KAS Selections November 2012

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KAS SELECTIONS Volume 19, issue 4, November 2012

Kempen & Co Strengthening infrastructure through direct link KAS BANK in Nordics KAS BANK and dwpbank start joint venture for retail securities processing in Europe KAS BANK and Solvency II Screen Event Conference on ‘Taxation and the latest developments in the pensions landscape’ OTC Derivatives under EMIR Fort lawyers The ‘Ultimate Forward Rate’: could this really be the final version? Risk management conference Improving returns in securities lending EU Short Selling Regulation Words from Wiesbaden: Depotbank


KAS Selections KAS Selections is a quarterly newsletter from KAS BANK N.V. Although the information in this issue is drawn up with the utmost precision, no rights can be derived from it. Volume 19, Issue 4, November 2012 Contents: Foreword 2 Kempen & Co 3 Strengthening infrastructure through direct link KAS BANK in Nordics 5 KAS BANK and dwpbank start joint venture for retail securities processing in Europe 6 Laurens Vision 8 KAS BANK and Solvency II 10 Screen Event 11 Conference on ‘Taxation and the latest developments in the pensions landscape’ 12 OTC Derivatives under EMIR 14 Fort Lawyers 16 The ‘Ultimate Forward Rate’: could this really be the final version? 19 New Clients 21 Personnel notes 21 Risk management conference 22 Global Custody Network News 26 Improving returns in securities lending 27 EU Short Selling Regulation 28 Words from Wiesbaden: Depotbank 30 Comments on this issue, suggestions for future articles and mailing list requests should be addressed to: Netherlands Client Management: Managing Director mark.schilstra@kasbank.com Sales & Business Development (S & BD) Managing Director mark.van.weezenbeek@kasbank.com German Branch Managing Director frank.vogel@kasbank.com KAS Investment Servicing GmbH CEO & Managing Director joerg.sittmann@kasbank.com UK Branch Managing Director laurens.vis@kasbank.com Translation: Wilkens c.s. Text editor: Robbert Veltman Editor: Carla Boogers KAS BANK N.V. Marketing & Commercial Development P.O. Box 24001, 1000 DB  Amsterdam The Netherlands +31 20 557 5812 carla.boogers@kasbank.com Graphic Design: Ebbenhorst Design, De Meern Print: KAS BANK, Document & Systems Services

Foreword Singing your own praises isn’t really the done thing – but I would like to make an exception. To receive one award is wonderful (as European Custodian of the Year), but winning two accolades in one evening is even better. At the European Custody Risk Awards ceremony in London on 20 November, KAS BANK took two awards: one for our Pension Fund Monitor app as ‘Technology Innovation of the Year’, and the second as ‘Custodian of the Year – Netherlands’. In the opinion of the independent jury of financial specialists from various sectors, the app has launched a revolution by allowing administrators real-time access to the pension fund’s main parameters. The app also makes a significant contribution to the education and decision-making processes of pension funds’ trustee boards. As Dutch Custodian of the Year, KAS BANK was particularly praised for its pure-play strategy and the bank’s low risk profile, which it consciously strives to maintain. While we are naturally proud of these two prestigious awards, we regard them above all as a reward for our close partnership with our clients in developing new services and products for the financial sector. Pilots and brainstorming sessions are one important aspect of this, but we also value your feedback greatly in all other spheres of our services. On behalf of all our employees, I would thus like to express our sincere thanks for your close involvement in KAS BANK. We owe these awards to you! We concentrate mainly on services to ensure you remain in control of your administration, your reporting obligations and your investments. This issue of KAS Selections contains several examples of this, such as the columns on EMIR and Solvency II. Our conferences held in KAS BANK’s auditorium provide an opportunity to share the latest developments with you, on national and European legislation and regulation. This time we report on our conferences on the taxation of pension funds, and risk management for pension funds. The engaging presentations by our specialist guest speakers ensured a lively exchange of opinions. Our staff regularly speak at external events too. At the ‘BeleggersBeraad’ (Investor Deliberation) event organised by IPNederland, Mark Schilstra highlighted the consequences of the introduction of the UFR for pension funds. At the Screen Event in Amsterdam, Albert Röell chaired the concluding panel discussion ‘From credit crisis to regulation crisis?’ The signature of our partnership agreement with dwpbank is, of course, another important subject in this KAS Selections. The launch of this joint venture heralds the creation of the new retail securities processing platform for the Dutch and European market. We are bringing you up to date on recent developments. In our series of articles about the businesses behind KAS BANK’s clients, we put the questions to John Hak of Kempen & Co., who sheds light on a variety of issues including the impact of financial regulation and the debate surrounding funding levels at pension funds. This issue of KAS Selections is so jam-packed that I lack the space here to mention all the subjects it covers. Apart from that, I’d like to take this opportunity to wish you a prosperous 2013. After all, looking ahead is a form of being in control. Sikko van Katwijk Managing Board of KAS BANK


In the second instalment of our series looking at the businesses behind KAS BANK’s clients, John Hak Chairman of Kempen & Co sheds light on a variety of topics, including the impact of more rigorous financial regulations on his business and the debate about pension

John Hak,

funds’ funding levels.

Chairman of Kempen & Co

How would you describe the corporate culture at Kempen & Co?

us to excel with those products. Our funds in high dividend

Kempen & Co is far from being your average bank.

equities, small caps, credits, real estate and alternative funds

A traditional bank deploys its capital and the funds entrusted

all offer alpha and have won a variety of awards in recent

to it, whereas all we have to offer our clients is ourselves:

years.

our knowledge, our experience, our creativity and our

As indeed has our securities business. One example are the

determination to be the best. As a boutique competing with

extel ratings, the industry’s ‘Oscars’, which are awarded on

bigger, international institutions, we are well aware that

the basis of input from businesses and investors and which

people won’t automatically gravitate towards Kempen – and

have revealed for many years now that our analysts, sales

that once they have chosen Kempen, we have to earn that

people and traders are regarded by our clients as some of

trust afresh, each and every day. That awareness is very

the best in the industry.

much a part of Kempen’s culture and the mindset of our employees, who are all professionals wanting to be the very

The financial world is contending with

best they can be, and to bring out the best in each other.

increasingly strict regulation, Basel III, AIFMD,

They have the courage to take that responsibility on board

MiFID, EMIR and FATCA being a few examples.

and want to be held accountable. We realise that it’s not

How is Kempen & Co preparing for this, and

what we do that makes us unique, but who we are and how

what role should your custodian play?

we do it, working with one other and with our clients.

You’re quite right, there’s a whole raft of new regulations affecting the financial sector. Although not all of these

What is Kempen & Co’s strategic vision for

regulations have a blanket impact on a specialised player like

preserving its ties with its clients?

Kempen & Co, implementing the laws and regulations that

We must fulfil our client’s expectations. Better still, we must

do apply to us involves a great deal of effort, and we are

exceed them. At Kempen Capital Management, one of the

keen to draw on the knowledge and expertise of other

ways we do this is by offering holistic, bespoke solutions to

parties in the market to assist us. KAS BANK has also given

challenges faced by pension funds and insurers when

us some useful input for certain aspects of the laws and

managing their investments in relation to their commitments.

regulations. By and large, we are confident that we will

We also offer specialised investment products for which we

adapt our systems, processes and procedures in good time.

have to realise a structural alpha. The fact that we have

One thing that does concern us somewhat is the level

made strategic choices about the products we offer enables

playing field with foreign competitors. In matters such as KAS Selections • November 2012

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inducements, share categories in Dutch investment funds

are achieving growth outside the Netherlands in our core

and remuneration, the Dutch policymakers and regulators

sectors: indirect real estate, life sciences and cleantech.

take a different approach in certain respects compared to

We’ve been involved in dozens of capital market

international policymakers and regulators. Given that we are

transactions in these sectors over the past two years.

operating on an international playing field, this could make

Almost 70% of those were European transactions. In our

us less competitive.

business, we’re no longer a Dutch bank, but, increasingly, a European bank with Dutch roots.

As an asset manager, what’s your stance

We are, in some respects, relishing the crisis. Bigger

regarding the debate surrounding pension

financial institutions are being forced to concentrate on a

funds’ funding levels?

limited number of activities. The activities on which we focus

First, it’s obvious that pension funds are struggling to meet

are often not core activities for these big players, so they are

their nominal commitments right now. This will still be the

being abandoned or sold. We can then step in and claim a

case, even after the new ‘regulator’s curve’ has been

bigger share of the market.

implemented. What’s more, in the next few years, it will be virtually

In your opinion, how will the financial sector

impossible to offer inflation indexation. For the sake of

look five years from now?

participants, let’s hope that inflation doesn’t rise too fast,

I expect the latest developments and measures to engender

because pension funds are ill-prepared for this eventuality.

a growing awareness in the sector that the client must not

In that scenario, funding levels may well recover, but pension

be sold what he is willing to pay for, but what he needs. This

payments will lag way behind in real terms. The regulations

is also essential so as to restore trust.

in their current form are based on nominal figures, making it

I also expect a sharper distinction to emerge between big

difficult to respond to the expected higher inflation.

financial institutions focused on capital-intensive and

There has also been a lot of debate, of course, about the

ICT-intensive services and products, and specialised

curve applied for discounting commitments. The choice of a

boutiques focused on knowledge-intensive services and

UFR-related curve presents no problems for us as an asset

products. In the ‘new reality’, assets must be employed

manager – particularly as we have already implemented

chiefly for the benefit of the client, substantially higher capital

similar curves for our insurance company clients. In general

requirements apply and products are simple and

terms, however, I think you have to be critical of rather

transparent. In this reality, sufficient scale is a prerequisite for

artificial approaches. It’s like feeling too warm indoors: if you

a sustainable earnings model in capital and ICT-intensive

merely replace the device that measures the temperature,

services and products, such as lending and payments. For

that won’t actually reduce the heat in the room.

knowledge-intensive services and products, such as asset management, private banking and corporate finance,

How is Kempen & Co responding to the

attracting and retaining top talents and providing an

financial crisis in Europe, as regards the

environment that inspires them is the key to success.

persistently low volumes on various markets

I believe specialised boutiques are best placed to do this.

for example?

