Good morning, ladies and gentlemen. Thank you for holding and welcome to the ABN AMRO Q3 2021 analyst and investor call. At this moment, all participants are in listen-only mode. After the presentation, there will be an opportunity to ask questions. I would now like to hand over the conference to Robert Swaak, CEO of ABN AMRO. Please go ahead, sir.
Thank you, good morning, everyone. Welcome to ABN AMRO's Q3 results. I'm joined by Lars Kramer, our CFO, and as always, Tanja Cuppen, our CRO. I will take you through the progress of our strategic agenda, and then Lars will take you through our third quarter results in a bit more detail. After which, Tanja will update you on impairment developments in our loan portfolio and on capital. Let's turn to our third quarter results on slide two. Over the last quarter, we did see the economy rebounding. At the start of Q3, most restrictions were lifted and society continued to take a significant step towards normalization. Now, this did have a modest positive effect on our results. Fee income was helped by higher credit card payment volumes, loan growth is picking up, and we again released impairments this quarter.
The low interest rate environment remains a challenge for us. To counter the margin pressure on deposits, we started charging negative interest rates on balances above EUR 150,000 starting July 1. Cost saving programs are on track, as are investments in the foundation for the future bank. The wind down of the CIB non-core portfolio is now over 85% complete. Last, but not least, our capital ratios remain very strong. We are in a constructive dialogue with the regulator on potential share buybacks following our full year 2021 results. Now turning to our longer term strategic ambitions on slide 3. I am very pleased that ABN AMRO was chosen as best mortgage provider by Dutch Intermediaries for combining expert advice with fast and convenient services to basic fundamentals.
Over the years, we've been working hard to improve the customer experience, and we now see these awards show that we're well underway. This quarter, we made further progress on our strategic agenda. Our entrepreneur and enterprise proposition went live in Germany. In the area of sustainability, we incentivize homeowners to improve the energy label of their home to label B by offering a discount on their mortgage. We take inclusivity serious, and we've set up a team now to identify and remove any barriers our clients encounter. This team is currently working on improvements to our service for female entrepreneurs. First in the Netherlands is also the introduction of cash withdrawals from ATMs using only a mobile phone.
Now, the wind down of our CIB non-core is running well ahead of plan, and I expect less than EUR 2 billion in loans to remain at year-end. Turning to slide 4, let me update you on ESG client assets. Now, our strategy around sustainability has always been and will continue to be built on long-term ambitions in the areas of climate change, the circular economy, and social impact. We have set a number of targets which are linked to these ambitions. Here, I'll highlight our progress on our ESG client asset target. We target a volume of client loans and investments in sustainable assets of around 1/3 of total by 2024. Since 2014, we actively focus on offering clients the option to invest in ESG assets. Our clients are increasingly looking for societal return in addition to financial return.
We invested in new products, reporting tools, staff education, resulting in a consistent increase in client mandates. We made sustainable investing the default option for new clients in 2019. In Q3, our ESG clients' assets have grown to EUR 39 billion, corresponding to 26% of total, and this is measured in line with SFDR definitions. We expect growth to accelerate further as ESG is becoming increasingly important in all of our investment decisions. Let me now turn to the new organizational setup that we announced a few weeks ago. We aim to bring convenience into the daily lives of our clients and expertise when it matters. Now, this is a guiding principle of our strategy. To anchor this firmly within the organization, we are simplifying our own organizational structure to three units serving specific client segments.
All three client units offer clients convenience, mainly through digital channels, combined with in-depth sector, product, and sustainability expertise that ABN AMRO is known for. Wealth management and corporate banking will be mainly expertise-driven. Our digital capabilities and services will be centralized within personal and business banking, as this unit is primarily convenience-driven. Now going forward, there will be a single executive board which will foster a collective responsibility. I am convinced that the new organizational setup is an important step in achieving our strategic ambitions. I expect a more efficient organization as we remove duplication in management and further centralize the development of the IT infrastructure. Before I hand over to Lars, allow me a few words on the economy. Now during the third quarter, we saw a further economic rebound as restrictions were lifted for the most part.
