Group, let me first say that today's comments may include forward-looking statements such as statements regarding future developments in our business, expectations for our future financial performance and any statement not involving a historical fact. Actual results may differ materially from those projected in any forward-looking statements.

A discussion of factors that may cause actual results to differ from those in any forward-looking statement is contained in our public filings, including our most recent annual report on Form 20-F filed with the United States Securities and Exchange Commission and our earnings press release as posted on our website today. Furthermore, nothing in today's comments constitutes an offer to sell or a solicitation of an offer to buy any securities.

Good morning, Steven, over to you.

Good morning, operator. Good morning, everybody, and welcome to our third quarter '23 results call. I hope you're all well. And as usual, I'm joined by our CFO, Ljiljana Cortan; and our CFO, Tanate Phutrakul, and we continue to focus on our strategic priorities, and I'm pleased to take you through today's presentation. And after that, we'll take your questions.

The third quarter was again a strong quarter for ING, and we continued to deliver outstanding results. I'm proud to see our people creating a superior customer experience every day. And this is evidenced by further organic growth. We have now more than 15 million primary customers. Since 2016, we have grown our primary customer base with a CAGR of nearly 6% and are on track to reach our target of 17 million primary customers by 2025.

The share of mobile-only customers increased further, and 62% of our Retail customers do business with us through their mobile-only, our main channel. In Wholesale Banking, the volume mobilized to help our clients transition to more sustainable business models, was EUR 27 billion in the third quarter and reached EUR 74 billion in the first 9 months of '23 , which is 15% higher compared with the same period last year.

Our income grew 32% year-on-year and is at a structurally higher level now that the rate environment has turned positive. The fourth quarter rolling average return on equity increased to 13.8%, and we have achieved this while operating on a higher CET1 ratio of 15.2%. Assuming a CET1 ratio of 12.5%, our long-term target, our fourth quarter rolling return on equity would be more than 16%. Our strong capital position and capital generation allow us to take another step in returning capital to our shareholders. We have announced a share buyback of EUR 2.5 billion, starting tomorrow, which will bring the total amount of capital we will return to our shareholders to EUR 7 billion this year.

And I want to emphasize that we have realized these strong results in the quarter, characterized by ongoing macroeconomic challenges, geopolitical uncertainties persist and further increased over the last few weeks. Cost of living rises as inflation remained elevated, while the cycle of recent Central Bank rate hikes appeared to have paused.

Before moving to the financial results in more detail, I will spend some time on the progress we're making in the execution of our strategy and related targets. On Slide 3, our purpose and strategic priorities are shown. The first priority is to deliver a superior customer experience that is personal, easy, relevant and instant. And this is highly valued by our customers, as evident by our Net Promoter Scores, where we maintained our #1 position in 5 of our 10 Retail Banking markets.

One example of how we offer this excellent experience is via digital onboarding. In many markets, we now onboard most of our new Retail customers via the mobile banking app. Another example is the introduction of a KYC tracker in the mobile app in Poland. An important part of keeping RNG safe and secure is knowing our customers and this new feature in the mobile app allows retail customers to track easily the status of their onboarding and directly address any requirements, making the process as seemly as possible.

Our second strategic pillar is putting sustainability at the heart of what we do. And we have recently published our '23 climate report, which describes progress our aim to steer our Lending portfolio towards global net zero climate goals and highlights our leading role in the banking sector. We also introduced several new sustainable alternatives for retail products. In Germany, we added sustainability filters for investments in our app, enabling our customers to identify investments that fit their sustainability preferences. They are already among the top 4 most used filters in the app. And in Romania, we added new purposes to our sustainable personal loans like solar panels.

And then we move to Slide 4, which shows our achievements in helping our clients and our low carbon transition. As mentioned, we have recently published our '23 climate report, and I would like to highlight a few milestones. We are increasingly making climate part of business processes, working on our approach to assessing client position plans, in scope of our Terra approach and developing tools to support this.

We have expanded our oil and gas approach, and we're not done yet. Last year, we were the first large global bank to stop providing dedicated finance to new upstream oil and gas fields. This year, we expanded our coverage by restricting dedicated finance to midstream activities, also aiming to reduce the volumes of the trade oil and gas that we finance. We also help set standards to join the Organization, and we have done this for the shipping and steel sectors, and we're now collaborating on a new methodology for the aluminum sector.

Our leading role in sustainability also offer opportunities. In the third quarter, we had a leading role in the financing of the first offshore wind farm in Poland, which will produce enough clean energy to power over 1.5 million households. In the Netherlands, we financed the national heat funds, which provides loans to private homeowners, homeowners associations and schools with the aim to make homes and buildings more sustainable.

In the Netherlands, almost half of the labeled homes have an energy-efficient label, but much still needs to be done to make homes more sustainable. However, we need to work on this together and specifically call on governments, hence regulators to guide the transformation more firmly.