Obviously, I regard Kempen & Co. as an example of this

As a specialist, we have chosen to focus on a select few

latter category.

activities in which we excel. At times like this, we really reap the benefits of this approach. We are stemming the tide. Our asset management business has grown strongly in recent years, on both the product and the fiduciary management side. As for our securities business and corporate finance, although we are faced with lower volumes in the Netherlands, and this despite a growing market share, we

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KAS Selections • November 2012


Strengthening infrastructure through direct link KAS BANK in Nordics As a General Clearing Member with direct membership of

Direct Connection (I)CSD

CSD’s Euroclear Nederland, Euroclear Finland and VPS in

Direct Connection CCP

Norway, KAS BANK now also offers clearing, settlement

Via custodian network

and custody services to traders in Northern Europe. This marks another milestone in the further expansion of our market position in the Nordics. KAS BANK allows its clients direct access to all the main European stock markets. The Scandinavian market – the fourth largest securities market in Europe – is becoming increasingly important to KAS BANK. Through our direct link to the securities infrastructure in the Nordics, we now offer our clients direct access to the Scandinavian market as well. Conversely, Scandinavian banks and brokers also have

KAS BANK has been handling post-trade services for

direct access to stock markets outside Scandinavia through

Neonet in Europe since 2003. Neonet manages an

KAS BANK. Combined with our direct links to NYSE

execution platform on which it offers its clients access to the

Euronext, the London Stock Exchange and Deutsche Börse,

complex and fragmented European securities market.

we now cover the four biggest securities markets in Europe.

Neonet’s services are focused mainly on smart order routing (SOR) and direct market access (DMA). Neonet does not

This direct link is an addition to our clearing services in

engage in proprietary trading or any other financial activity

Sweden, Finland and Norway and will enable us to offer

that might constitute a conflict of interest with its clients.

improved services:

While banks and brokers are its primary target group, it also

• Tighter settlement deadlines

offers institutional investors the opportunity to trade directly

• Lower risk and greater efficiency

via the Neonet platform instead of through their own asset manager – affording them a direct insight into how

We will continue providing a service to clients who operate

purchases and sales are executed, and for what fees.

on the Danish market through our sub-custody network.

For institutional parties, this information is important for accountability purposes and for keeping check on

Minority interest in Neonet

movements in their own assets.

In order to further consolidate our position in the European infrastructure, we have acquired a 20% minority stake in

The other new shareholders of Neonet are investment

execution service provider Neonet AB. The stake in Neonet

company Hay Tor Capital and the incumbent management

will enable KAS BANK to further develop its European

of Neonet. Current owner Nordic Capital Fund VII will

post-trade services, in anticipation of the increasingly

continue to be involved in the Stockholm-based business as

stringent requirements for transparency and best execution

a minority shareholder.

under the European MiFID II Directive, which is expected to come into force next year.

KAS Selections • November 2012

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KAS BANK and dwpbank start joint venture for retail securities processing in Europe Following intensive preparations, on 26 September 2012

Joint venture

KAS BANK and dwpbank signed an agreement

The agreement adds a fourth focus to KAS BANK’s range of

establishing a joint venture for a new European securities

services: servicing retail clients. The market is crying out for

platform. It will be based in Amsterdam.

a player who can handle large volumes of securities transactions efficiently – a tall order which relies on flawless

In the joint press release with dwpbank in December 2011,

processing. The new platform is capable of handling millions

we clearly explained to the market our aims and vision for a

of wholesale and retail transactions each day.

European infrastructure. Back then, it seemed both

The new joint venture aims to be the market leader in

advisable and feasible to establish a new securities platform

processing securities transactions in the Netherlands by the

for processing retail securities transactions in Europe in the

end of 2018. The range of services will be extended to other

summer of 2012. As time went on however, the realisation

European markets in the second phase of the joint venture.

dawned for both parties that it was better to take proper stock of our shared aims, and to flesh out our ambitions

The joint venture offers the following benefits to banks and

before establishing the platform. This process culminated in

financial institutions considering moving their securities

the partnership agreement with dwpbank which we signed

processing elsewhere:

on 26 September. The start of a joint venture and the opening of a dwpbank branch in Amsterdam mark a

Economies of scale

milestone on the road to realising our shared ambitions for

• Low fixed costs in an uncertain market, due to a unit-

growth. Both parties are therefore totally committed to this end result, and we can focus all our energies on making the

based pricing model • Lower unit prices thanks to the bundling of volumes

platform a success.

From left to right: Karl-Martin Im Brahm Rolf Kooijman

Markus Walch

Albert Röell

Christian Tonnesen Sikko van Katwijk

dwpbank

dwpbank

KAS BANK

dwpbank

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KAS BANK

KAS Selections • November 2012

KAS BANK


Management of operational risk

To actively involve clients in the change process, we are

• Outsourcing of process and trading risks

setting up a Client Control Board. Clients who are interested

• Completely redundant system architecture

in taking part will be fully informed of changes, involved in

• System availability of 99.9% of the time in the last three

those changes and have a say in setting priorities and

years

identifying scope for improvements.

Scope benefits

Trailblazing

• With the new platform, clients are assured that their

As a bank, there have been many instances in the past

securities transactions will always be processed using

when we have successfully blazed a new trail. Through our

the latest technology and in accordance with all the

dialogue with clients and the market, we have ascertained

applicable laws and regulations (Target2-Securities,

that they are interested in our partnership with dwpbank and

MiFID) and the various tax systems or other national and

are responding positively to it. Talks about the new platform

European regulations.

and KAS BANK’s wholesale services for dwp clients in

• No costs incurred for the timely implementation of legal provisions (such as FATCA)

Germany are underway with various parties. Together, we are adding a new dimension to the service-oriented KAS BANK.

Wholesale services Its partnership with dwpbank will also enable KAS BANK to optimise its growth opportunities in Germany still further. With this in mind, dwpbank is providing KAS BANK with support for the provision of wholesale securities services to dwpbank’s institutional clients and to German financial institutions – reflecting the high level of confidence in KAS BANK’s wholesale services. We are increasingly recognised and valued in our specialist field in Germany. Client Control Board The change of control over processing from KAS BANK to dwpbank was originally scheduled for the summer of 2012. However, further investigation revealed that more time would be needed to build a completely new platform. The wholesale knowledge of our processing staff is a key factor in this process. To ensure that the process is handled with all the necessary care, the transfer of around 150 operational staff to dwpbank’s new Amsterdam branch is now scheduled to take place in 2015.

KAS Selections • November 2012

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Laurens’ View Memories of dramatic events

into a state of deep crisis); in pensions (today’s pension

are collective phenomena. As

crisis is the equivalent of the perfect storm); in the political

time passes, details start to

arena (the political crisis in the country has reached a critical

fade (supposedly from three

juncture with Congress thrown into a deep crisis); in

months onwards) and the

meteorology (authorities are seeking crisis communication

event becomes distorted,

systems to cover the global warming crisis after series of

finding its way into the stories

high impact weather crises); in medicine (bitterly contested

of our past.

health reforms throw hospitals into crisis amidst a fresh political crisis); in humanitarian issues (homeless migrants bring a humanitarian crisis to our doorstep); in the military

When disaster strikes, the most telling visible witnesses are

(rapid crisis response severely threatened by lack of

the broken-down homes, the devastated buildings, the

operational crisis guidance); in culture (our cultural system

ravaged infrastructure, the meltdown of communications,

faces the biggest crisis of legitimacy ever) and last but not

the spike in disaster coverage newsreels.

least psychological (economic crisis dramatically increases adults’ vulnerability to physical and mental crisis).

Because broken buildings equal broken people. And broken people predict the danger of a broken social fabric. And our

It seems that words fail us to make as many versions out of

fellow men responsible for ‘the news’ are in business, while

a crisis as the media are capable of. And the economic crisis

we, the bystanders, watch in fear and anxious anticipation

is a case in point.

for the recovery to present itself, for the rescue teams to move in, for the familiar structures to reappear and to once

Small wonder that the word crisis itself is derived from the

again provide shelter and domestic safety for the homeless.

original Greek word ‘krisis’, coming from ‘krinen’, to draw a line, to separate. Which stood for ‘a decision’ and was used

But where are we when no such thing seems to happen and

to describe a turning point, a time when a decision must be

the story of recovery does not (seem to) unfold? What if the

made.

back-end of one disaster leads into an even worse one as a result of it? What if the return to what was, gives way to a

Today, the word crisis stands for a sequence of events,

seemingly permanent deviation from the normal state of

describing the economic crisis as the economic and financial

things. It is then that we know: we are in a state of crisis.

situation around the world. Because, as we are reminded many times, the economic crisis manifests itself in our day

These days it appears that the very meaning of a crisis is in

and age on a global scale. And it truly has become a global

crisis itself. We are practically inundated in crises every day,

crisis. Even more worryingly, it has progressed to becoming

the media are hammering home crisis left, right and centre.

‘an ongoing crisis’.