Recently, a few measures had to be reimposed as intensive care units are slowly filling up again now autumn has arrived. Current measures allow most businesses to operate normally, though the leisure sector, of course, has some restrictions in opening hours. We do expect bankruptcies, which are currently at a historical low level, to increase to more normal levels now support measures have ended. Now this is expected to lead to a minor increase in unemployment. However, the Dutch unemployment rate is expected to remain well below the European average. Our economic bureau expects a continuation of low rates, as we expect both inflation and longer-dated interest rates to come down during next year. The housing market will continue to remain very strong. Prices are expected to increase by about 15% this year and again by about 10% next year.
Transaction levels are impacted by the lack of supply, and this contributes to the sharp increase in house prices. Let me turn it over to Lars now to discuss our third quarter results.
Thanks, Robert. Just looking at slide 7. I'll briefly highlight the main results of the bank before going into some further detail. Our net profit was EUR 343 million, and if I exclude the non-core, then we get to about EUR 406 million. The operating income was stable, but with sizable incidental items in both Q2 and Q3. This quarter, we took a provision to compensate clients with revolving consumer credit of about EUR 217 million. EUR 174 million of which was booked in the interest income and the remainder in the cost line. Operating expenses, in addition, increased due to higher regulatory levies and AML costs. Again, we had limited new impairments, leading to a net release for the quarter. The non-core wind down is also progressing well, with both loans and RWAs decreasing further this quarter.
Now turning to loan volume developments for the core bank, please take a look at page 8. Here we have mortgage volume was slightly up for the quarter and the size of the overall Dutch mortgage market increased a bit further. Given our 15% market share in Q3, we still managed to increase our mortgage portfolio. Lending activity and commercial banking increased as government support ended. In CIB core, we showed strong growth this quarter, both in corporate lending and financial institutions. The declining trend in consumer lending is also in line with the overall Dutch markets. Now turning to take a look at deposits on page 9. As Robert's already said, starting first of July, the threshold of charging negative rates was lowered from EUR 500,000 to EUR 150,000.
Nevertheless, we've had limited outflows, with deposits actually increasing during Q3. The threshold will be lowered further to 100K on January 1, 2022, and this will impact a further EUR 9 billion of volumes. At that point, we'll have around 50% of our deposits, which is around 5% of all clients, who will be being charged negative rates. For those who are being charged, the rate is -50 basis points, though for some financial counterparties, the rate is higher. Now turning to our net interest income. NII was impacted by incidentals, mainly the compensation scheme for revolving consumer credits. On a clean basis, NII increased EUR 14 million quarter-on-quarter. The lower threshold for charging negative rates contributed EUR 27 million to NII, and mortgage prepayment penalties were high in the previous quarter and increased further as clients locked in low rates.
I think it's worthwhile noting that at some point, these prepayment penalties will return to normal levels, but the timing is difficult to predict. This quarter also, the margin pressure on deposits amounted to around EUR 23 million. The increase in interest rates actually had very limited benefits as short-dated rates didn't move very much. Our outlook remains cautious given that our own economics bureau expects rates for longer maturities to come down again next year. This quarter, there was some pressure on front book margins of especially our retail products. For now, this impact is limited. However, we are keeping a close eye on these developments. We did make progress on achieving the TLTRO threshold and actually remain quite optimistic that we'll reach the threshold by December. Moving to slide 10 to look at fees and other income.
During the quarter, we saw an improvement in credit card usage and payment fees. The credit card usage in our domestic market is actually now back to about pre-COVID levels. The transaction volume outside of Europe is still limited due to travel restrictions. Clearing continued a strong performance as trading volumes across global financial markets remain high. The higher stock markets also helped fee income and private banking. Under other income for the core bank, it was again boosted by positive equity participation and venture fund revaluations. Together, these delivered about EUR 56 million of the other income in Q3. Turning to costs on slide 12. Expenses were slightly up this quarter, and this was mainly from the rising AML costs and the higher regulatory levies.