Then on Slide 5, we highlight our continued success in the Retail Banking market in Germany. We have been chosen as the most preferred bank for 17 years in a row by Euro Magazine and have continuously maintained our #1 position since we started measuring it in 2015. This appreciation of our digital products and services has resulted in a strong growth in the number of primary customers, particularly in the last few years.

As of 2023, we once again were able to benefit from the positive rate environment and grow the number of clients further via attractive and profitable savings campaigns. Despite some limited outflow of deposits to competition this quarter, we have grown our deposit base by over EUR 11 billion year-to-date. And we may expect some further outflows as the savings campaigns have ended.

We also saw a continued shift to assets under management, and the number of investment product accounts continues to increase. And we have also again been able to grow the Lending book, despite challenging market circumstances with subdued demand.

Then we move to Slide 6. In the third quarter, our strong capital generation and capital discipline have resulted in a further strengthening of our capital position, allowing us to take a next step in converging our CET1 ratio towards our target level. And I'm pleased to say that we will distribute an additional EUR 2.5 billion through a share buyback, which will start tomorrow. Including the buyback, we have already returned approximately EUR 21 billion to shareholders since 2018 and almost EUR 7 billion in '23 alone, resulting in a 16.2% return year-to-date. The size of the next steps on our path towards our target level by '25 will depend on profitability and RWA developments going forward. On risk-weighted assets, as I indicated before, we have absorbed most of the regulatory RWA inflation, and any impact from the implementation of Basel IV is expected to be manageable.

As an example of the regulatory impact, there is a new standardized measurement approach for operational risk, which takes into account profitability and which could result in an impact of up to 20 basis points in 2025. periodical methodology changes and strategies taken regarding the IRB model landscape will continue to have a positive or negative effect on credit risk-weighted assets.

Then Slide 7 shows our financial targets for '25 on fee growth. In addition to the strong impact of further primary customer growth, we see room to increase or introduce fees in Daily Banking, the continued growth of investment product accounts will result in higher fee income when market confidence improves. Further support will come from a growth of Lending fees when overall loan demand recovers. Total income grew over 20% year-on-year, significantly higher than what we had guided for in the beginning of the year, mostly driven by the strong recovery of liability margins.

Our cost-to-income ratio decreased to 51.6%, in line with the '25 target. Our costs are well under control, despite the ongoing pressure from elevated inflation levels, and we also continue to invest in our business, which will support commercial growth and brings operational efficiency in the longer term. On our CET1 ratio, we intend to move to our targeted CET1 ratio of around 12.5% by '25. And as mentioned before, the next steps will reflect the strong capital generation and capital discipline, and we will update the market with the disclosure of the first quarter results of 2024.

Despite risk costs coming in below our through-the-cycle average and no identifiable trends in provisioning are there, we remain vigilant as the cost of living, hence doing business arises for our customers in the current context. Taking all of the above into account, we are confident that we will be able to sustain our 12% return on equity.

Then to Slide 9, there we go to the third quarter results. We saw a development of total income in the last 5 quarters. It's clear that the strong growth is driven by a recovery of liability margins, while all other income lines have been stable. The cycle of recent Central Bank rate hikes appear to have paused, which means that our liability margins may reduce somewhat from current levels. And I will also be impacted by the change in the remuneration on the minimum reserve requirement by the ECB and has a positive NII support, we currently expect interest rates to be higher for longer and margins to stabilize at a structurally higher level than in the past, depending on developments in the comparative landscape for savings.

55% of our replicating portfolio will continue to support our liability income, while our strong and diversified commercial positions in Retail and Wholesale Banking will enable us to capture income growth even more so when loan demand recovers.

Also the quarterly development of our net interest income and margins on Slide 10. The strong increase of NII year-on-year was driven by normalization of our liability margin, which now stabilized at around 120 basis points. And the acceleration of core rate increases was absorbed, but a positive impact from reinvesting part of our replicating portfolio at higher rates.

In Lending, we saw the overall margin increase for the third consecutive quarter, despite some pressure on mortgage margins due to rising interest rates as client rates generally track higher funding costs for a delay. Note that the interest income continued to be impacted by accounting asymmetry, which led to lower net interest income in Treasury and Financial Markets, which was offset in other income. Our overall net interest margin for the quarter increased by 1 basis points to 157 basis points. And year-on-year, the net interest margin increased by almost 30 basis points.

Slide 11 shows the development of our net core lending, and Retail mortgages continued to show growth, despite challenging market circumstances, growth was mainly visible in the Netherlands, Germany and Belgium. In Wholesale Banking, we saw a small decline in net core lending as demand was still subdued, and we continue optimizing our capital usage. And going forward with still heightened macroeconomic uncertainty, we expect loan demand to remain subdued. However, our business model and geographic diversification has enabled us to capture growth opportunities through the cycle. And then the liabilities after the significant deposit inflow in the second quarter, we saw core deposits declined by EUR 7 billion in this third quarter. This was mainly due to a shift from deposits to assets under management and seasonal impacts as customers tend to spend more during the summer holidays.

