Good morning. This is Mark, your operator. Welcoming you to the ING's 3Q 2022 Conference Call. Now, I will turn the conference call over to Steven van Rijswijk, Chief Executive Officer of ING Group. Let me first say that today's comments may include forward-looking statements, such as statements, including regarding future developments in our business, expectations for our future financial performance, and any statement not involving historical facts. Actual results may differ materially from those projected in any forward-looking statement. Discussion of factors that may cause actual results to differ from those in any forward-looking statements is contained in our public filings, including our most recent annual report on Form 20-F, filed with the United States Securities and Exchange Commission and our press release as posted on our website today.
Furthermore, nothing in today's comments constitutes an offer to sell or a solicitation of an offer to buy any securities. Good morning, Steven. Over to you.
Thank you, operator. Good morning, and welcome to our Q3 2022 results call. I hope you're all well. As usual, I'm joined by our CFO, Tanate Phutrakul and our CRO, Ljiljana Čortan. I'm pleased to take you through today's presentation. After that, we will take your questions. It has become a recurring theme that we operate in a challenging environment, and also recurring is that we perform well under these circumstances and with our strong positioning and strategy. I'm confident that we will continue to do so. That confidence applies to a successful execution of our strategy, as well as delivering healthy financial results. I'm proud to see our people making an effort every day to create a superior experience for our customers, and to support the transition to a more sustainable society.
The results of these efforts were again visible this quarter in more primary customers, a leading NPS position in more countries, as well as more sustainable deals and volumes mobilized. On our financial results, the accelerating NII momentum is a clear tailwind, while fee income provided proved to be resilient. Expenses were well contained despite the increasing inflationary pressure from indexation and contained investments to realize our strategy. Loan growth continued with good growth in Wholesale Banking and a slightly slower pace in retail. Risk costs reflect our prudent approach of taking management actions to incorporate the uncertainty posed by the economic environment, and we continue to operate with a low Stage 3 ratio and with confidence in the quality of our loan book.
Finally, our capital position remains strong, which allows us to take another step in returning capital to our shareholders, as we announced today a distribution of EUR 1.5 Billion. Separately, although not a Q3 event, I would like to address the ECB decision to change the TLTRO program. As a result of changed conditions, we have had to unwind our TLTRO-related derivative position. The impact of this action, adjusted for TLTRO benefit until 23 November 2022, will lead to a negative impact on pre-tax profits of around EUR 350 million in the fourth quarter. Now before we go into the quarterly figures, I will spend some time on our strategic priorities, our outlook in the current environment, and the return on capital.
Slide three clearly shows how the world around us has continued to change since our investor update in June, fueled by growing political, geopolitical instability and high energy prices. Interest rates are forecasted to remain at a much higher level, while inflationary expectations for 2022 and 2023 have increased significantly before being expected to taper off in 2024. Not surprisingly, this impacts the GDP outlook, which now includes a recession, although the expected economic contraction is still relatively modest. Overall, the impact of the energy shock is cushioned by two main factors. First, labor markets have been tightening following the pandemic. Employers can be reluctant to lay off workers, while those losing their jobs can quickly find a new one. Overall, this lowers the risk of high unemployment.
Secondly, while consumer confidence has been impacted, governments have been quick to offer large support packages in this cost of living crisis and to help both customers and companies cope with the high energy prices. Although bankruptcies can be expected to go up from the low levels seen during the pandemic, the impact of difficult external conditions on corporate sentiment is still relatively mild. For the near term, uncertainty remains high, and it is hard to predict how things will evolve. We will manage through these times, while we will also keep our eye on the longer term on executing our strategy, which brings me to the next slide. Slide four shows a selection of actions we have taken and the results for our two strategic priorities, a superior customer experience and sustainability.