The AML costs is expected to peak this year, and we are continuing to increase FTEs in order to really try to finalize the remediation by the end of next year. I do just wanna emphasize that despite this increase in costs, we do still expect our costs for the year to come in at the EUR 5.3 billion guidance without the restructuring of the Guardian penalty. That for the longer term, 2024, our cost savings are also on track. That year to date, we've already booked about EUR 100 million of the cost savings that we anticipated in our plan. I'll leave it at that, and I'll hand over to Tanja to give us some insights into impairments and capital.
Thank you, Lars. We are now at page 13. For the third consecutive quarter, we showed a net release of impairments, EUR 12 million for this quarter. The inflow in Stage 3 remains limited, most of which is related to a number of individual oil and gas in the non-core portfolio. In Commercial Banking, model updates and improved economic outlook led to releases. The total management overlay amounts to EUR 255 million, following a small net addition this quarter. Around half of the overlay is COVID-related, reflecting uncertainty as government support measures end. For the full financial year 2021, cost of risk should end around breakeven. As Robert mentioned, we expect impairments in Commercial Banking to rise as government support measures ended.
I consider the tail risk of the non-core portfolio well covered, though we do expect limited impairments will materialize in the coming quarters. Looking at the right-hand chart, the difference in risk profile of the non-core portfolio versus the core bank is evident. Although non-core is now down to 1% of total exposure, non-core still constitutes over 10% of stage three exposure. I expect to update you on a revised cost of risk target for the core bank in the coming quarter. Now turning to slide 14 on our capital position. Our capital position remains strong with a Basel III capital ratio at 17.8%. The decline compared to previous quarter mainly reflects an RWA increase of EUR 3.3 billion due to a net increase in loans and a model update.
We took notice of the Basel IV proposal of the European Commission, published on October 27. In line with the industry view, we consider these proposals on balance marginally positive. Given that for us, the output-floored RWAs are only marginally different from the conventional-constrained IRB RWAs, there is no benefit from the phase-in period. We will effectively move straight into a fully loaded Basel IV on implementation, expected by January 2025 at the earliest. With that, I want to hand back to Robert.
Thanks, Tanja. Just turning to slide 15 then, where we revisit our long-term targets, the and the outlook for 2021, which clearly will be impacted by some of the incidentals we've talked about. We managed to further grow our mortgage portfolio. I think that's very clear, and that's also showing up in slide 15, which shows our financial targets. The quality of our mortgage products and service is acknowledged in this quarter with a number of awards, and that's thanks to our hard work. We are now well-placed in this very competitive market. On cost, I'm confident we can achieve our 2024 target. For this year, we expect a cost base of EUR 5.3 billion, as Lars had already alluded to, excluding the AML settlement and restructuring costs.
With a large part of the non-core assets now wound down, the risk profile of the bank has improved. Over the full year, we expect impairments of around zero. Our capital position continues to be strong, and with our Q4 results, we will update you on the threshold for share buybacks and dividends. As I mentioned at the start, we are in a constructive dialogue with the regulator on potential share buybacks. Let me ask the operator now to open the call for questions.
Thank you, sir. Ladies and gentlemen, we'll start the question and answer session now. If you have a question or remark, please press star one on your telephone. Go ahead, please. Ladies and gentlemen, as we're running short in time, please limit your questions to two. Thank you. For questions or remarks, please press star one. The first question is coming from Mr. Benoît Pétrarque, Kepler Cheuvreux. Please go ahead.
Yes, good morning. Benoît Pétrarque from Kepler Cheuvreux. Two questions, one on capital, one on loan growth. So first of all, on capital, you know, you have a 100 basis points buffer versus your buyback threshold. You know, if you put that in euro terms, that's about EUR 1.2 billion. I was wondering if you could help us to understand all your constructive dialogue with ECB on buyback next steps. You know, trying to understand if you will be pitching potentially for a 100 basis points share buyback, or you have a different view on that. A lso, I was wondering if you also started the discussion with the Dutch government on a potential share buyback.
Also finally on a third point on that, whether you still consider to lower the threshold of currently 15% to potentially a lower figure, if this is still something you have in mind. Sorry, that's a bit of a long question, but that's the first one on capital. The second one on loan growth, really, clearly on TLTRO benefit, things seems to go in the right direction. What about 2022? Do you also expect, you know, beyond the probably more short-term effect of trying to get this benefit from TLTRO three, do you expect also more long-term the long-term loan growth to be also back on your Dutch business, especially thinking about 2022, if you expect a positive loan growth there?