Irrespective of the area of our endeavours, we seem to be heading towards, to be in or to be going out of a crisis.

Decisions are at hand, but the necessary decisions have not been made, due to the (you guessed it) ongoing governance

Crises are on the loose in finance (the European debt crisis

crisis and the dysfunctional marketplace being in a state of

and dysfunctional banks are bringing the Global Economy

crisis.

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KAS Selections • November 2012


Because it did get squeezed, in varying degrees of intensity,

The Chinese knew of this all along and use the word crisis

it failed and was drawn into the process of being dislocated.

(wei-ji) in many words of motivation. Their word for crisis

The tensions spread to money markets (worldwide), the

stands for how to handle danger (wei) and see the

crisis became ‘systemic’ and liquidity stopped flowing from

opportunity (ji) at the same time. Chinese characters tend to

cash-rich banks to cash-poor banks.

have many different meanings. But in this case the word wei circles lightly around fear in its different meanings, while the

Markets slumped (as if they disappeared into quicksand

word ji points towards a ‘favourable juncture of

never to surface again), plunged and plummeted (as if in free

circumstances’ and a ‘good chance for advancement or

fall), spiralled downwards (as planes collectively dropping

progress’.

from the sky), collapsed outright (implying a sudden catastrophic event resulting in the total destruction of all

But for now, as we are heading towards the inescapable

created market value), crashed (as always ever popular) and

end of the year, I wish you a good, healthy and happy

flash-crashed (a new version of the traditional crash), melted

cross-over into the New Year. But do keep your eye on

down, or, at best, took a downturn (which is what markets,

Christmas please. For the sake of us all. You might have to

annoyingly, tend to do before they start to rise again).

protect it against an impending crisis. Because it is now considered to be the most financially ill-prepared time of the

In short, we entered the language of crisis. Where are the

year, caught in a crossfire between credit card companies

days when markets falling more sharply than normal were

and crushed under the very weight of the debt crisis.

called black or ink-black coloured Mondays, Wednesdays and Fridays? Black is the colour of crisis against which

Wei-ji (危机) is the word!

we try to protect ourselves by means of crisis plans drafted in crisis departments by crisis management teams. The crisis button is never far away. Can we plan a crisis? A phenomenon, as the name suggests, that defies collective wisdom and defeats what we believe to be normal. Should we keep trying to do so? With all our might, devices, regulations, protocols and hierarchical structures? Because crises can also be productive. They destroy creatively (otherwise known as Schumpeter’s – the economist – gale), they create such a state of affairs that forces radical change in the socio-economic system (Karl Marx’s concept) and they announce themselves when we have passed the point of no return before it is too late. And they necessitate radical measures to present and preserve another spell of security which we believe to be a normal, permanent and safe environment.

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KAS BANK and Solvency II KAS BANK’s

A study by Ernst & Young reveals that almost 80% of

Solvency II

Europe’s insurers have made little progress in implementing

project team

the pillar 3 reporting requirements, although Dutch insurers

has mixed

are doing better than their European counterparts in this

feelings about

regard (60% - 70% have made little progress). The reasons

progress on

cited are the complexity of the reporting requirements and

implementing

the challenges in terms of process and system adjustments.

Solvency II. Although

These issues are also recognised by KAS BANK’s Solvency

Meir Elmaliah, Account Manager

another delay is

II project team but, in spite of the difficulties and the

Fund & Insurers Services

apparently on

ambiguity of the regulations, the systems at KAS BANK are

the cards, the

in the final development phase. EIOPA has chosen a number

situation is very vague. It seems to be the intention of the

of data elements and identification codes that are not widely

European regulator, The European Insurance and

used in the market, if at all, and that are also not normally

Occupational Pensions Authority (EIOPA) to postpone the

offered by data vendors as part of their existing services.

implementation until 1 January 2015 at the earliest.

Here we, and the market in general, are dependent on third

De Nederlandsche Bank (DNB), however, is hinting that

parties. Setting up a high-quality look-through service

parts of Solvency II may be implemented, even if EIOPA

presents another challenge. As well as being a requirement

postpones its implementation until after 1 January 2015.

for Solvency II, this service is in keeping with a wider market

Meanwhile, the European Parliament has delayed the vote

trend towards a stronger focus on risk management and

on the Omnibus II Directive from 20 November 2012 to

compliance.

11 March 2013. Thanks to KAS BANK’s independent position, we see This uncertainty surrounding the implementation date makes

ourselves as a natural player in this development: after all, an

it difficult to finalise the timetable for the Solvency II project.

asset manager has nothing to fear from any disclosure of the

Progress by European insurers is slower than anticipated,

look-through data supplied to us. KAS BANK is immune to

particularly on aspects that are still far from being finalised.

issues such as conflicts of interest or loss of competitive

One of those aspects is pillar 3, the reporting requirements.

advantage, because we are not involved in areas of advice

The relationship between the reports is not always clear and

or management.

logical, the format of the reports is likely to change and the interpretation of the data elements is not set in stone.

To round off our asset-related Solvency II services, we have invested in the essential post-QRT report steps, i.e. the

The persistent uncertainty about the implementation date

scenario analyses or stress tests. Thus we are now able to

has prompted some regulators to incorporate certain

handle the entire process for insurers and relieve them of all

components of Solvency II into existing local laws, thereby

their asset-related activities.

introducing tighter supervision of insurers in certain respects. This is happening in the UK, Germany, France and the Netherlands. The danger with this is that it may result in a hotchpotch of unharmonised local regulations – negating one of the aims of Solvency II.

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KAS Selections • November 2012


Screen Event The Amsterdam Screen Event was held on 27 September, on the theme of ‘Dealing with uncertainty: new realities in the financial information services industry’. Screen is a one-day event for the financial sector consisting of a conference and an exhibition. KAS BANK had a stand. At the conference Albert Röell, Chairman of KAS BANK’s Managing Board, chaired the concluding panel discussion ‘From credit crisis to regulation turmoil?’ Albert Röell, Chairman KAS BANK’s Managing Board models were considered. The option of partial outsourcing and consultancy was discussed at length, stressing the importance of concluding sound Service Level Agreements. Next up for discussion was the question as to whether the sector exerts sufficient influence on the key players in the legislative and regulatory landscape. Opinions on this were The panel, made up of Carolien Boog (Syntrus Achmea

very mixed.

Vermogensbeheer), Remko de Jong (APG Asset Management) and Frank van de Ven (Mn Services),

On a more philosophical note, the participants considered

discussed with the audience how businesses can best

whether, by implementing all the regulations, the regulator

prepare for implementation of the relevant legislation and

will achieve the pre-defined goals, or whether there will be

regulations governing the financial sector.

unforeseen consequences? The new system risks under EMIR were cited as an example, because some CCPs may

The lively debate began with consideration of a number of

soon become too big to fail. There is also the risk that the

possible implementation models for the imminent laws and

more stringent capital adequacy requirements under

regulations. As well as abandoning certain aspects of the

Solvency II will dissuade shareholders from investing in

existing service range, the ‘in-house’ and ‘aggregator’

companies. Last up for discussion was the basic premise of the new regulations – namely, that they restore the focus on the client. It isn’t inconceivable that there will be unintended side effects for the end client, or that new rules will converge. The measures relating to derivatives transactions, for example, might have a significant impact on the capital charge.

KAS Selections • November 2012

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Conference on ‘Taxation and the latest developments in the pensions landscape’ Three topical issues were the main focus of the

Prior to the transfer, both the transferring party and the party

conference on ‘Taxation and the latest developments in

taking over the fund must weigh up the interests of all the

the pensions landscape’, held on 4 September 2012 in

stakeholders carefully. There are also a number of

partnership with Loyens & Loeff: Is our pension system

mandatory communication steps, such as a final letter from

still future-proof? What measures must be taken to make

the transferring party, an introductory letter from the party

the pension system efficient and flexible? What is the

taking over the fund, and a uniform pension overview.

thrust of the recent case law of the European Court of

As well as getting legacy costs in order, SMART agreements

Justice as regards pension funds’ VAT liabilities and

between the old and new administrator are very important.

discriminatory withholding taxes?

Equally important are clear agreements between the Boards of Trustees of the pension funds involved and the continuing

Ernö Kalmár, Manager of Marketing and Sales at pension

involvement of the pension fund directors on both sides. The

services organisation Timeos, described how the process of

progress of the entire process can be checked against Key Performance Indicators. A member of the audience asked to what extent, when a fund is integrated, allowance is made for cultural differences, which are often a major stumbling block when organisations join forces. In Kalmár’s opinion, it is very important to retain the look and feel of the fund being integrated. A ‘Sector

‘integrating’ pension funds into an industry-wide pension

Committee’ serves as a forum for making agreements on

fund – in this instance, the Pension Fund for Graphic Design

how best to preserve the fund’s identity.

Companies – works in practice. Essentially, the motives for

As regards including the pension fund’s commitments in the

making the transition are the same for every pension fund,

company’s balance sheet, this has no implications at the

and include economies of scale and better prospects for the

present time. Under the current accounting rules, pension

participants. Another consideration behind the decision to

assets are regarded as a single investment pot when the

integrate into an industry-wide pension fund rather than

individual schemes are retained – so they do not constitute a

transferring the fund to an insurer, is the lower costs of asset

multi-company pension fund.

management. A growing number of companies are also wondering whether running an independent pension fund is

Joël Wessels, Tax Consultant at Loyens & Loeff, then

still part of their core business. In this respect, increasing

considered the options open to pension funds for paying

numbers of funds are either no longer willing, or no longer able to satisfy the increasingly stringent governance requirements. What’s more, after the transition, both sides (management and labour) remain in charge of the content of their pension scheme and enjoy a fair amount of freedom in managing the parameters of the scheme’s structure.