In Germany, we had some outflow, reflecting intensified competition, while the decline in Belgium was mainly attributable to customers buying retail bonds issued by the Belgian government in September. We had significant inflows in Retail other, mostly in Poland and Australia, and Wholesale Banking recorded a small outflow.

Now to Slide 12, which showed growth year-on-year, driven by Retail Banking, while Wholesale Banking was seasonally lower, and Retail Banking fees from investment products increased, particularly in Belgium, due to a net inflow of assets under management. Daily Banking fees also increased, reflecting higher fees in payment packages and new service fees. Wholesale Banking was impacted year-on-year by lower volumes in Daily Banking. And sequentially, the fees were stable quarter-on-quarter.

Fees in Retail Banking grew due to seasonally higher travel fee-related income and lower commissions paid to independent agents in Belgium. Fee income for Wholesale Banking was lower, mainly due to subdued demand in Lending and seasonally lower deal flow in Global Capital Markets and Corporate Finance.

Next Slide 13. Excluding regulatory costs and incidental items, operating expenses were up 4.7% year-on-year. This was mostly due to the effect of high inflation rates on staff expenses, reflecting indexation and CLA increases across most of our markets. We also continue to invest in growing our business. Quarter-on-quarter expenses, excluding regulatory costs and incidental items, increased 1.3%, despite higher staff expenses, so it was relatively limited.

Regulatory costs were up slightly year-on-year as the third quarter last year had included a lower contribution to the deposit guarantee scheme in Germany. And on a clean basis, our year-to-date cost growth was roughly 7% versus the prior year, which is a good indication of our run rate in 2023.

Then we move to risk costs on the next slide, that's Slide 14. Our risk costs were EUR 183 million this quarter or 11 basis points of average customer lending, well below our through-the-cycle average of 25 basis points. We still have a stock of management overlays amounting to EUR 486 million. In Wholesale Banking, risk costs included a number of well collateralized individual files. This was, however, offset by a further release of Russia-related provisions as we continue reducing our Russia exposure. Total offshore Russia exposure amounted to EUR 1.5 billion at the end of the third quarter, and total risk costs in Wholesale were EUR 15 million, 1-5.

In Retail Banking, the risk costs were predominantly in Belgium, Germany, Poland and Spain, mainly driven by collective provisions. And although Stage 3 increased slightly at 1.5%, it remained low with modest inflow and no clear trends visible. The lower Stage 2 ratio mainly reflected repayments and some individual files moving to Stage 3. And all in all, a very benign quarter on risk costs. We are vigilant as the cost of living and doing business increase for our customers, and we remain confident in the quality of our loan book.

Slide 15 shows our CET1 ratio, which increased further to a very strong 15.2%. CET1 ratio -- sorry, CET1 capital increased by nearly [EUR 8.5] million, driven by the inclusion of net profit for the quarter after reserving for dividends. Furthermore, risk-weighted assets were EUR 2.1 billion lower, including EUR 400 million of FX impact. Credit risk-weighted assets decreased by EUR 2.2 billion, mostly driven by an improved profile of the loan book and a further decrease of our Russia exposure.

[In our] share buyback will have an impact of 78 basis points on CET1 ratio, which will be visible in the fourth quarter numbers of this year. Including the distribution, we offer a 16.2% return to shareholders year-to-date. We will update the market on our capital plans with the disclosure of our first quarter 2024 results, which brings me to the wrap-up with the highlights for this quarter. A strong third quarter in which we again delivered an excellent set of results. Execution of our strategic priorities delivered strong growth of primary customers, and we made significant progress in our aim to help our clients transition to more sustainable business models. Our financial results in the third quarter clearly demonstrate that we are well positioned to continue to benefit from the positive rate environment. Total income increased further, and expenses remained under control. Our capital position remains very strong, allowing us to announce a EUR 2.5 billion share buyback starting tomorrow. And going forward, I am confident that we will continue to deliver robust financial results while executing successfully on our strategy.

Now over to Q&A. Operator?

(Operator Instructions) The first question comes from the line of Giulia Miotto from Morgan Stanley.

Two questions from me. The first one is on net interest income. You are flagging some pressure on the liability margins going forward, which makes sense, deposit EBITDA will go up. But on a net basis, do you think this can be more than compensated by asset margins improving in the replicating portfolio? Or how do you see essentially the net impact? So that's my first question.

And then I just want to check something on Slide 6. When you say the Basel IV impact is expected to be manageable. So is this a change, what does manageable exactly mean? Can it be more than 50 basis points, for example? Or And also if you can comment on the time line because the day 1 impact perhaps is low, but then what will be the total impact also including the output floors?

Okay. Thank you very much, Giulia. I'll take the question on net interest income, and Ljiljana takes the question on the Basel IV impact, which is manageable by the way. But going to net interest income, look, clearly, the competition for savings has increased and may increase, and that could have an impact on the core rates, and that could also then have an impact on the net interest margin for deposits.

