Welcome to Banking News, the KPMG Ireland Quarterly Banking Newsletter, which has been designed to bring together useful insights and developments that are relevant to the banking and capital markets industry.
Economic outlook
The ESRI’s Quarterly Economic Commentary projects domestic demand to increase by just 2.2% in 2023, a significant reduction on 2022 growth. The Institute expects cost of living pressures to remain elevated in 2023 with headline inflation remaining above 7% for the full year. In 2023, the unemployment rate is still set to continue to fall to a near historical low of 4.3 per cent.
The UK economy is experiencing a rather mild but drawn-out recession with GDP growth expected to fall by 1.3% in 2023, KPMG’s latest Global Economic Outlook has found. Inflation is set to fall from a peak of over 11% in October, to under 4% by the end of 2023 and reach its 2% target by mid-2024. A weaker pound and the rising energy costs have resulted in reduced consumer spending power. This poses a great challenge to businesses as they are adapting to the changing habits of consumers.
According to the ECB Economic Bulletin, economic growth in the euro area slowed to 0.3% in the third quarter of 2022. High inflation and tighter financing conditions are dampening spending and production by reducing real household incomes and pushing up costs for firms. Weaker growth and soaring inflation have deteriorated the outlook for Europe. On the flip side, employment increased by 0.3% in the third quarter, and unemployment hit a new historical low of 6.5% in October.
Soaring energy prices, resulting in steep inflation, are expected to sink growth. The OECD Economic Outlook, forecasts that world growth will decline to 2.2% in 2023 and bounce back to a relatively modest 2.7% in 2024. Asia will be the main engine of growth in 2023 and 2024, with the IMF now forecasting Chinese growth of 4.4% in 2023, whereas Europe, North America and South America will see very low growth. Higher inflation and lower growth are the hefty price that the global economy is paying for Russia’s war against Ukraine. Central banks around the world are increasing interest rates to curb inflation - a strategy that is starting to pay off. The financial sector appears to have weathered these recent shocks relatively well as banks continue to work down their non-performing loans. However, the OECD notes that the sector is set to face some structural problems.
KPMG updates
KPMG recently published Banking and Capital Markets thought leadership on several topics, linked below.
- Mortgage Measures Framework Review: Exploring the potential impact for lenders
- Recession, restructuring and resilience in EMA: KPMG’s Europe, Middle East and Africa region leaders share their advice on restructuring in a recessionary environment.
- KPMG 2022 Banking CEO Outlook: Banking leaders are focused on interest rate and reputational risks
- SSM supervisory priorities 2023–2025: What lies ahead for European banks?
- Regulatory Environment: Concerns from regulators remain
- Non-performing loans: Early signs point towards an increase in 2023
- 2023 EU-wide stress test: the future looks hybrid; What challenges do banks face as they prepare for the next exercise?
- Transactions overview: European loan sales market in a nutshell
- Navigating European distressed markets: European debt sales 2022
Central Bank of Ireland news
Central Bank identifies calculation errors in Deposit Guarantee Scheme contributions: The Central Bank has apologised to dozens of member institutions participating in the Deposit Guarantee Scheme after it identified errors in its calculations of institutions’ contributions. The errors resulted in undercharging and overcharging, mainly of credit unions, totalling c.€253,000 over a two-year period (2019-2021). Once the assessment is completed in February 2023 the Central Bank will identify next steps to regularise the position of the affected institutions.
Targeted communications with mortgage borrowers can help to improve uptake of refinancing opportunities: Adjusting notifications to mortgage holders to include clearer information on refinancing opportunities led to a significant increase in refinancing activity. The findings from the recent Central Bank research demonstrate the value of leveraging behavioural insights to inform policy design and to address issues in financial product markets. The Central Bank will incorporate the findings of this research into its review of the Consumer Protection Code.
ESB set to raise rates by 50 basis points: The ECB is set to raise interest rates by 50 basis points in both February and March and will continue to do so in the months after, governing council member Klaas Knot said in an interview in mid-January. Knot said that it was “too early to tell” if the ECB could slow down the pace of rate hikes by the summer.
Spotlight: Retail banking review
The retail banking sector, a fundamental element to the functioning economy has saw unprecedented changes over the last 15 years. Due to amalgamations, closures and foreign actors leaving the Irish retail market, the number of banks serving the sector has reduced significantly from 12 to 3. In addition, the repercussions of the Great Financial Crisis and the repaid deployment of financial technology driven by the COVID-19 pandemic has also had great effects on the sector.
As a result of recent departures and changes in retail banking, the Department of Finance undertook a broad Retail Banking Review, which made recommendations to the Department, the CBI and retail banking sector participants, including the three remaining Irish Pillar banks. The recommendations developed address topical issues, and aid stakeholders to navigate further change in a controlled, fair, and equitable way.