12

KAS Selections • November 2012


less VAT. Under Dutch law, Dutch pension funds provide

One of the questions raised by the audience was whether the

VAT-exempt services as long as they handle the asset

discriminatory deduction options for VAT encourage pension

management and implementation of the fund themselves.

funds to transfer their asset management to a provider

If these activities are outsourced, VAT will immediately be

outside the EU. In Wessels’ opinion, tax considerations are

charged, because the fund is then receiving VAT invoices

not normally a major factor in the investment decisions of

from external suppliers. Since VAT was increased with effect

large investors such as pension funds. If the implementing

from 1 October 2012, this can push up their costs by 21 per

body is spun off or split off (outsourcing), the agreements with

cent.

the tax authorities have to be reviewed. In this event, the

They can avoid this by applying VAT exemptions, deducting

‘exemption for cost-sharing groups’ can usually be claimed.

VAT or charging the VAT costs through the employer. However, to be eligible to do this, they must fulfil the criterion

Erik Bobeldijk, left (Head of the Tax Department at

of ‘management of assets raised by investment funds and

KAS BANK) and Ronald Wijs, right (Partner and Tax

investment companies for collective investment’. In the

Consultant at Loyens & Loeff) then delivered a joint

Netherlands however, the assets of an institutional investor are regarded as individual assets, not as a collective investment fund. To clarify whether this constitutes unlawful differences in tax treatment, the Court of Appeal in Leeuwarden has submitted some preliminary questions on this issue to the European Court of Justice. Among other things, the Court of Appeal is seeking a ruling on whether a pension fund in which assets are contributed and invested by

presentation on dividend withholding tax refunds which, for

or on behalf of participants and in which the participants

pension funds, are an important means of increasing the

share in the proceeds, can be classed as a ‘common

return on their investments.

investment fund’. One complicating factor in the Netherlands

Most EU states charge withholding tax on dividends as an

is the new option to establish a ‘premium pension institution’

advance levy on wealth tax. Refunding this tax is regulated by

(PPI). Management services for PPIs are exempt from VAT,

European treaties or bilateral tax conventions. Despite this,

because defined contribution is deemed in law to be a

local pension funds are often entitled to a refund of

collective asset.

withholding tax, whereas foreign funds are not. Under European law, this constitutes an unlawful hindrance. This

For many years, Dutch pension funds have had the practical

paves the way for Dutch and foreign pension funds to submit

option of reaching agreements with the tax authorities

claims for a refund of withholding tax in the EU Member

regarding certain exemptions or a reduced rate for services

States. Because of the EU principle of the free movement of

subject to VAT. Pension funds are only liable for VAT, for

capital, funds outside the EU, including Switzerland, can also

example, with regard to trading in securities. As this activity is

submit claims.

VAT-exempt, pension funds do not, in principle, deduct VAT

Ronald Wijs pointed out that a good cost benefit analysis is

– the exception being transactions with non-EU parties, for

necessary when making a claim. In some countries, being

which VAT is deducted. Given that the counterparty’s

right in essence is not the same as actually being proved

domicile is usually difficult to ascertain, practical agreements

right. To be proved right, you often have to fight your way

on the percentage deduction are based, among other things,

through a lot of red tape or arrange full translations of all the

on the location of the stock exchange on which the

relevant documents in order for your claim to be considered.

transaction is settled. Agreements can also be made

Although European case law will gradually eradicate the

regarding administrative services, and pooling investments is

differences in treatment, completely equal treatment is not yet

another option for the exemption or deduction of VAT.

in prospect, given that countries seek to preserve their tax sovereignty as far as possible.

KAS Selections • November 2012

13


OTC Derivatives under EMIR The require­

deal must be registered no later than one day after the

ments and

conclusion/amendment/close of the transaction. ESMA has

consequences

published a standard template with all the details that have

of EMIR have

to be provided. The exposure and collateral of each deal will

been explained

have to be reported on a daily basis. The challenge will be to

at great length

combine information from different systems (such as the

in recent issues

derivatives files and collateral system) in good time, so that

of KAS

the trade repository receives full and accurate data.

Selections. Edgar Kooter, Sales Director Institutional

Time, now, for

Risk mitigation requirement

Services

a brief summary

EMIR requires market parties who conclude non-cleared

of the back­

OTC deals to take risk-mitigating measures with regard to:

ground and implications of the regulation for pension funds and insurers, the solutions KAS BANK offers, and a few questions that need to be answered.

• Confirming the deal: OTC derivative transactions must be confirmed as soon as possible (by electronic means); • Portfolio reconciliation and compression: agreements on this must be recorded in writing. For larger portfolios, the

Background

parties must conduct six-monthly reviews to determine

In response to the impact of the credit crisis, the G20

whether the portfolio can be restructured with fewer

decided to introduce even tighter regulation of the global

derivatives and larger notionals;

OTC derivatives market. In Europe, this intention has been

• Dispute resolution: the parties must agree mutually, in

formalised in the European Market Infrastructure Regulation

advance, the procedures and processes for identifying,

(EMIR). The regulation requires trading parties to:

recording and monitoring disputes about deals,

• clear standardised OTC contracts centrally

valuations or the exchanging of collateral;

• trade via trading platforms (SEFs) for standardised OTC derivatives (where possible) • notify all OTC derivatives to trade repositories • tighten up their risk management with respect to uncleared OTC derivative transactions.

• Valuation: deals must be valued at mark-to-market. Only if this is not possible is mark-to-model permitted; • Collateral: The margin frequency will be increased to daily valuation and collateral matching for each currency. The expectation is that counterparties will have to provide collateral using a method similar to that applied by a

Central clearing

CCP. This could mean, for instance, that initial margin

The European Securities and Markets Authority (ESMA) will

has to be exchanged (which could be held by a third

supervise compliance with EMIR and stipulate which OTC

party custodian).

derivative classes are eligible for central clearing at a CCP. To begin with, it is likely that Interest Rate Swaps (IRS) and

(Relative) exemption for pension funds and

Credit Default Swaps (CDS) will be subject to the EMIR

insurers with pension activities

clearing requirement.

Pension funds and insurers are exempt from central clearing until August 2015. However, the expectation is that the

Compulsory reporting to trade repositories

costs of bilateral clearing of OTC derivatives will increase

All market parties (both financial and non-financial) are

substantially. Parties currently exempt will therefore decide

required to report all derivative deals to a trade repository

to settle these transactions through central clearing

(i.e. including the parties who are exempt from clearing). The

(voluntary clearing), because of the impact on banks’

14

KAS Selections • November 2012


solvency of bilateral OTC derivative transactions in the wake

In operational terms, the indirect implications of EMIR for

of Basel III.

pension funds and insurers are much more far-reaching. • How do I integrate OTC derivatives in my investment

The implications of EMIR

administration and related reports? • How can I optimise my collateral and liquidity

The direct implications of the regulation for the parties

management?

affected are obvious. To enable central clearing, a clearing member must be designated who is a member of the

• How do I guarantee independent supervision?

preferred CCP. KAS BANK can fulfil this role for you.

• How do I ensure that I am always in control?

However, our open architecture also allows you to choose

• How do I keep my systems up to date?

one or more third-party GCMs.

• How do I report my transactions and positions and

Once the transaction is complete, it must be reported to the

ensure that I continue to comply with the latest regulatory

repository and – for the duration of the contract – collateral

requirements?

etc. must be moved, reconciled and administered on a daily

Provided the above issues are handled correctly, EMIR

basis. There are various ways of structuring this process.

could be a source of great opportunities for you.

KAS BANK’s solution KAS BANK provides all the facilities necessary so that you can fulfil the requirements set by EMIR: Requirements under EMIR Clearing via CPP

Trading via platform

Reports to repository

Risk mitigation requirement

Reducing system risk

Increasing price transparancy

Regulator can check positions

Improving management of credit risk

KAS BANK as GCM or as intermediary

Institutional Risk Management & Treasury

Investment Management Services

Institutional Risk Management & Treasury

(non cleared transactions)

KAS BANK’s (EMIR) solution

Custody

Clearing & Settelement

Other services

• Derivatives clearing, execution and administration • Consolidated overview of all positions with all parties/CCPs • Collateral and liquidity management optimised in a pool • Up-to-date information for effective risk management • Single source for all relevant reports, including to regulators, and information • Performance and compliance management

KAS Selections • November 2012

15


lawyers Receivers are a special client group at KAS BANK. We spoke to Frits Kemp, lawyer and administrator at legal firm Fort, about bankruptcies, insolvency law and the special requirements when dealing with a bankruptcy account. Who are Fort and what is your specialisation? Fort is an Amsterdam-based legal firm operating nationwide. The office was established almost 40 years ago, but in its early years it traded under a different name and as a small full-service office. In 2000 we decided on a complete change of track. Today Fort employs some 30 specialised lawyers, who only handle financial corporate law and property law.

Frits Kemp, lawyer

The advantage of our concept is that we are big enough to

and administrator at

provide highly specialised, bespoke services, but small

Fort lawyers

enough to do so at competitive rates and to operate with permanent, regular contact people. Increasing numbers of

limited company. The law on limited liability companies has

business owners are seeking the right lawyer for the right

been more flexible since the new law was introduced on

job. In our segment, you won’t always find that at a large

1 October 2012, so the ‘flexible limited company’ is the

firm in the Zuidas district of Amsterdam. Costs are obviously

limited company as we know it, but subject to an

also an important factor: on average a large firm is twice as

overhauled law.

expensive.