The good thing is, is that -- and that's on the positive side, and that's maybe what you're alluding to that so far, how we have seen benefits from the higher rates partially, but 55% of our 480 billion Retail Eurozone replicating portfolio is invested longer than 1 year, and that part will continue to reprice at higher rates, and that can provide a support for NII. And furthermore, we will continue to aim to grow our customers and to grow our business also benefiting from Lending when that recovers.

So yes, more pressure on NIM. Good diversification in funding. So more than 55% of our Retail deposits longer than 1 year, and a good diversified business with continued focus on growing customers, growing fees and we will benefit when Lending demand recovers.

Then to the Basel IV impact, Ljiljana.

Giulia, as we said, the overall impact is manageable. This means it's within the regular updates that we are performing quarterly on our model. So we do not expect anything new than what we said before. The only news that we are now more crystallizing is the more clear impact due to the standardized measurement approach on operational risk assets as well due to increasing profitability of the group. So from that perspective, we say it's up to 20 bps on operational risk assets, but the rest, including these 20 bps, we seem manageable.

And if I can just follow up on the NII. So directionally, do we think NII has peaked? Or it can still grow next year? Essentially, this was what I was trying to get to with my question.

Yes. Well, look, that what we do see is, if you compare it to the past, we are managing our NII at a structurally higher level than what we have seen in the past. And we are confident on the composition of the liability book on the ability to further diversify our income, but also to continue to grow our loan book when demand recovers. And depending on the speed with which happens, that will have the effect, but we're confident that we can continue to provide an attractive NII level.

The next question comes from the line of Tarik El Mejjad from Bank of America.

I have a couple of questions, please. First, on the capital return. So you moved away from equal steps distribution to, if I quote to, size the position next step will depend on capital generation going forward. So in '23, you had quite a good capital generation driven by lower RWAs and some model updates. That's yielded some positive generation. So -- and you distributed EUR 2.5 billion in the last tranche buyback. So would that mean that if a normalized kind of capital generation next year will be lower size? Or are you still thinking of capital generation in conjunction of steps. That's the first question.

The second one is on the Wholesale Banking. I mean the portfolio shrunk in this quarter. And would you link that to a slowdown or uncertainty in the market? Or do you see some weakness in some area in your business model in Wholesale Banking that would probably, at a later stage, need more work and some restructuring.

Okay. Thank you, Tarik. I'll take the question on the Wholesale bank, and Tanate will talk about the (inaudible). So on the Wholesale Bank, now there is nothing in particular to mention other than now loan demand has relatively slow, given the, let's say, low economic cycle in which we currently are in, then also seasonal effects play a role where typically the large Lending deals don't come in the third quarter because of the summer period. And we also see that, by the way, on the global capital market side, where the third quarter is a bit slower. So nothing out of the ordinary or then the fact that loan demand is relatively slow. As I said before in the past, although we don't have a loan target per se. We have seen loan demand grow in Wholesale Banking typically between 3% and 4% per annum over the last number of years on average. This year, it is lower with around 1%. So at some point, it will recover again, but there is nothing specific to mention here.

And Tarik, on the capital, yes, we removed the language around roughly equal step. That's because, as you mentioned, the last 3 quarters, the capital generation by ING has been really strong, reaching 15.2%. That is allowing us to step up our distribution to EUR 2.5 billion, right? We still plan to converge on the 12.5% core Tier 1 target levels. But we also flagged that this is really depending on how the earnings outlook looks like, risk-weighted levels as we see it going forward and also taking into account macro and geopolitical developments in the coming period.

The next question comes from the line of Farquhar from Autonomous.

Just two questions from me, and apologies, I've a slight cold. Firstly, the EUR 2.5 billion buyback, it kind of takes us to a 14.5% CET1 on a pro forma basis, that still kind of up a little bit from 1Q. Can you just outline when we might actually begin to see that come down as part of the trajectory and what math might be and trigonometry around it might be? And then a related point, when thinking about indicative steps from here, should we think about the annual step of around EUR 4 billion, i.e., 1Q and 3Q added or most recent EUR 2.5 billion for the 6 months?

And then secondly, the DNB published some details around this new approach on anti-money laundering yesterday. I just wondered what your thoughts might be around that? Is it kind of a step in the right direction? Is it leap-forward or maybe a bit of a step?

Yes. Thank you very much. On the DNB approach on AML, I think we're very happy with that. I think that they have come out with principles and guidelines in terms of having a more risk-based approach is something that we have been advocating for many years. This for a better doing of AML, i.e. much more effective. And we can also focus also our capacity on where it is really needed rather than a one-size-fit-all approach. So it's much more effective. It can also potentially be more efficient.

But in the answer, when we do these things, we want to do the right thing, and I think that's very good. And I'm very happy that the DNB has come out. We also have roundtables with them to give input on how this can be done. So I think that -- I mean the world in general is maturing on AML, but I think that also here in the Netherlands with the DNB coming out, which is a very, very good step forward. So that's maybe point one.