Thank you.
Benoît, thank you. Thanks for the question. Let me take your questions on the, on capital. O n the 100 basis points between 15% and 16%, clearly what we've indicated, as we get closer to that 15% threshold, which we are around about 14.16%, that would mean that we would start our conversations around potential share buybacks. Now, that is exactly what we're now doing. We're having that conversation, as we speak. Hence, we indicated as such, in the presentation just now. Are we then also talking about a potential reconsideration of that threshold? We also indicated, as we consider our conversations on share buybacks, we would indeed take a look at the threshold.
That again is predicated on the fact that we had identified factors leading up to that threshold of 15%. That also forms part of our dialogue. As we said, indeed, a constructive dialogue with the regulator. As to your question on NLFI, you'll appreciate that as we go through this process, we have to have a conversation with all of our stakeholders, including NLFI. I think it's fair to say we also have a constructive dialogue with them as well. In terms of TLTRO, the question, yes, we are. Well, we're more increasingly confident that we'll get to recognizing the benefits of TLTRO, and that is indeed predicated on the volume growth that we've seen in this quarter. Which clearly is a sign. It actually signals a number of things.
It signals ABN AMRO in the market and our activities in the market in which we're operating right now. It also is indicative of a Dutch economy that's beginning to open up, and therefore, driving volume growth, both in terms of the corporate client loans and but also, I should say, in the CIB areas where we've seen some growth continuing. Now, our GDP forecasts for 2022 still will remain at around, I believe, 3 percentage point. For all intents and purposes, if we continue to see the economies opening up the way we have seen over this quarter, what you're actually seeing is ABN AMRO being well-positioned on the back of some of the strategic choices that we've made.
I'm not gonna provide you any guidance in that sense, but more from a generic point of view. Let me just leave it at that.
Great. Thank you very much.
The next question is coming from Mr. Omar Fall, Barclays. Please go ahead.
Hi there. Thanks for taking my question. I've just got a few questions entirely on costs on OpEx. Where are we on the cost elements you highlighted at the last Investor Day? At the time, you'd said that we'd see around EUR 100 million of savings in 2021, which, you know, you're highlighting you've achieved. Then you said EUR 300 million in 2022, 2023. As we're close to 2022 and you clearly seem to be slightly ahead, would you expect most of that 300 to come through in 2022, or is it a bit more back-end loaded? Then on the strategic investments of EUR 300 million and restructuring costs of EUR 150 that you targeted, how much of that has actually happened?
Lastly, if you could just confirm that you still plan the 15% FTE decrease, because since the plan was given, FTEs have actually gone up by 4% of the group. Sorry for all of those, but it's just the 2024 cost target is a long way from now, so it'd be great to get some building blocks for our modeling.
Let me take your last question on the 15%, and I'll ask Lars to talk about the various components of our cost and CapEx. On the 15%, we've guided that we go to a 15% FTE reduction by 2024, and that still stands on the basis of the measures that we're taking. Lars, maybe on the components of cost.
Yeah. I would say for 2021, yes, we have materially locked in the EUR 100 million, and that's also actually enabled us to spend a little bit more on the AML remediation. Instead of then pushing the costs up overall for the year, we've been able to compensate some of that saving. What I would say for next year is that the AML cost base will be roughly the same as this year. Then we will start seeing the tailing off in probably 2023, 2024. That's the aim. In terms of the strategic investments, we've set aside about EUR 100 million a year on strategic investments, and those that money is being well spent and definitely being deployed, and that will continue.
In terms of the restructuring costs, you know, where we're trying to cut EUR 700 million out by 2024, again, yes, we've made a step change this year. We will again see a step change next year. I do caution that because of the AML, where we still have one more year of cleanup to do, I would say a chunk of the savings will probably come more towards the back end, rather than we see the EUR 300 million you're talking about coming through next year.
I think that covered your question.
Yeah. Just as a very quick follow-up. Of the FTE declines, the targeted 15%, can you give a sense of how much of that is from-
AML related stuff, because I guess we know how much is coming from the non-core exit, but just to get a sense of what's then core, what's then, AML, which is a bit more back-end loaded. Thanks.