The impact of the financial crisis on our clients is becoming increasingly apparent to us. Banks are still withdrawing

Which market developments are most relevant

money from the market and cancelling loans, often in

to you?

stages, spread over a number of years. Business owners are

We’re seeing a rise in ‘prepacks’, an approach to

rightly protesting about this, because the implications are

bankruptcy whereby the administrator in a bankruptcy is

far-reaching and they’re having to arrange refinancing at

named several weeks in advance. This means the right

gunpoint, so to speak – often involving big, personal

approach can be discussed ahead of the bankruptcy

commitments by directors or stakeholders, such as

proper. Following the ruling, any plans for a restart can get

guarantees. The worst-case scenario, bankruptcy, is a

underway immediately. The drawback is that this isn’t very

frequent outcome. I always say to my clients: call me

transparent, which means it can be difficult to get creditors

immediately if, instead of your usual account manager, you

and employers’ organisations on-side. This is a frequent

get a call from somebody in Special Asset Management.

occurrence in England though: the new business can be up and running just one hour after the bankruptcy ruling.

Of which networks are you a member and how

A prepack can avoid a downward spiral. Rumours of

do those networks affect the way you work?

bankruptcy are never good for the relaunch of a business.

It’s really important to be notified quickly of things like the

Between 6,000 and 7,000 bankruptcies are expected next

cancellation of a loan, refinancing, personal guarantees and

year in the Netherlands – and that’s not including the

so on. Many business owners are far too quick to throw in

self-employed without staff, because they are covered by

the towel. Only a handful of firms have the legal expertise to

debt restructuring laws. It’s more about the new, flexible

provide proper support with these credit issues. I think we

16

KAS Selections • November 2012


are just about the only firm with the required expertise that

properly and promptly, have the courage to follow your own

doesn’t have a permanent relationship with one of the

convictions and aren’t afraid of drastic measures. With

well-known banks.

hindsight, we only regret the things we didn’t do, never the things we did. So a company director who has run into

What activities do you undertake with regard

stormy weather mustn’t rely solely on the advice of his

to insolvency law?

bank’s Special Asset Management department, and he

I’ve always been involved with insolvency law. I act as a

mustn’t just plough on regardless with his regular lawyer. My

lawyer for our clients, primarily in finance-related disputes.

advice is: please seek out a true specialist, without delay.

I’ve also been appointed as an investigator by the Enterprise

This might sound odd, but even the bank will appreciate it

Section of the Amsterdam Court of Appeal and I’m

greatly: it indicates that you aren’t sticking your head in the

appointed as administrator by the district court. The

sand, but are taking the problem seriously.

‘highlight’ for me so far was my appointment in the Kroymans bankruptcy in 2009; the company employed

What conditions does your firm believe a

4,000 people and had a stock of more than 8,000 luxury

bankruptcy account must fulfil?

cars. I learned a lot from that case and I’m certain that you

The money that an administrator gathers together must be

can always identify a structure, a permanent thread, when a

carefully managed. In a bankruptcy, a supervisory judge is

company runs into difficulties. The recurring themes are

always appointed as well as an administrator, to supervise

overfinancing, restructuring and administrative doubts. A lot

the bankruptcy. In Amsterdam, the supervisory judge wants

of issues can be resolved if you analyse the situation

to check and approve each payment in advance. This calls

Office Fort Amsterdam

KAS Selections • November 2012

17


KAS BANK. You understand how an administrator operates and what he needs. There’s a continuous system of evaluation and quality assurance. We enter all our payments via KAS-Web, which is quick and easy. We have the support of a helpdesk if we experience technical problems. Sometimes, an administrator might have to make a payment to a creditor in an obscure foreign country for the first time, or a particular payment may have to be made outside the system. In those situations, help is very welcome. You always get to speak to the right person quickly, because the lines of communication are short, and I really appreciate that. for very specific support. First and foremost, an administrator must be able to pay quickly. Sometimes a lot

What do you think of KAS BANK’s payment

of small payments are involved. An instruction to make 800

system in terms of the separation of functions

payments ranging from €10 to €5,000 is not uncommon. For

and the extra validation stage before the

us, it’s important that no costs are charged for this. In small

court?

bankruptcies, or in debt restructuring measures, if costs are

When an administrator is appointed by the court, he has to

charged for this, the money intended for the creditors soon

open a bankruptcy account, in which the bankrupt funds are

gets swallowed up. Furthermore, if the balance is zero, no

administered and managed. We use the inputter/checker

costs are charged. This isn’t the case with a standard bank

model. The payment instruction is also authorised by the

account, where costs apply to each credit or debit, or to the

court in Amsterdam. Thus the court supervises payments

package.

made by the administrator. These people don’t work in the same building, so a separate structure had to be developed

Our bankruptcy practice group handles lots of bankruptcies

for this. KAS BANK came up with a bespoke system. I was

and, for many years, all the accounts have been held at

a member of the special committee that tested the beta versions and conveyed the special requests made by the court and the administrators. We found the working

Frits Kemp is a partner in the

relationship to be pleasant and informal.

Corporate Law practice group at

A bankruptcy account was recently confiscated at

Fort. Frits specialises in corporate

KAS BANK. Whether this should be permissible is a moot

law and insolvency law and advises

point. Your employee appreciated this fact, and initially

numerous large companies. He

refused to make the payment and cooperate with the

heads the growing and renowned

attachment. Interlocutory proceedings followed, which we

insolvency law practice at Fort.

won. This is an example of the good service KAS BANK

He regularly acts as an administrator in moratoria on

offers to administrators, its active involvement in coming up

payments and is often appointed administrator in major

with solutions and its expertise.

bankruptcies. As well as being highly adept at handling the legal aspects of a case, he also has a wealth of knowledge and experience of the commercial and economic issues involved.

18

KAS Selections • November 2012


The ‘Ultimate Forward’ Rate: could this be the final version? On 11 October, IPNederland organised the annual

Figure 1:

BeleggersBeraad ‘investor deliberation’ event. On the KAS BANK stand, our relationship and sales managers talked to many people interested in KAS BANK’s institutional services. Mark Schilstra, Managing Director of Client Management at KAS BANK, delivered a presentation on the impact of the introduction of the Ultimate Forward Rate (UFR). It is summarised here.

Consequences The UFR method proposed in May will have considerable

The Ministry of Social Affairs’ so-called ‘September

consequences. Firstly, it has implications for the funding

Package’ introduces the UFR as the new way of setting the

level and its volatility. As long-term commitments no longer

yield curve for determining the market value of pension

have to be valued at the market curve, but at a lower,

funds’ commitments. The introduction of the UFR will have

presumed, long-term average, funding levels will increase

the effect of artificially increasing the forward rate to an

considerably. The effect of this will be even greater for

ultimate one of 4.2%. This has direct implications for funding

pension funds with a young participant population, since the

levels, the hedge effectiveness of positions set up, the

commitments of these funds lie further in the future.

market and the generation conflict.

Because a stable long-term interest rate has been chosen, implementation of the UFR will also result in a decrease in

The Ultimate Forward Rate

the volatility of the funding level of pension funds with

Under the current Financial Assessment Framework

(predominantly) long-term commitments. Using a long-term

(Financieel Toetsingskader, FTK), nominal pension

average will also have a subduing effect, bringing the rate

commitments are valued at current market interest rates.

towards 4.2%.

Since pension commitments are generally long-term, the valuation is extremely sensitive to the long-term interest rate.

Applying the alternative discount curve will also result in a

Given the limited liquidity in the long segment of both

significantly shorter duration for the commitments. Because

government bonds and interest rate swaps, determining the

the method of setting the forward curve beyond the LLP is a

‘right’ curve for this segment of the market is no easy task.

self-fulfilling prophecy there is, in reality, no interest rate risk

In the Framework Memorandum on revising the financial

for durations of more than 20 years. Consequently, the

assessment framework for pensions (FTK) of May 2012, it

interest rate risk will be focused entirely on the LLP, and

was therefore decided to value commitments at the so-

interest rate sensitivity will actually become negative at the

called Ultimate Forward Rate.

15-year point. Due to the shorter duration and the absence of sensitivity to interest rates after the LLP, when hedging on

The first part of the UFR curve, from today until the Last

the basis of the UFR the interest hedge must be reduced for

Liquid Point (LLP, set at 20 years), was based on the swap

durations beyond the LLP. If, however, pension funds make

interest rates and matched the swap curve exactly. From the

the collective decision to reduce their interest hedge so as to

Last Liquid Point onwards, the 1-year forward rate is

get their duration match back in order, a large percentage of

extrapolated over 40 years by means of a Smith Wilson

the positions longer than 20 years will be unwound – which

algorithm, to a long-term average of 4.2%. The swap curve

will then cause a rise in the swap curve in the long segment.

is then reconstructed from this forward rate (see Figure 1).

(See Figure 2).

KAS Selections • November 2012

19


Figure 2: Base point for sensitivity of pension funds’

The introduction of the UFR places a greater strain on

commitments under swap curve (dark green) and UFR (light

solidarity than valuation at market value. The higher actuarial

green).

interest rate has a greater influence on the value of the pensions of younger people (cash flows have a longer duration), the UFR only takes effect after the LLP (cash flows up to 20 years are therefore completely unaffected), and a higher funding level could result in fewer pension cuts. The September Package The introduction of the September Package made the UFR

Under the UFR, however, the interest rate risk (S1) within the

a reality for pension funds. This UFR, however, is quite

Required Capital (VEV, Vereist Eigen Vermogen) would

different to the UFR proposed in May – which means many

actually rise. This is because S1 is defined as a relative

of the consequences discussed above no longer apply, or

interest rate shock applied to the official Term Structure of

have at least been mitigated.