On the share buybacks, indeed, we're moving to 14.5%. That is well calculated. And we will continue with our rhythm of updating you in the first and the third quarter. And as always, you know us by now, we will do it by then, and we will not provide any further guidance upfront. We'll do it when we announce the first quarter results in 2024.

The next question comes from the line of Johan Ekblom from UBS.

We can maybe come back to NII and two questions. I guess in this quarter, we saw the savings rate increases offset the positive impact of the replication portfolio. Can you just talk about what, if any, savings rate changes you've implemented since the end of the third quarter to help us understand what the impact would be looking forward?

And secondly, just on the Treasury impact. I mean if I look at the Dutch NII, it's down some 14% Q-on-Q and 20% year-on-year. I'm assuming a lot of the Treasury impact is booked there. Can you help us understand kind of what the magnitude is impacting the Dutch NII specifically? Because it seems like most of the geographies are showing pretty good NII momentum and the weakness is really in the Netherlands.

Okay. I'll give both questions to Tanate, starting with NII.

Yes. So I think on NII, we -- you asked about announced rate increases. We have 2 increases being a core rate increase in the Netherlands and also an announced core rate increase in Germany. To give you a sense, the deposit beta for ING in Q1 was around 15%, 20% in Q2, 28% in Q3, and it will be 31% as of the 1st of November this year. Okay.

Then the second question regarding Treasury arbitrage. That continues to be in place. The strategy is still continuing into Q4. And the reason why it affects the Dutch book more than others, this is where our major Treasury operation results on the Dutch balance sheet.

So we can assume that most of the 2 50 headwind sits in the Netherlands?

It is, yes.

The next question comes from the line of Raul Sinha from JPMorgan.

I guess a couple of questions just staying on NII. Let me kind of think about the outlook for NII from here. I was wondering if you might be able to comment a little bit around whether or not you think you can maintain NII stable with -- given the rising deposit beta from here through any changes in the replication portfolio. And I guess the question I'm really trying to ask is, would you consider changing the 45%, 55% split within the replicating portfolio going forward if it provides you with more NII stability?

And then the second question is just coming back to the volatility within NII. I think this is the second quarter where consensus is a little bit surprised. The market is obviously much more focused on NII versus other income total income. The accounting estimate that your NII is obviously suffering on a reported basis. But I presume on a banking NII basis, things might be a little bit less volatile. So I was wondering if you could comment on perhaps the underlying NII trends, whether they're a little bit less volatile than the headline that you reported?

Okay. I'll take the first one and then Tanate take the second one on the symmetry. But look, I mean, the -- again, on the outlook, there is pressure or we expect pressure further on the deposit NIM as competition progresses or as people will move more money to the assets under management. We have seen it also this quarter where we have, on a gross basis, a couple of billion moved to assets under management and it depends on the competition in the markets.

Second element on the NII is, of course, the minimum reserve requirements. A decision of the ECB that has moved to 0, that is going to have an impact as of the next quarter. And on the positive, we have currently loan demand being subdued. So when that picks up, that will be helpful. Still 55% of our deposits is being invested for longer than a year. I'll come back to that. And we grow the number of customers with what we have done in the past, approximately 6% per annum. So that is between 600,000 and 800,000 per annum currently.

And those are all the upward moves. And how that all plays out, we have to see. We're very positive that we can trade at a significantly -- a structurally higher level than we did in the past on NII. Regarding the 45-55 split, yes, the way that we have built up our replication has, of course, to do with the value of savings, i.e., the behavior of our customers, and that's the way that we're building it up. So we're not changing it as such because we have to have a -- we want to match funds in that sense, if you will, based on behavior as liabilities as much as we can. So we would change based on changing behavior. But not based on, let's say, changing P&L because you want to keep your banks safe and that's how we do it.

And Steven, if I can follow up on the AUA -- sorry, Tanate, just on the AUM impact as deposits move into AUM, what is the pickup for the P&L from a fee perspective?

Yes. I mean, currently, you do see -- so then that depends on the amount and how many trades that you have You have fee income and commission income. Fees is a one-off and commission income, which is ongoing. So that then depends on the mix. But you now see gradually and the number of accounts, which we have seen increases -- continue to increase, but also the number of trades is picking up again. And that can have a positive effect when that continues to be the case on our fee income in terms of investment products.

Then Raul, to answer your second question. I think overall, we managed the bank on overall income, right? So the fact that in Treasury, sometimes you see lower NII and higher other income. I think that is just, by the by, it's just the results of accounting. But I think overall, the net is positive for ING. That's why we do these trades. But if you strip away those results and you look purely at the banking book, they are quite stable. And I think the best way to describe it is that the pressure from deposit beta is negated by our replication strategy. So that's why you don't see purely on the banking book, much material impact despite the increase in beta in Q3.