Yeah. Let me just reiterate that 15% and the composition of which we'll get to when it's applicable.
Okay. Thank you.
All right. Thanks for your question.
The next question is from Mr. Stefan Nedialkov, Citi. Please go ahead. Your line is open now.
Yeah. Hi, guys. Good morning. Just a couple of questions on my end. In terms of fees, are you reiterating the EUR 400 million per quarter going forward, given the better level of activity that we're seeing? Secondly, on Basel IV, you do mention that the final proposals are marginally positive. Can you quantify how marginal, how marginally positive that is? Is that included now in the 16% Basel IV that you reported? Thank you.
All right. Thank you. Thanks for the two questions. Yeah, on fees, we'll just reiterate the EUR 400 million guidance that we've given quarter on quarter. I would remind you that we've come off lower numbers as we're navigating a COVID-19 timeframe. As economies continue to open up, we do see that EUR 400 million in terms of fee guidance to continue to hold. On Basel IV, I'll ask Tanja to comment.
Yes, sir. As said, indeed, the impact we expect to be marginally positive. We see some components that are definitely positive, but are also ones that have a slight negative impact. We don't have the exact details yet, so we are doing the calculations right now, so I cannot give you a more precise guidance at this stage. Therefore, also in the around 60% that we are disclosing right now, the new proposals are not included in there. It's based on the same methodology that we have been using over the past quarters to be consistent there as well.
Thank you, Robert. Thank you, Tanja.
All right, thanks, Stefan Nedialkov. Bye.
The next question is coming from Miss Kiri Vijayarajah, HSBC. Please go ahead.
Yes, good morning, everyone. Just a couple of questions on the CIB, if I may. So your cost base on the CIB non-core, you know, as guided, that's coming down nicely. But the cost in the CIB core seem to be creeping up again. I guess not in a major way, but I just wondered if we could have some color on what's happening there, what investments you're making there, and how much is coming from maybe an increase in the variable comp pool there. Just to try and understand on the clearing business, you know, whenever you have a good quarter for revenue, say, does that benefit or the delta mainly come through on the net interest income line, or do we see on some of the other revenue lines?
Just trying to understand, how that clearing business feeds through into some of the individual revenue line volatility that we're seeing in recent quarters. Those are my two questions. Thank you.
Thanks for the questions. Let me just take the clearing one, and Lars, I'll ask you to comment on the cost levels of CIB. Clearing is mostly coming through fees and commissions lines, irrespective of what quarter we're in. Maybe, Lars, for you to comment on CIB.
Yeah. Look, the increase is not coming from variable remuneration. I can state that In terms of if you look at it quarter two on quarter three, it's not really materially that different. I mean, there's a little bit more going into personnel costs. We're obviously building some teams in various areas, also in Northwest Europe to specifically focus on the enterprise and entrepreneur area. So that is somewhere where we are seeing some personnel expenditure increases. I think in terms of the other expenses which are up by EUR 1 million quarter-on-quarter, I think that's a little bit of rounding here or there. There's nothing particular that we are spending extra money on.
Okay. All right. Thanks, guys.
Thank you.
The next question is coming from Miss Giulia Aurora Miotto, Morgan Stanley. Please go ahead.
Yes. Hi, good morning. Thank you for taking my questions. Two, if I may. On NII, of course, I hear your guidance for 2021. If I think about NII evolution sequentially, do you think we could say that we have bottomed or not yet? When do you expect to see any positive impact from the recent move in the five-year swaps? That's my first question on NII. Then, more strategically on potential M&A targets. I understand you've been looking at this now for a few months. Is there any update on opportunities that you've seen or any updated thoughts on your inorganic growth strategy? Thank you.
Lars, if I could ask you to comment on the five-year. I'll take the M&A. Indeed, we've been looking at, as I've talked about in previous quarters, we've been looking at the potential for any M&A. I would just reiterate that any M&A that we would consider to do would be in the areas of bolt-ons. The M&A has to fit very much so within our current business, our geographical footprint. As I said before, it has to be accretive in terms of the choices we have made as a bank, the strategic directions that we've made as a bank. We've talked about previously about private banking. I've also mentioned previously activities that could serve as a feeder to private banking.