Interest Rates including UFR, published by DNB. This would imply increasing the interest hedge. So pension funds must

The main difference is that market data are used to

strike a balance between basing their steering on economic

determine the UFR instead of the Smith Wilson extrapolation

risk (which is the crux of the matter), UFR funding level (the

method. This goes some way to solving the problem of the

official steering tool) and Required Capital (which constitutes

wholly ‘self-fulfilling’ approach to setting the forward curve

a parameter).

(eradicating the interest rate risk after 20 years). The basic premise is still that only market data will be used until the

The introduction of the UFR also has consequences for the

LLP is reached. For durations over 20 years, weightings are

generation conflict. The current pension system is based on

used to determine which portion will be set using market

the principle that all the participants in a pension fund pay

data and which using the UFR (4.2%). Beyond 20 years, the

the same contribution as a percentage of their pensionable

use of market data will dwindle in favour of the UFR. As

salary. This enforces solidarity between men and women,

provided for in the May package, the zero swap curve will

the highly-educated and the low-skilled, and young and old.

then be distilled based on this forward rate. The September method also has implications (albeit to a much lesser extent) for the funding level and its volatility. Because of the partial use of market data, although the funding level will increase and the volatility will decline, that increase and decline will be substantially less pronounced than under the method proposed in May. As regards hedge effectiveness, the use of the alternative discount curve results in a shorter duration for the commitments. However the effect is considerably more limited than in the May proposal because, for durations

Mark Schilstra, Managing Director Client Management

shortly after the LLP, substantial use of market data is still

KAS BANK at IPNederland BeleggersBeraad

made. Consequently, durations over 20 years will still be

20

KAS Selections • November 2012


New Clients sensitive to interest rates, albeit to a dwindling extent. The

Netherlands

(partial) use of market data prevents the interest rate risk

Stichtingpensioenfonds Urenco Nederland

being concentrated on the 20-year segment, and eliminates

Currency Overlay

the negative interest rate sensitivity of the 15-year segment. See Figure 3 for an illustration.

Germany SJS Markets Limited

Figure 3: Base point for sensitivity of pension funds’

Settlement and Custody Services

commitments under swap curve (red) and UFR (blue).

United Kingdom Simply Stockbroking Clearing, Settlement and Custody Services Valbury Capital Settlement, Custody and Securities Lending

The September UFR places less of a strain on solidarity, since the increase in funding levels is less pronounced than under the May version. Generally speaking, the UFR places a greater strain on solidarity between generations than the

Personnel notes

use of the swap curve. Sales & Business Development Conclusion The introduction of the UFR will entail rising complexity for

1 October Werner Schreiter, Product Sales Order Execution

pension funds. They must strike a balance between basing their steering on economic risk (the crux of the matter), UFR

Client Management

funding level (the official steering tool) and Required Capital

1 September Roy Braem,

(which constitutes a parameter). What’s more, until the end of 2012 they will still have to contend with the 3-month averaging of market interest rates. When a new Financial Assessment Framework is introduced in 2014, they may also be faced with the 12-month averaging of the funding

Account Manager Institutional Services 1 October Sandra Büttner and Leif Srocka, Relationship Managers Germany 1 October Kevin Bromet, Relationship Manager UK

level. Many of KAS BANK’s clients have been prompted by these developments to ask for the swap rate to be included in their reports, as well as the UFR interest rate that must be used for DNB purposes. This reflects the economic risk actually incurred. Your account manager will be happy to assist you with providing the right steering information for your particular situation – ensuring that you remain in control, even in this challenging environment.

KAS Selections • November 2012

21


Risk management conference On 1 October, KAS BANK organised a conference in

forward: independently or by seeking to join ranks or

partnership with APG, the FNV Bondgenoten trade union

cooperate with another company or party. Oerlemans

and Ortec Finance on pension fund risk management. The

argued the need for a public debate which focuses more on

conference was prompted by the publication of the

the long-term outlook for our pensions rather than on the

Investment Risk Guide, an initiative of FNV Bondgenoten.

current funding level. He feels this is the only way to retain

The Guide offers guidance to trustees on how to use risk

public support for pension provision. We must also focus

management instruments for their investments and

less on the asset allocation and far more on specific risks,

investment processes. With Sikko van Katwijk, Board

such as interest rate and country risk.

Member KAS BANK in the chair, five speakers explored a number of aspects of the ‘sources of risk’ method

Oerlemans, himself a trustee, concluded his talk with the

described in the Guide.

optimistic message that managing might appear to have become a more complex task but, in essence, it still boils

Alwin Oerlemans, Director of Institutional Business

down to the same thing: making good use of the available

Development at APG, talked about the instruments of good

steering instruments and deploying the best possible management skills. José Suarez Menendez, a Pensions Advisor at FNV Bondgenoten, then explained the steps detailed in the Risk/

governance in relation to the increased focus on risks and risk management. Trustees must ensure that the fund is organised along lines allowing effective risk management. They have a number of steering instruments with which to do this at their disposal: the investment, contribution and

Return Profile chapter. The basic principle is allocation by

indexation policy and, in the current market, the question of

sources of risk rather than asset classes. Various aspects,

whether or not cuts to pensions have to be made. To ensure

including the parameters for a fund’s risk appetite and risk

efficient management, their agenda must be determined by

capacity, must be determined prior to the ALM. Menendez

these steering instruments (and organisational issues),

emphasised that the management must also consider

rather than a plethora of operational issues. It is vital to

whether the pension mandate formulated by the fund is

communicate with participants in order to get them on-side

realistic. Is the risk commensurate with the pension promise

with the risk policy.

to the participants? Once the risk appetite and risk budget have been

Pension funds take considered risks to increase their returns

determined, these assumptions can be incorporated in the

– but participants are not keen on uncertainty. To create

ALM. Although the risk budget is apportioned by sources of

certainty and to keep their pension promise, pension funds

risk rather than assets in the ALM, this requires the input of

will therefore have to reflect on how they wish to move

the Board of Trustees. The fund then names the sources of

22

KAS Selections • November 2012


risk, based on clear criteria. Properly substantiated

as the basis for the ALM. The purpose of holistic risk

expectations with regard to the return, mobility and

management is to manage financial risks in a consistent way

diversification effects of the sources of risk must also be

and to improve the quality of management. The risks in

stated, followed by choices as to which risks are acceptable

question are strategic ones and the risks in the performance

and which are not, and for what purpose. All of this forms

of the investment policy. For a young pension fund, those

the input for the ALM and the basis for the mandate to the

risks may differ from the risks run by an old fund.

asset manager. Good management information is then

Risk management can be improved by setting clear

needed so as to revise the assumptions where necessary.

guidelines for the risk budget and risk mix during the ALM

Ideally, monitoring and reporting will be handled by a third

phase. Some of the advantages of the sources of risk

party rather than the asset manager itself, so that it is always

method are: the management has a greater understanding

possible to ‘go back to the source’ when deciding on the

of the risks, complex products can be analysed to identify

choice of particular risks and sources of risk and to answer

the basic elements, and the method enables consistent

the question: why I am willing to take this risk?

implementation and awarding of mandates as well as consistent monitoring throughout each phase of the

Next, Loranne van Lieshout, Senior Consultant Pension Risk

process. However, the risk mix is an addition to, rather than

Management at Ortec Finance, discussed sources of risk

a replacement for, the asset mix. Additional, unquantifiable risks must still be monitored – a process that relies on proper consultation between the people involved in the ALM, the asset manager and the custodian, while the concept is being developed. During the implementation phase, the agreed strategy must be properly executed. Van Lieshout demonstrated how a risk mix is preferable to an asset mix when determining the investment mix. This is because the risk mix illustrates which source is responsible

KAS Selections • November 2012

23


for which part of, for instance, the funding level risk,

this need not always be regarded immediately as an explicit

affording a better understanding of the risks than the asset

breach.

mix. It is also important to use the risk measure (volatility, VaR, Expected Shortfall) consistently throughout the ALM

The focus of the ALM is on market risks, in terms of both

process.

mismatch and investments. The same applies to the

At present, choices are often made during the investment

resulting mandates. Mandates must be clear about ‘known

portfolio construction phase which alter the risk profile or

unknowns’ and how to handle them, which is why

alter the spread across sources of risk. Because of this, the

parameters must be defined in the mandate. A list of

asset mix must be checked constantly against the risk

permitted instruments, for example, is a generic and

budget and the risk mix. Finally, all the parameters must be

effective parameter. Additional, restrictive conditions are also

recorded in the mandate and actively monitored.

necessary to rule out exposure via another route, such as securities lending or reinvesting collateral. A maximum

Pieter van Foreest, Head of Client Risk Management at APG

portfolio leverage can also be stipulated. The counterparty

Investment Services, then described the parameters for

risk and bankruptcy risk can be limited by restricting the share of particular counterparties, sectors or countries to a certain percentage of the total exposure. Finally, valuation models must be used to identify the link between how the sources of risk are translated and the changes in value in the balance sheet headings. These models thus play a crucial role in every phase of the investment process, from ALM to implementation and reporting. To ensure consistency across the different phases of the investment process, the valuation details must be

formulating mandates for sources of risk. The key

explicitly recorded in a valuation manual.

requirement when formulating mandates is that the risk policy and risk management must be included in the fund’s

In his talk on reporting and monitoring, Ard de Wit, Head of

mission. After all, the mission is the point of departure for the

Institutional Risk Management at KAS BANK, explored three

mandate to be drawn up and the benchmarks for sources of risk, target returns for sources of risk, risk budgets and ranges and, finally, the parameters. However, it is virtually impossible to take account of all the risks in the risk budget. In the sources of risk model, the risk budget is determined by setting targets for key risk measures (absolute and relative). To prevent short-term overreactions, ranges can be used (soft and hard limits) along with the related escalation and other guidelines. The limit structure has been designed to enhance the transparency and awareness of sources of

key components: performance, risk measurement and

risks. Limits are set on both sides of the target and (because

compliance. When reporting on a fund’s performance, it is

they serve as warning signals) must be breached with a

important above all to compare the risks realised and results

pre-defined likelihood. In this way, when limits are exceeded,

achieved with a clear and carefully chosen benchmark. This

24

KAS Selections • November 2012


is because the results of the measurement depend heavily

A participant then expressed his concerns about the

on the benchmark chosen. Consistency between the ALM,

younger generation if the interest rate – an important

implementation and monitoring is also crucial. Compliance

parameter of the source of risk model – continues to fall.

processes must be geared heavily towards monitoring the

Suarez Menendez shared his concern. He pointed out that a

mandate in respect to risk realised versus mandated risk.