In our retail, we introduced new products and solutions with a focus on digital-only, mobile-first to offer that superior experience that we strive for. For example, with a new account in Spain, co-created with customers and offering instant digital onboarding. On the business side, we co-created an app that can be used in stores for easy access to contactless payments to be piloted by a large retail chain in the Netherlands. The hard work of our people in improving the experience for our customers has yielded good results. The share of customers using only mobile went up by four percentage points, now reaching 57%. In seven out of our 10 retail countries, we had a leading NPS position, a step towards our ambition to have the highest NPS score in all 10 retail countries.
This supported further growth of our primary customer base, because we added 139,000 primary customers this quarter, bringing the total to 14.4 million. On sustainability, in retail, we introduced the eco mortgage in two more countries, Germany and Italy, supporting our customers' transition to more sustainable homes. We will continue to expand our green offering products, product offering in line with our target to have a green alternative for all our key retail products by 2025. In September, we published our 2022 climate report. We have now updated the intermediate 2030 targets for the sub-sectors covered by Terra. In wholesale banking, our colleagues' efforts on financing the transition have paid off, with both volume mobilized and the number of sustainability deals growing compared to last year.
As we continue to focus on executing our long-term strategy, our near-term financial results are affected by the changing world around us. To start with the rate environment on slide five, that shows the positive development for ING, and we have mentioned before we will benefit from high interest rates, with the benefit coming in over time as our replicating book gets reinvested against higher rates, and also depending on the speed of pass-through. During our investor update, we gave you an estimate based on the sensitivity of our retail eurozone book with an illustrative instant 50% pass-through scenario, which already gave insight in the potential upside. As we have seen the curve steepening since then, the upside has gone up. The updated sensitivities includes an illustrative gradual pass-through scenario to reflect the increased asymmetry with the replicating result in an environment with such rapidly rising interest rates.
The sensitivity analysis clearly shows the increased NII tailwind for the coming years. Already now, after years of downward pressure from negative rates, the boost in liability NII is visible in our results. On to slide six. First, on how the outside world affects our cost base, and the impact of the increasing inflation rates actually doesn't need much explanation. We've talked about it before, that impacts our staff costs this quarter, mainly through indexation. As an example, the legally required bi-monthly indexation in Belgium has so far driven a staff cost thereby more than 7%, and that's the number you can't fully offset anymore with all the good actions taken in Belgium to restructure the service model and change the footprint.
Next to indexation, in several countries we announced voluntary compensation to help our people cope with the rising energy prices and these one-off amounts will be booked in the coming quarters. As mentioned, we are also continuing to invest in our long-term performance and digitalizing customer journeys and also marketing campaigns to ensure we keep increasing the number of primary customers as the base of future success. Going forward, we steer to keep cost growth below the inflation rate. On to asset quality. Why I'm addressing the topic here is because we generally see thematic concerns from the outside world increasing as the economic environment becomes more challenging. I want to emphasize that we don't always share these concerns. We are confident on our asset quality, and our conviction is underpinned by a solid risk management framework and proven by our strong track record.
To highlight some characteristics of our loan book that support our confidence, our retail lending is primarily mortgages with only a small consumer lending book. We operate at low LTVs, though our main focus is on affordability of the loan. To illustrate, our largest mortgage book is in the Netherlands, where 94% of the book has an LTV below 97.5%, and in general, home ownership is concentrated on higher income groups, and the same group, which is more likely to have savings and less likely to be affected by layoffs. During the global financial crisis, we did not have material losses in this book, and with a better risk profile now, we have no reason to believe it will be different in the current situation.
On our loan book to companies, the majority is to large companies with a focus on investment grade. These companies are not immune to economic challenges. However, they generally do have larger buffers to withstand economic headwinds. Moving to slide seven. Over the past years, we have built a strong track record of delivering attractive yield to our shareholders. Going forward, ING continues to be a good investment case with consistent strategy execution, income growth, well-contained expenses and strong asset quality, and combined with our strong capital position, we are in a position to return capital to our shareholders.