These are all areas that we would potentially look at. So that gives you a little bit of color around, as I've said before, around how we are considering M&A at this point. Marcel, you were replicating.
Yeah. On the NII, in terms of giving guidance for next year, we're not gonna give guidance for next year at this point. What I can sort of reiterate is that what we have seen for most of this year, which is the pressure on the deposits, and we've come, we talk about the EUR 20 million a quarter on average, that will continue into the next quarter. It's likely a little bit less. The unwinding of about EUR 10 million will come through next quarter as well. We are starting to see in terms of the pressure on the retail margins on the front book, both in terms of mortgages as well as in terms of consumer, you know, that is continuing as well, and that's something we are, you know, really watching quite carefully.
We've been able to pass on some price increases over the past quarter, but again, you know, with the swap curve increasing, you can only get so much in terms of margin increase. In terms of the prepayment penalties, I think this is another quite unpredictable area because definitely mortgage refinancing continues, and with lower rates for longer, you know, that seems to be a bit open-ended at the moment. We do see seasonality in that. If anything, at least in Q1, we expect that you have the normal lower prepayment levels. That would certainly be some step down. Then the negative pricing is the other one. We've been able to get quite a positive impact on the negative pricing from the EUR 150k already this quarter.
That will obviously continue into next quarter. Having already signaled the drop to 100,000, which will be effective Q1, that will give a little bit of a positive tailwind. Again, what we don't know is how much deposit outflow there will be as a result of this when it takes effect because we are actually being, let's say, the most penal on our customers because we charge this just on an aggregated basis, whereas my understanding is other banks do this at account level. This could mean that there is some shift in deposits away from us to the other banks.
Does that answer your question?
Yes. Thank you. Sorry, I was on mute. Thanks.
All right. Thank you.
The next question is from Mr. Johann Scholtz, Morningstar. Please go ahead.
Good morning, guys. Thank you very much for taking my question. Two from my side. Firstly, in terms of the management overlay on the provisioning side, you did indicate that there was a slight expansion in the management overlay. Just maybe a little bit more color, is that structural in nature trends that you're seeing, or is it this is more of a technical change? Secondly, just on capital return, would you say that the dialogue that you're having with the regulators is really the only impediment that remains before you in a position to return capital?
that there's no internal impediment in the sense that you know you want to preserve capital for potential worsening of COVID or anything like that. Thank you very much.
Let me take the one on capital, and Tanja, I'll ask you to comment on the management overlays. Just to kind of reiterate, we go through a process in the bank. There's a governance process we go through when deciding on share buybacks. One of the steps also clearly on share buybacks is approval for the regulator. T hat is known around share buybacks. As I said, let me just reiterate that the conversation with the regulator is constructive on that end. In terms of your other questions, we have very much highlighted the various components that went into that 200 basis point threshold from the 13% to the 15%.
We've signaled that we're now north of that 15%, hence our dialogue and hence our conversations around share buybacks. Part of that conversation, as I answered earlier to an earlier question, is about recalibration of that 15%. Now both on the outcome of the share buyback and the recalibration on that 15%, we expect to come back to all of you at full year.
Okay.
Tanja.
Yeah, I'll take the question on the management overlays. Actually, indeed, a net addition. There are some smaller releases related to the management overlays that we took for COVID. The additions are related to, well, mainly to two aspects. One is a model update or an update of the definition of default that we will implement in Q4 and already have included in our
Provisioning calculations. That is one that will disappear again next quarter. The other one, the other part is related to a wind down portfolio in commercial banking. Well, getting more into detail, we have basically concluded that our models not fully capture the developments there and therefore taken a management overlay. This one will of course also disappear over time, but it will take a bit longer, dependent on the speed of run off of this portfolio. Nothing structural. I would say mostly technical.
Perfect. Thank you very much, guys.
All right. Thank you.
The next question is coming from Miss Anke Reingen, RBC. Please go ahead.