Board of Trustees must constantly ask itself whether the

Back testing is another important component of the

fund’s target return is still realistic, in the current

monitoring process. After all, using a particular model

circumstances. If it is not, the board can decide to return its

without regularly reviewing the assumptions is in itself a form

mandate to the fund’s partners.

of risk. De Wit concluded with five key points. A pension fund must

The model presented comprises two dominant sources of

keep a careful eye on its pooled investments and illiquid

risk: the interest rate and marketable securities. That’s

positions. Furthermore, as well as making a considered

nothing new in itself, one member of the audience argued.

choice in favour of a particular risk measure and risk model,

He wondered whether the value of the model lies primarily in

it must use assumptions and models in a consistent way, to

the preliminary discussions about the assumptions made

ensure meticulous reporting and monitoring.

when setting the risk budget. Van Lieshout agreed, so she advised always using different methods for examining the

The concluding panel discussion was chaired by

assumptions. Oerlemans also reiterated that the added

Kris Wulteputte, Chief Risk Officer at KAS BANK. One of the

value of the model lies chiefly in the fact that it elucidates the choices in favour of particular sources of risk. New sources of risk may arise over time as a result of the diversification of the investment portfolio, and the board must constantly be mindful of this. The final question was related to this. Risks themselves vary over time. How does the model handle this and how does the regulator, DNB, judge this? Suarez Menendez explained that DNB always ‘judges’ the pension fund’s board of

questions was whether maintaining a certain amount of

trustees by the result actually achieved. Therefore, trustees

accounting leeway is also a source of risk. Oerlemans felt

must always be able to explain to all stakeholders ‘in

that was indeed an important point, which touches upon the

retrospect’ how and why certain risks were taken to achieve

issue of distribution between young and old. The fund must

the fund’s objective. This ‘coupling piece’ between

always be guided by its mission. After all, the regulator has a

determining the risks to be taken in advance and

different perspective on the fund’s capital than the fund

subsequently being able to explain why this was done was

itself. Furthermore, opting for a certain amount of accounting

previously lacking. The source of risk model helps raise

leeway affects how supportive participants are with regard to

awareness of the risks.

the risks taken. De Wit concurred with this. As a trustee of KAS BANK’s pension fund, he prefers to be guided by economic principles rather than regulations – which can, after all, change often. Van Foreest commented that the ‘regulation risk’ ought to be a matter for public debate.

KAS Selections • November 2012

25


Global Custody Network News Europe

Outside Europe

Germany – Eurex Clearing plans new clearing system for

Brazil – Tax exemption for certain instruments

derivatives Eurex Clearing is planning to launch a new clearing system for derivatives clearing in Q4 2013. The ‘new clearing architecture’ will ensure more flexibility for the introduction of new product types, asset classes and services. Hungary – Financial Transaction Tax applicable to

securities and derivatives transactions The Hungarian Government has published a proposal to modify the law on the Financial Transaction Tax (FTT) that was approved in July 2012. The government extends the

The Brazilian Government has amended the tax benefit

FTT to securities and derivatives transactions as of

characteristics for certain instruments. Foreign investors not

1 January 2014. The FTT will not apply to foreign banks and

domiciled in tax haven countries, investing in CRI (mortgage-

other financial institutions during 2013. It will be paid by

backed securities), infrastructure debentures and investment

banks based on the clients’ transactions. The proposal is

funds of such instruments will be subject to 0% withholding

currently under analysis by all market participants and its

tax if the instruments meet the necessary characteristics as

content may still be changed during Parliament’s discussion

described in Law 12,431.

and approval process.

Law 12,431 also determines that the issuer of the CRI and debenture is subject to a penalty of 20% of the amount

Austria – Go-live of the CCP.CEE cash market clearing

raised if the issuer does not comply with the Law.

system is postponed

Clients are advised to consult their brokers and investment managers in the local market to determine whether a debenture complies with Law 12,431 requirements and whether they can therefore benefit from the tax exemptions described above. Nigeria – NSE introduces market makers

The Nigerian Stock Exchange (NSE) has begun a Market Making Program in the Nigerian Stock Market. Initially the CCP.A (the Central Counterparty Austria) has postponed

market making has been introduced for 25 blue-chip shares

implementation of the new CCP.CEE cash market clearing

selected from the banking and consumer goods

system until 2013. The OeKB (CDS) will announce the new

sectors. Price swings for the selected shares are also

go-live date by the end of 2012. Because of the postponed

relaxed to allow movements up to 10% a day, from the

implementation, the new amendments and fees to the

current 5%.

CCP.A clearing rules will come into force later.

26

KAS Selections • November 2012


Improving returns in securities lending Borrowing and lending securities improves the liquidity of

participating parties. Sadly, the global financial crisis has

the financial markets and is essential for these markets to

done enormous damage to confidence in the financial

function more efficiently. Securities lending has great

markets, resulting in a dwindling securities lending market.

benefits for both institutional investors and broker-dealers.

The parties involved have been quick to accept and implement risk-mitigating changes, agreements and stricter

Institutional investors generally appoint their global custodian

controls. As a result of more stringent legislation and

as their securities lending agent. In this role, the custodian

regulations, such as Basel III, Dodd-Frank and the regulation

not only eases their administrative workload but also

of short-selling in the European Union, the market has

provides institutional investors with access to the market of

ultimately emerged from this test of confidence stronger,

potential borrowers, such as market counterparties and

safer and more transparent.

broker-dealers. This is a way for institutional investors to make more profit from their ‘dormant’ securities portfolio.

The result is growing demand for equities and bonds around

However, securities lending is also important for broker-

the world, which is translating into higher turnover on the

dealers, particularly borrowing securities so as to avoid

securities lending market. For you, this means that the risk/

non-settlements. KAS BANK is a longstanding provider of

return balance of your investment portfolio can once again

securities lending services to its professional clients (both

be carefully assessed. Our specialised Securities Lending

end investors and intermediaries). What sets us apart from

traders can estimate for you what return you could generate

other providers of these services is our pure play model and

on your portfolio through securities lending. Contact your

our Principal Agent programme, whereby KAS BANK

relationship manager for more information.

assumes the counterparty risk. The Securities Lending market has traditionally been founded on a great deal of mutual trust between the

KAS Selections • November 2012

27


EU Short Selling Regulation The EU Short Selling Regulation has come into effect in

An exemption to this regulation is provided for the activities

the European Union as of 1 November 2012. According to

of market makers, since market makers often need to take

the European Securities and Markets Authority ‘the

short positions to perform their crucial role of providing

objectives of this short selling legislative framework are to

liquidity. As a prerequisite, the activity must be notified to the

increase transparency of short positions held by investors

competent authority and the respective transaction must be

in certain EU securities, reduce settlement and other risks

rendered as part of a market maker activity. This exemption

linked with uncovered or naked short selling, and create a

may be extended to primary dealers in the future.

harmonised framework for coordinated action at the European level.’ In this article we will discuss what the EU

Funds (or portfolios under management) managed by the

Short Selling Regulation comprises, what the disclosure

same management entity are not expected to report net

requirements are and what the buy-in regulations will be.

short positions, as at individual fund level only the calculation of the net short position for each particular issuer is required

Regulatory framework

to take place.

The EU Short Selling Regulation has been introduced as a European regulation and therefore has immediate effect. The

What is a ‘short sale’?

regulation is directly applicable in all member states and

A short sale is defined as any sale of a share or debt

does not have to be implemented in national legislation.

instrument which the seller does not own at the time of

The regulation lays down a common regulatory framework

entering into the agreement to sell, including where the seller

and ensures greater coordination and consistency between

has borrowed or agreed to borrow the share or debt

member states in case actions have to be taken in

instrument for delivery at settlement. A short sale is only

exceptional situations. The rules will lead to a higher degree

allowed if at the time of the short sale the transaction is

of transparency due to the reporting obligation, will increase

capable of being settled when due.

the role of the European Securities and Markets Authority (ESMA) and will impose a virtual ban on certain Credit

Scope of the EU Short Selling Regulation

Default Swap transactions.