I'm pleased that today we have announced another step in converging to our targeted CET1 ratio of around 12.5% with a EUR 1.5 billion distribution. We aim to execute as much as possible in 2022 via a share buyback, with any remainder to be distributed in cash on 16 January 2023. Now let me take you through our second quarter results, starting on slide nine. Our pre-provision profit was up almost 90% year-on-year and 9% quarter-on-quarter. I'm happy we realized another very good quarter in today's markets, and as mentioned in NII, we see the impact from the improved yield curve. The drag on the liability margins from negative rates in the past years turned into an increasing tailwind. We also continue to benefit from higher rates in non-Eurozone countries.
On lending NII, the picture was slightly different as client rates generally track higher funding rates with some delay and prepayment penalty income continued to level off to more normal levels. Although quarter-on-quarter, we see that effect is bottoming out. Looking at the other P&L lines, fees and daily banking continue to grow, while uncertainty impacted fees on investment products and lending. Overall, with 4% fee growth realized year to date, we continue to target an average of 5%-10% annual growth. Operating expenses reflected inflationary pressure, mainly in staff costs. Overall, with measures taken to control expenses, we contained the upward pressure and kept cost growth well below inflation rates. We did see some volatile items this quarter, including the previously announced expected impact from the Polish moratorium.
In Belgium, we had an exceptional EUR 288 million hedge accounting impact, with the mirroring positive impact to be recognized over the coming years. We also added EUR 75 million to the compensation for customers on certain Dutch consumer credit products. We move to slide 10. Year on year, NII was up 8.5%, excluding the expected impact from the Polish moratorium, mainly due to the accelerated recovery of liability margins I mentioned earlier, combined with a higher FX ratio hedging results. We continued to see some pressure on lending margins in the Q3, reflecting a delay in tracking higher funding rates and lower prepayment levels on mortgages, although we see this bottoming out.
Quarter-over-quarter, NII was up 6.1%, excluding the Polish moratorium, again, supported by improved liability margins, offsetting some remaining pressure on mortgage margins due to the reasons I just cited. Excluding the Polish moratorium, our net interest margin for the quarter was up at 142 basis points, mainly reflecting the higher NII on liabilities. Slide 11, that shows net core lending growth. In retail, mortgages continued to grow, mainly in Germany and the Netherlands, although at a lower pace, reflecting an overall slowdown of demand driven by uncertainty. Lower net core lending and business lending was mainly visible in Belgium. In wholesale banking, loan growth was mainly visible in lending, partly offset by Trade and Commodity Finance, reflecting lower commodity prices. Going forward, with increased macroeconomic uncertainty, we expect loan demand to be subdued.
Net customer deposit growth was EUR 10.5 billion, mainly driven by retail, with a continued inflow, especially in Germany. Wholesale banking also records an inflow, mainly visible in our cash management business and Financial Markets. Turn to fees on page 12, which show resilience despite growing uncertainty that affected the appetite for both investments and lending. Year-on-year, fee income was stable. Daily Banking fees continued to grow, this quarter by an impressive 26% compared to a year ago. This reflected growth in primary customers, the increase in payment package fees and new services. Lending fees were down slightly, while in investment products fees, we continue to see the effect of lower stock markets and less trading activity. Sequentially, we saw the same development with 8% higher Daily Banking fees, while investment products and lending were lower, driven by uncertainty. Slide 13.
Excluding regulatory costs and incidental items, operating expenses were up on both comparable quarters. As I explained, this is mainly the effect of high inflation rates coming in through salary indexation and CLA increases, while we also keep investing for future growth. Regulatory costs were down on both prior periods. Year-on-year, this was due to a lower deposit guarantee scheme contribution in Germany. Quarter-on-quarter, this mainly reflected a one-off contribution in Poland to a new institutional protection scheme in the previous quarter. Incidental items this quarter included a EUR 75 million addition of the interest on interest effect to the compensation for consumers on certain Dutch consumer credit products and EUR 10 million for hyperinflation accounting in Germany.