The next question that comes from the line of Benjamin Goy from Deutsche Bank.

I've two questions, please. First, in Germany, the savings campaign, you mentioned some outflows, but net positive. I was just wondering if you can shed a bit more light on primary customers you're winning out of that? Or was the mainly existing customer transfer more fund for kind of what was the longer-lasting impact other than this nice margin for 6 months at least?

And then the second question is capital return and potential changes to the taxation of buyback. I'm just wondering how that impacts your thinking about capital return strategy? And whether that's the reason why the EUR 2.5 billion might be executed fully as compared to the last buyback in Q3 where you paid out the residual, then in January, a special dividend?

Okay. Thank you. Yes, if you look at the growth in primary customers, you can also see that on Page 5, if you then do the translation, but we -- I think every quarter in this year in the top 3 or fastest-growing number of primary customers, Germany has always been there. So that was indeed the strategy not only to get deposits in to also make a return on those deposits because even with the marketing rates that we had at the time, we made a spread between what we paid to our customers and what we earned on these deposits. It was also to get new primary customers in, and the primary customers indeed have been growing very well in Germany. And again, like I said, top 3 every quarter since the last 3 quarters. That's maybe number one.

Number two, indeed, there is some outflow because our campaign started somewhere in the second quarter in the beginning, and that campaign -- typically, these campaigns last for a couple of months. And then after that, we were early, and I think we timed it very well, then other banks follows with their campaigns. And at some point, our campaign is ending. Other campaigns continuing, and then you will see that you get some outflow. That's what we have always said that we calculated that we would have some outflow, but let's face it compared to the beginning of this year. There is still an EUR 11 billion increase in our deposits in Germany. So that is very, very good. And if there are other marketing also lose something.

And in terms of the money where then was flowing out, yes, it's through our part to assets under management. But it was coming from not per se, new clients is also coming from existing clients. So it was not that the money was -- is perceived as being very hot and everything that flows in also flows out. And yes, look, we have to continue to look at the next quarter. We see what will happen. I also said we can expect perhaps more cash -- or more outflows. It typically depends on when our campaigns start and end and when campaigns of others start and end. Tanate?

On capital return, I think, clearly, we are watching the taxation on share buyback very carefully. Our expectations is that it will not take place until at least 2025, if at all, once the new Dutch government is in place. But share buyback is one of the key tools that we use in terms of cash distribution to our shareholders. And so we're watching the situation carefully. But clearly, given the fact that our stock still trade at a discount to price to book, that's why we decided to announce the share buyback mostly in shares or exclusively in share buyback.

The next question comes from the line of Amit Goel from Barclays.

So two questions. The first one, maybe a bit more of a follow-up. But just I just want to understand on the replication portfolio. What's the average duration of the 55% of the book, which is more than 1 year because I'm just trying to understand the shape of the liability margin? And if we could see some improvement after some nearer-term softening?

And then secondly, in terms of the capital return, I think your consensus doesn't have the group getting down to the 12.5% CET1 target and that level would leave the group with a smaller buffer MDA to where we see other banks in the sector. So I just wanted to, again, just double check why your confidence in getting down to that level and that it is an appropriate level?

Okay. The replication, I think we disclosed at the end of 2022, the behavior -- so the duration of our behavior-driven replicated liability is approximately 2.8 years. And given the interest rate movement now, you can expect that, that duration is somewhat shorter than at 2.8 years, okay?

Then to your second question on our targeted capital ratio. We have come up with these capital ratio based on a number of factors, our earning capabilities, stress testing, and looking at the MDA level and the most importantly, the stability of our business model, right? We are a highly stable, very predictable earning capital generator. And that's why we're confident that we can operate at around 12.5%. Sometimes the buffer looks tighter because of, for example, countercyclical buffers being higher at this time. But during a different economic cycle, the countercyclical buffers could be less. And as you have seen announced by the Dutch National Bank that have given us an OC buffer reduction of 50 basis points, which will come due in 2024 as well.

And just coming back on that first part, in terms of the shape of the liability margin, are you thinking it could come back somewhat, but there could be some support thereafter from the replication portfolio? Or is that baked into the guidance, the contribution from the portfolio?

It's baked into the guidance I suppose in a way to look at our disclosure and maybe where you can find more facts. Remember, in Q3 2022, we gave a simulation of how the shape of our replication would look like. That shape is still similar to what you would find. But the exception is that we use that based on the September forward curve where the short end of the curve is materially shifting up in 2023. So perhaps you can look at that and maybe apply the current forward curve rather than the September curve.

The next question that comes from the line of Kiri Vijayarajah from HSBC.

A couple of questions, if I may. Firstly, just coming back to the retail fees. You mentioned good momentum there, good conversion rates there. But looking forward, do you think it gets more challenging to convert those deposits into investment products as core rates keep trending up and customers potentially preferring to sit on cash there? So are there some potential fee headwinds on the retail side and kind of need to think about there?