Thank you very much for taking my questions. I just wondered if you can maybe go back to your commentary about the NII on the EUR 20 million headwind and the EUR 10 million non-core. I'm just a bit surprised given long rates have moved up and as well the non-core has come down in absolute volume, so why that wouldn't look better? On the capital, you indicated there will be some headwinds in the next quarter. You can maybe just give us a bit more detail about the RWA inflation. I think that's also, if I'm not wrong, this Q4 headwind to capital, but maybe I've got the quarter wrong here. Thank you very much.
Do you wanna expand on the NII?
Yeah. In terms of the EUR 20 million, I think if you see this quarter, we were at about EUR 23 million. There is definitely a bit of an improvement expected next quarter to just below EUR 20 million. I mean, that's the long end of the curve increasing in pricing. I t's also quite volatile. I t's been up before and it's come all the way back down again. In terms of our investment positioning, it's pretty much across the curve. It's not as if the bulk of it is at the long end and is immediately sensitized to rate increases. W e really do need to see the short end coming up to sort of have a material impact in terms of where our investments are positioned in terms of replication.
You're right on the non-core. Clearly, this is coming off faster and the EUR 10 million I think is going to be around EUR 8 million next quarter. There is going to be a reduction. But it's not an improvement. But again, it's on average, we're still looking at this EUR 20 million and EUR 10 million over a period of time.
Tanja
Okay. Yeah, shall I take the question on capital? Actually it is indeed related to the credit risk RWAs. You've seen in this quarter, credit risk RWAs went up. It's related also to, apart from business development and business growth that we have been talking about also to a model update. The impact is actually EUR 2.4 billion. This is in line with what we guided before. I think we guided EUR 5 billion for the year. We do expect an additional step in the next quarter. This has to do with the fact that we are updating our models and bring them all in line with the guidelines for internal rating-based models by the end of this year.
into next year, we do expect that there will be some further inflation into credit risk RWAs because, ahead of Basel IV, we will move some models to more or less advanced approaches, and that will increase RWAs a bit, but of course will reduce the difference between Basel III and Basel IV RWAs.
Thank you. If I may just follow up on your comment on the interest rate sensitivity. You're saying that the short end would need to go up to really make a difference. How sensitive do you think your deposit charging is to a rise in short rates? Thank you.
You know, in terms of a rise in short rates up to zero, there is quite some sensitivity. I think, beyond zero, that is where, you know, we're able to manage it, probably a bit better in terms of timing. The fact that we are pricing it below zero, and if, you know, those short rates really do start improving back to zero and above, we would have to track reasonably quickly on that front.
Okay. Thank you.
The next question is coming from Mr. Robin van den Broek, Mediobanca. Please go ahead.
Yes. Good morning, everybody. Thank you for taking my questions. I would like to dwell a little bit deeper into the credit risk RWAs, because I think at the beginning of the year, you indeed indicated that you were expecting roughly EUR 9 billion of RWA impacts, which probably is the EUR 5 billion you just mentioned, and the EUR 4 billion coming from the mortgage floors from the Dutch Central Bank. If I take the EUR 2.4 billion out, that basically leaves another EUR 6.5 billion to come in Q4, which would raise your RWAs towards EUR 117 billion. In previous presentations, you've shown that your Basel III RWAs per year-end 2021 would be less than 10% of your Basel IV level.
Of course, less than 10% is basically gives you a very wide range. Am I right in assuming that the residual Basel IV inflation is more likely to be around 5%, given the building blocks I've just mentioned? That's the first question. The second question is more about, yeah, I guess the political situation in the Netherlands. I mean, I guess you would prefer to do a direct placement with the government when it comes to buybacks. Yeah, I mean, the Dutch. There is no Dutch government at the moment, only the demissionary one.
The information process doesn't seem like it's speedy enough to have something in place even when you come out with the Q4 results. How could this affect your thinking? I mean, if the Dutch government can't make a decision on participating directly in a buyback, the liquidity of your stock is not that great to do a very large buyback program that would be suggested by us. If your 15% threshold would go to 14.5 on the back of the AML settlement, that would imply quite a hefty buyback potential. Doing such a thing, giving you liquidity, might constrain you in a different way.