The Review team found that the sector will continue to be fragmented, with consumers obtaining products from a range of providers, including traditional banks, digital banks, and non-banks. Despite recent departures, sufficient competition will exist within the sector in the medium term. The CBI and the CCPC should co-ordinate to facilitate new entries and An Post/ Credit Unions should continue to expand their product offerings.
The Review team recommend banks set out standards via customer charters and outline which ombudsman deals with complaints relating to firms passporting into Ireland. Banks could voluntarily implement actions if they are not incorporated into the CP Code this year.
To help create a level playing field for the traditional banks, remuneration restrictions should be revisited. The report recommends removing the bans on variable pay (capping it at €20k and subject to ‘super tax’ of 89%) and standard employee benefits, as well as Bank of Ireland’s €500k pay limit for any individual employee.
Some of the key recommendations made to the retail banking sector are as follows:
- Consider how best to expand its products/services so that it provides a competitive offering to consumers and SMEs to help in the transition to a lower carbon future.
- Seek to preserve consumers’ and business’ access to cash services at December 2022 levels.
- Review existing mortgage product suite to identify opportunities to enhance and expand it for customer benefit, in particular to help reduce borrower's overall cost of credit.
- Increase its levels of collaboration, wherever possible, to reduce costs and improve/retain customer service levels (e.g. Shared Banking Hubs.)
- Review strategies and delivery models for SME credit making amendments where required to ensure good customer service standards and to facilitate effective engagement by SMEs with skilled staff.
- Work in conjunction with the Institute of Bankers (IOB) to consider the establishment a Financial Services Skills Framework.
- Set out and publish customer charters ahead of CBI instruction.
Spotlight: Mortgage Measures Framework Review
In 2015, the Central Bank of Ireland (“CBI”) introduced mortgage measures with the objective of strengthening the resilience of borrowers, lenders, and the economy overall. These mortgage measures use Loan-to-Value (“LTV”) and Loan-to-Income (“LTI”) limits to place an outer boundary on the size of borrowers’ mortgage debt used to purchase residential properties providing services that meet their unique needs.
Following the CBI’s annual review of the Mortgage Measure Framework in 2022, the CBI is retaining its dual instrument approach using both LTV and LTI limits. The LTI will remain as the income-based limit due to its clarity and comprehensive nature. The LTV will remain as the collateral-based limit. The LTI limit will continue to set a limit on the amount of money consumers can borrow relative to their gross income and the LTV limit will continue to set a minimum deposit amount needed by borrowers to complete the purchase of a residential property.
First-Time Buyers (“FTBs”) can expect change, as the LTI limit is increasing from 3.5 times to 4 times annual gross income. The LTV limit will remain at 90%. The scope of the definition for FTBs is also being enhanced, allowing FTBs who are obtaining an equity release / top-up on their home to avail of the FTB limits, provided the property remains their primary residence. Borrowers facing a change in circumstances (e.g., divorce or personal insolvency) will also be considered FTBs when taking out a new mortgage where they no longer have an interest in the previous property.
Other outcomes of the review include the LTV limit for Second and Subsequent Buyers (“SSB”) is increasing from 80% to 90%, whilst the LTI remains unchanged at 3.5 times gross income. Furthermore, no changes were made to the mortgage measures for Buy to Let (“BLT”) borrowers where a 70% LTV limit will continue to apply. Lastly, following the change in the FTB LTI limit and SSB LTV limit, the proportion of lending above the revised LTI and LTV limits will now apply at the level of the borrower type rather than the individual limit. In this regard, 15% of FTB lending, 15% of SSB lending and 10% of BTL lending can take place above the revised LTI and LTV limits for each borrower type.
These changes to mortgage measures announced by the CBI should theoretically increase the opportunity base for lenders. However, the current macro-economic climate coupled with the short lead in time before these changes take effect will pose challenges. This creates an additional layer of potential complexity for lenders in reviewing and revising their own mortgage lending practices.
The review recommends lenders consider a range of different approaches to manage and cope with the latest CBI amendments to mortgage measures. Some recommendations include potential changes to business strategy, assessing integration implications for any recent residential mortgage portfolio acquisitions, downstream implications for end-to-end credit journey transformation and maintaining lenders’ own lending standards despite the revised measures.
How KPMG can help
KPMG has a large team of professionals with extensive knowledge and expertise in Financial Services, Banking, Aviation Finance, Insurance and Asset Management. KPMG Ireland can leverage a network of multidisciplinary professionals, stretching across Europe and beyond. Supported by this global network, KPMG Ireland can provide a broad range of support, advice and guidance on how to address the challenges you face.
If you have any queries on the topics covered in this issue of Banking News, please contact Owen Lewis, Head of Banking and Capital Markets. We'd be delighted to hear from you.
Owen Lewis
Partner, Head of Management Consulting, Head of Banking & Capital Markets
KPMG in Ireland