And then secondly, turn to the restructuring in Belgium, some of the charges you've taken there. I just wondered what the underlying trigger. Obviously, you want to get the cost base down. But is the revenue generation is coming in under budget in Belgium? Or is it more the lying cost inflation is proving a bit more severe than you thought, hence it kind of new restructuring?

And then just in terms of the timing politics and the bank taxes in many places. I just wondered is, is now the best time to unveil sort of headcount cuts and branch closures, politically speaking? So just your thoughts there on the Belgian restructuring?

Yes. Starting with the restructuring in Belgium, I mean we are -- as a bank, we are continuously working on a better digital experience for our customer. So that's -- we have all kinds of STP targets, and we have scalable tech targets and scalable op targets that we also presented during the investor update that we gave in June of 2022. And in that setting, that means that also in Belgium, we're relatively speaking, compared to some of the other markets, we were not so digital. We have been working very hard in making our organization more digital. And that's not only branches, that's also how we respond to customers and how we deal with call centers and how our product interaction is that it is in all kinds of levels that we are building a more digital organization. Now that is paying off. At some point, it also means that some of the services we are doing more automatically. And that at this point means, we also then do it with less people, and that's what the restructuring is for. And you've seen it in many markets, we don't do that in big banks. But we continue to look at how we can optimize and maximize the offering for our customers, and this is the result of it.

In terms of Daily Banking, yes, look, what I mean, let's take a step back at a higher level. First of all, if you look at our total assets under management, and that's what I've also said a few years ago, if you look at our fee income relatively to our interest income is relatively low. And one of the reasons is that we did not develop as yet so well a number of our diversification products. Still now, we have an asset under management base or with our customers or they trade, which is less than EUR 200 billion. Now compared to banks of our size, that is very small.

So to convert our customers to primary customers, which means customers that do more with us, we're still a long, long way to go. And that's, of course, you could see, on the one hand, that higher interest rates and depending on investment appetite, customers may be less keen to invest because they may also be able to get it on an interest account. But we still need to convert a number of these primary customers also to investment customers. And there, we still have a long way to go to get to where we need to be. That's why I'm positive on this.

The next question comes from the line of Flora Bocahut from Jefferies.

And I'd like to go back to the NII because you give us on this call pluses and minuses on the evolution from here. But you then don't commit to say whether this is going to be a net positive or a net negative and that leads to, I think, some people thinking, okay, so we should actually annualize the performance you just printed on Q3 NII. And if we do that, it means a substantial decline in consensus expectations, which I suspect is why the shares are under pressure today.

So just two questions I'd like to ask again on NII to make it clearer for us. First is on the deposit beta. And thank you, Tanate, for giving us the deposit beta evolution here. So 31% as of the 1st of November, where do you think this is going? Because my feeling is you lack at this stage the repricing on the asset side. And then you have obviously already had a significant repricing on the deposit side compared to other countries. So where could that go? What's the end level of deposit beta in your view? And then the second question is on the drag to NII from Treasury and Financial Markets. Is it going to continue at this pace, the same pace as we saw in Q3?

I'll give the second and third question to Tanate. And the first question, yes, I gave number of pluses and minuses. And it is what that is. So I think the most -- I think what we do very well, and that's what we build confidence in is that we have been able to continue to grow our primary customers. We do see that loan demand compared to where we currently are as low. We do have deposits that for 55% are still longer than 1 year and are, therefore, have an upward pressure on NII.

And then, of course, there is the competitive pressure that we need to see what that is on -- in different markets. That leads by the way, to one of the questions of Tanate, whereby the tracking rate so far on average has been below what we thought it would be for the average of the year. But again, that is until now. So that all remains to be seen, at least we're very positive of the levers that we can pull. And the macroeconomic context is the macroeconomic context, and that's what we will live in.

Then your question is, where would the tracking go from 31% that we see on November 1? It really depends on a number of factors, right? The first and the chief one is the level of competition for deposits, given that loan demand is weak at the current time, you can see that the competition for deposits is likely to remain benign for the time being. And the second factor is really where ECB rates are to go. And clearly, some people call it the ECB rates are paused. Some say it's already peaked and coming to an end, which means competitively, banks are less likely to increase deposits to protect NII. So that -- to answer your question.

And then to address the question -- second question, if I understand correctly, it's around the Treasury arbitrage and FM, where the similar levels of trades would happen in Q4, and the answer is, yes. Our expectations is that, that will remain about the same kind of pace.

And just to follow up on that last point. Is it just a '23 story of this is something that continues in '24, these arbitrage you are doing?

Yes. If this opportunity remains available, we will continue to do it.

The next question comes from the line of Anke Reingen from RBC.

I've just one follow-up question on NII. Are you willing to quantify the headwinds into Q4 from the MRR as well as the deposit outflows on Belgium and Germany? And then secondly, on costs. Thanks very much for the guidance on Q4 and the year. If we look into 2024, do you think the cost ex levies have sort of plateaued? Or do you think inflation is still quite meaningful headwind? And if you can, please remind of the latest your expectation about the SRF decline in '24?