The financial instruments concerned by the net short position notification and disclosure requirements are:

The regulation consists of the following items: 1. Requirement for firms to disclose net short positions in EU-listed shares and EU sovereign debt. 2. Restriction on uncovered short selling of EU-listed shares and EU sovereign debt. 3. Prohibition of uncovered credit default swaps (‘CDS’) in

1. Shares admitted to trading on a European regulated market or a multilateral trading facility (MTF). Shares that are traded principally on a trading venue outside the EU but are also traded in the EU are exempt. The predominant trading venue is decided by the largest volume in the previous 24 months.

EU sovereign debt, which does not serve to hedge

2. Sovereign debt issued by a sovereign issuer.

against exposure to the underlying sovereign debt.

3. CDS on sovereign debt of a sovereign issuer.

4. Requirement for central counterparties that provide clearing services for shares, to ensure that there are

With respect to shares, the regulation requires that a list of

adequate arrangements for buy-in of securities when

exempted shares is published by ESMA on its website on

there is a failure to settle a transaction within four

the basis of the information provided by national competent

business days after the day on which settlement is due.

authorities. ESMA will update this list every two years, but

5. Creation of additional measures that can be taken by national regulators and the ESMA.

28

KAS Selections • November 2012

the list will also be updated by national competent authorities. If a share is not mentioned on that list and is


admitted for trading on a regulated market in the European

the buy-in of shares where there is a failure to settle a

Union or is traded on an MTF in the European Union, it is

transaction within four business days after the day on which

subject to the requirements of the EU Short Selling

settlement is due. Where buy-in is not possible, the short

Regulation. ESMA has published a list of shares admitted to

seller must pay to the purchaser an amount based on the

trading on a regulated market in the European Union

value of the shares to be delivered at the delivery date, plus

(http://mifiddatabase.esma.europa.eu/) which identifies the

an amount for losses incurred by the buyer as a result of the

relevant competent authority for each share for the purpose

settlement failure. The requirements relating to the buy-in

of the regulation.

procedures apply only in relation to the short sale fo shares but not to the short sale of sovereign debt instruments.

Disclosure requirements

The regulation also provides that central counterparties that

The regulation also requires firms to disclose net short

provide clearing services for shares will be required to

positions in EU listed shares as follows:

impose daily fines in cases of non-settlement. The daily fines

• A net short position of 0.2% or more of the issued share

shall be sufficiently high to act as a deterrent to natural or

capital of a company whose shares are admitted to

legal persons failing to settle.

trading on a regulated market. Any 0.1% increment over 0.2% in the net short position must also be disclosed to

Conclusion

the relevant competent authority (i.e. 0.3%, 0.4% and

Market participants will need to reassess their investment

0.5%).

strategies utilising short sales of EU listed shares and EU

• A net short position of 0.5% of the issued share capital of a company whose shares are admitted to trading on a

sovereign debt. For the most part, the EU Short Selling Regulation is not retroactive.

regulated market or MTF must be reported publically to the market. Any 0.1% increment over 0.5% in the net

Market participants will need to ensure that systems are in

short position must also be reported to the market. All

place which will calculate net short positions in EU shares

disclosures must include the identity of the person

and EU sovereign debt at midnight of the trading day and

holding the short position.

make reports to the relevant regulators no later than 15:30 of the following trading day.

Timing of disclosure of a net short position Calculations of a net short position must be made by

To prevent any net short positions, market participants can

midnight at the end of the trading day. The notification or

utilise the borrowing possibilities that are facilitated through

disclosure shall be made not later than 15:30 on the

the KAS BANK lending desk.

following trading day. All times are calculated according to the time in the EU Member State of the relevant competent authority to whom the relevant position must be notified. The regulation sets out the format of the information to be provided in the notifications to the regulators and public disclosures. This means that all EU Member States have a harmonised form of disclosure. Buy-in procedures and fines for late settlement Central counterparties providing clearing services for shares must ensure that there are automatic procedures in place for

KAS Selections • November 2012

29


German Depotbank well-prepared for future challenges

Words from Wiesbaden The challenges Depotbanks face have rarely been

Let’s talk about the German market. What are

greater than nowadays. The wave of regulations puts the

the recent topics with which you have been

industry under enormous pressure. But at the same time

dealing?

these challenges represent a great opportunity for all

Schuhbeck: In 2010 the German Federal Financial

market participants. Günter Schuhbeck, Branch Manager

Supervisory Authority (BaFin) announced new regulations

KAS BANK N.V. German Branch and Anja Maiberger,

with its circular ‘Depotbankrundschreiben’. As one of the

Head of Sales, Institutional Custody and Depotbank

first market participants KAS BANK was able to meet the

Services, illustrate the characteristics of the German

requirements of these regulations completely.

market and what the key will be for future success.

According to BaFin statistics the German Depotbank market urrently consists of 50 potential competitors.

The Depotbank is a registered credit institute

A consolidation of these Depotbanks has been forecast by

and has two different functions in the German

experts for some years, but has still not begun. It is

fund market. Could you please explain these

questionable whether this consolidation will happen at all.

briefly?

Thus a new service sector has been created due to the

Schuhbeck: All activities and tasks of a German Depotbank

shifting of services and the tendency of outsourcing

can be summarised into two main categories. Firstly, the

services.

custodian activities which comprise for example the execution of payments and the delivery of securities, tax

Maiberger: Regarding EU regulations, AIFMD is one of the

reclaims and proxy voting. And secondly, the activities

hot topics and has the potential to become a lucrative new

required by the German Investment Act (Investmentgesetz).

business segment for KAS BANK in Germany. For closed

These functions might include the subscription and

end funds for example, we can offer services similar to our

redemption of shares (of the fund), authorisation of

control functions in our current Depotbank. In comparison to

transactions (for example obtaining loans, etc.) and above

the UK and the Netherlands, we envisage a lesser impact of

all control functions (e.g. post-trade compliance checks,

the AIFMD from an operational perspective; in many ways

check on security holdings and account balances, valuation

the new regulation is close to the set-up already in place in

and calculation of the NAV, attention for shareholders’

Germany.

interests). Why is the control function of a German Depotbank so unique? Schuhbeck: Because it is a German speciality and of the utmost importance; no other leading fund market has comparable control demands. All are based on the principle of investor protection. To set up a fund in Germany, not only an asset manager is required but also a KAG and a Depotbank. Each entity is regulated to ensure that each party is carrying out its duties correctly and the investor’s assets must remain separate, similar to a trust set-up.

30

KAS Selections • November 2012


and standardising our processes, our service range, our Branch Manager Günter

service quality and our external reporting to boost our

Schuhbeck joined the KAS BANK

custody and Depotbank business.

German Branch bringing with him thirty years’ experience from

In your opinion, who will be successful in the

CACEIS Bank Germany and its

German Depotbank market in the next few

predecessors HypoVereinsbank AG

years?

and Byerische Vereinsbank AG. In

Maiberger: Those Depotbanks will prevail which are able to

his previous position at CACEIS Bank, Schuhbeck was

adapt to a continuously changing regulatory environment,

responsible for Sales & Relationship Management for

and which at the same time anticipate their clients’ needs

Depotbank clients. Before that he was responsible for

and deliver tailor-made services and sophisticated reporting

Depotbank Services at HypoVereinsbank.

e.g. Performance and Risk Reporting to support them. Schuhbeck: We believe, and that’s what we are focusing on,

The Depotbank in Wiesbaden is a young

that Depotbanks which offer very individual and flexible

representative within the industry. Can you

services of a high quality will be in a winning position. The

please give us a brief overview of your

willingness for new products and to strike new paths will

business and what is your main focus at the

differentiate the market participants from each other. In the

moment?

long term a market-adjusted service portfolio will be decisive

Schuhbeck: We set up our German Depotbank business in

and not the price.

June 2010 and our team currently consists of six employees. Anja joined KAS BANK in the summer as a highly experienced sales manager for institutional custody and

Anja Maiberger joined the

Depotbank services. We work on the same IT platforms as

KAS BANK Wiesbaden team on

our colleagues in Amsterdam (Mainframe, SimCorp, etc.). As

1 August 2012 as Head of Sales,

I mentioned previously, we have met the requirements of the

Institutional Custody and

Depotbankrundschreiben right from the start. So we have

Depotbank Services. Prior to

been able to focus on establishing a high standard regarding

KAS BANK she worked for several

our technical infrastructure as well for our knowledgeable

years for the Bank of New York

staff. Both the BaFin and our external auditor confirmed our

Mellon in Frankfurt. In her previous position as Director

excellent set-up.

Business Development at BoNY she was responsible for the Nordics and later for the German market with a

Maiberger: Obviously we are a relatively small Depotbank in

focus on financial institutions, insurance companies and

comparison to our competitors. But our aim is not to

banks. Maiberger previously worked as Senior

become a price leader in the German market. Our focus is to

Relationship Manager for Transaction Banking–Custody

position ourselves as a recognised specialised niche player.

Solutions and Depotbank at Dresdner Bank.

Our flexibility is currently our main asset. And as a proven modern Depotbank we feel fit for future challenges. At the same time we work continuously on improving, optimising

KAS Selections • November 2012

31


NETHERLANDS

NETHERLANDS

UNITED KINGDOM

KAS BANK AMSTERDAM P.O. Box 24001 1000 DB Amsterdam The Netherlands Spuistraat 172 1012 VT Amsterdam The Netherlands T: +31 20 557 59 11

GERMANY

KAS BANK LONDON 5th Floor 10 Old Broad Street London EC2N 1AA United Kingdom T: +44 20 7153 36 00

KAS BANK WIESBADEN Biebricher Allee 2 65187 Wiesbaden Germany T: +49 611 1865 3800

www.kasbank.com


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