I was just wondering if you could give your thinking around that. Thank you.
Yeah, thanks. Thanks for the questions. Let me take the political situation in the Netherlands and the associated consequences for buybacks. Tanja, maybe for you to comment on the first part of the question. L ook, we are discussing right now our thoughts on our buyback program. We are identifying and debating the various components of the buyback program. We do that within the bank, and clearly we do that with the regulator. We're in conversation, as I also said, with NLFI as a direct representative. I can't really talk for the government, whether they're amenable or not. What I can say is that the conversations that we're having also with NLFI are constructive.
We first have to decide which direction of travel we choose, and then we'll get to the next steps in the conversations. We're keeping both the regulator and the NLFI very close in our conversations. Let me just leave it at that. Again, for any questions as to how the government reacts, it's really up to the government. Then Tanja.
That was the question on the credit risk RWAs. Indeed, you were right on the different components. I didn't mention in my previous response the mortgage floor. The mortgage floor is now final. The DNB has announced this, and this will kick in in January 2022. It is estimated to be around EUR 5 billion. The difference between the headroom under Basel III and Basel IV, we have guided that this is less than 10%. Of course, we will update the guidance for the new information that has come in on Basel IV, where we have said this will be marginally positive for us.
That will reduce the difference as well. What the exact difference will be, that is to be determined. Of course, we will continue to work to refine our guidance in that respect. I cannot give a new number today.
Okay. Then maybe on Q4, I mean, should we still expect maybe an impact from a sale-leaseback of that quarter's or?
Well, we're working hard to complete that transaction before year-end.
Yeah. I think just on this, it's key to note that if we do book something, please, 'cause you're also updating your models, do factor in that this would be a taxable event as well as that under IFRS 16, we'd have to book some lease liabilities as well. That would come off any sort of book profit. Please factor that in as well.
I'm sorry, the capital gain itself is also subject to taxes?
Yes.
Okay. Why is that? Because I thought normally in the Netherlands, capital gains are not subject to taxes.
Yeah. I mean, on this transaction, it would be.
Okay. Thanks. That's clear.
All right. Thank you.
Ladies and gentlemen, if there are any additional questions or remarks, please press star one. Go ahead, please. There is a follow-up question from Mr. Benoît Pétrarque, Kepler Cheuvreux. Please go ahead.
Yes. Thanks for taking my questions. Just to follow up on, first one on the charging of negative rates. You know, the discussion between charging it on an aggregate basis or per account basis, you know, what are your thoughts on that? Do you think you could move towards a per account charging? O n the inflation we see now, on a broad basis in several countries, is your EUR 4.7 billion properly capturing, let's say, the current inflation we see? Or do you see maybe headwinds from inflation on your EUR 4.7 billion figure? That would be my two follow-up questions. Thank you.
Thanks, Benoît. On your first question, the aggregate is what we apply, and that's what we will continue to apply. We think that is better. On 47, the guidance we've given, that stands.
Great. Thank you.
All right.
The last follow-up question is coming from Stefan Nedialkov, Citi. Please go ahead.
Thank you. Quick follow-up. On the Basel IV RWA inflation being less than 10% as of year-end, is that before or after the DNB floor? It looks like DNB is in place from the first of January, but I just wasn't sure whether you're gonna book it officially in Q4 or in Q1.
Tanja, do you wanna?
Yeah. Actually, I would have to look at the numbers. It's probably around that number, but I have to come back to you on that one because whether it's just above or just below the 10% by year-end, I need to check. We previously anticipated indeed that the DNB floor would come in still this year. It's now as of January, and we haven't decided yet when we will book it. That depends also a little bit on the guidance there.
Okay.
I don't have the exact response for you here.
Based on the previous assumption of the DNB floor coming in in 2021, you were always going to be at 10%.
Yeah.
Less. Okay.
That is correct.
Thank you.
There are no further questions. Please continue.
Okay. Well, then, thank you all for your questions. As always, this will then conclude the analyst call. Look, really look forward to speaking to many of you over the next few weeks. For now, see you later. Thank you.
Ladies and gentlemen, this concludes this ABN AMRO event call. You may now disconnect your line. Thank you.