Okay. I think the first question on the MRR, the negative impact of that for the fourth quarter is EUR 70 million per quarter. So EUR 70 million for fourth quarter and then also that same amount going forward. Tanate?

Then if I answer your second question on regulatory costs, I think our guidance has been that for 2023, we expect regulatory expenses to be approximately EUR 200 million lower than the same period in 2022. So that's the first guidance. And the second guidance is that with the DGS pool being fulfilled, SRF pools being fulfilled and also taking into account what we know of additional bank taxes that are coming in the Netherlands, in Belgium and in Romania, our expectation is that SRF contribution by ING in 2025 is likely to be approximately EUR 300 million lower than the prevailing levels of 2021.

And in terms of cost ex the levies, do you think those have plateaued going into '24 or--

I think there are three component points, Anke, is that the level of labor inflation will remain high in 2024, less than '23, but remains elevated because some of these collective labor agreements are agreed already upfront. The second part is that we continue to have savings program to negate part of that through our digitization program. And programs, as Steven mentioned, around restructuring like in Belgium that we had. And the third is, of course, that we continue to invest in our future. So these are the 3 balances that will take into account the impact. But I would say the pressure on inflation is coming down, but it's not fully over in '24.

The next question comes from the line of Chris Hallam from Goldman Sachs.

Just two. So the first is a follow-up clarification on some of the earlier comments around capital. You mentioned the pace of reduction down to 12.5% could be impacted by the outlook on profit growth, RWA growth and the broader macro backdrop. Those inputs really just into the split of distribution between '24 and '25? Or would they potentially feed into pushing the 12.5% target back beyond 2025, either through your own decision or from an approvals perspective? That's the first question.

And then second, and maybe we can take this offline. But I think you said in August, betas were tracking at 29%, and now they're at 31%. So is the right way to think about that, that a 2 percentage point change in deposit beta offsets the tailwind from the replicating portfolio? Maybe I got the beta numbers wrong, but I just wanted to check that.

Yes. I think -- thank you very much. I think the answer on the first question is no. We still have our target for 12 -- around 12.5% for end of 2025, which is what we said before and which we still say now. On the beta tracking?

Yes. So the beta tracking, what you see is that the increase in beta from 2028 in Q3 have been fully compensated by our replication. Whether that would be the case for the 2 percentage points increase in Q4 is something that we'll report in Q4.

The next question comes from the line of Mike Harrison from Redburn Atlantic.

I've got two, please. So rates that you're offering the in the quarter went up quite a bit. I just wanted to ask about how the higher savings rates were impacting deposit mix? And whether you see that accelerating in the future? And then the second question, again, on NII is there's some discussion about the ECP increasing minimum reserve requirements, not just flashing. Can you talk about what offsets you have in the business, both in terms of the impact on NII and the impact on the liquidity coverage ratio? Because, I guess, your subsidiary in Wholesale makes you a little bit more vulnerable versus some of your peers?

Well, I think we have three components in terms of our liability mix, current account, savings and term deposits. And if you go back a decade ago, then you have a split of around 25-75 between current account and savings account and materially very little in term deposits. What you see with the current environment is that current account is coming from a high level and starts normalizing as savings are remunerated. So that trend is beginning to converge back to more normal levels, but remains above the historical trend that I mentioned.

And also, we see that from a competitive perspective, a number of banks, including ING, is basically offering more term deposits. So the share of term deposits are rising as a part of our funding mix. Then to talk about the second part, we just think that the introduction of an increase in MRR is simply the wrong thing, right? When we have advocated that with our regulators and the ECB monetary policy because increasing MRR actually reduces the bank liquidity coverage ratio. But having said that, if we have to manage it, we have to manage the size of our balance sheet, right, to shorten the balance sheet to compensate for further impact of MRR, if that were to take place, including for BMG .

There are no further questions in the queue, so I will turn the call back over to your host for some closing remarks.

Yes. Thank you very much. Thank you very much also for listening in and for your good questions. And today is a special day since Mark Miller, the Head of Investor Relations, is going to move on. He started in May '17. And since then, he has been at the helm of Investor Relations for 6 years. He is now passing on the baton to Sjoerd Miltenburg, who starts today.

And Mark, and we have worked a long time together will stay with ING. I'm very happy with that he will now become the Head of Wholesale Banking. So I think that's very positive. Netherlands -- sorry, Wholesale Bank Netherlands, the CRO corrects me, Wholesale Banking Netherlands. But still, that's a very positive development for ING and I think for all stakeholders involved. But Mark, thanks very much for all that you've been doing. I'm sure, by the way, all the analysts on the call that you have really enjoyed working with Mark in this capacity, but I'm sure he will do the same with Sjoerd.

With that, we'll leave you for now, and we hope to speak and see you soon. Cheers.