Overall, in light of the current operating environment, and especially when looking at the high inflation rates, I'm pleased with how well operating expenses were contained. On to risk costs on the next slide, which were EUR 403 million this quarter, or 25 basis points of average customer lending. We booked EUR 160 million reflecting updated macroeconomic indicators and recorded a net addition of EUR 89 million to management overlays for the potential impact of secondary risk of the current macroeconomic environment. In total, we build up EUR 520 million in management overlays. Risk costs also include the release of EUR 77 million in Stage 2, reflecting a further reduction of our risk exposure. The increase in the Stage 2 ratio is mainly the result of a methodology change following IFRS accounting, rather than a deterioration in the risk profile of our loan book.
This change impacted primarily investment grade exposure with a very small impact on risk costs. The Stage 3 ratio improved to a low 1.3%. The next slide that shows CET1 ratio, which remains stable at 14.7%. CET1 capital was EUR half a billion higher, mainly due to the inclusion of net profit for the quarter. RWA were up by EUR 2.7 billion, including EUR 3.1 billion of AVIX impacts. Credit RWA were up slightly when excluding AVIX impacts, reflecting some model impacts while the overall profile of our loan book improved. Market RWA were lower, reflecting a decrease in the capital multiplier for trading book positions. Furthermore, higher operational RWA reflected the update of the AMA model.
Concerning our distribution plans, today we have announced we will distribute an additional EUR 1.5 billion via a share buyback in 2022. Any amount remaining after the 31 December 2022 will be paid in cash on 16 January 2023. Slide 16 shows our financial targets as we presented them to you during our investor update. The CET1 ratio remains well above our target of around 12.5%. Also, when including the EUR 1.5 billion additional distribution we announced today. The cost income ratio remains an important input for our ROE, and we continue to work on our ambition of 50%-52%, and this will be supported by the acceleration of liability NII and continued customer growth.
We keep our expenses contained and continue to invest in our scalable tech and operation foundation that will enable us to grow at a lower marginal cost. ROE came in at 6.8%, including some exceptional items over the past quarters and based on a high capital position. On the 12.5% CET1 ratio, the pro forma ROE was 8.9%. We maintain our ambition to provide an attractive total return and are well-positioned to do so with continued growth of customers and income, focus on managing expenses and asset quality while we optimize our capital position. To wrap up with the highlights of the quarter, our people make an effort every day to build a superior experience for our customers and to support the transition to a more sustainable society.
We see these efforts positively reflected in primary customer numbers, NPS, as well as sustainable deals and volumes mobilized. Our financial results show that accelerating NII momentum is a clear tailwind, with fee income has proven to be resilient. Expenses were well contained this quarter, despite the inflationary pressure of indexation in some markets and continued investments to realize our strategy. Our capital position remained strong, which also allows us to take another step in returning capital to our shareholders, as today we announced a distribution of EUR 1.5 billion. Overall, in a challenging environment, we have delivered another good quarter, and with our positioning and strategy, I'm confident that we will continue to deliver healthy financial results as well as a successful execution of our strategy. With that, I hand over for questions.
Thank you. If you wish to ask a question, please dial zero one on your telephone keypad now to enter the queue. If you find your question is answered before it's your turn to speak, you can dial zero two to cancel. In the interest of time, we kindly ask each analyst to limit yourselves to two questions only. Our first question comes from the line of Giulia Aurora Miotto of Morgan Stanley. Please go ahead. Your line is open.
Yes. Hi, good morning. Two questions from me. The first one, I will start with, capital. I think the EUR 1.5 billion, you know, distribution with a clear commitment by the 16 January, was very nice. Can I just double-check that nothing has changed in terms of your commitment to ultimately get to 12.5%, and therefore we should expect, you know, potentially another one, with the full year results? The reason I ask is just because we keep seeing, you know, these headlines from the ECB, for example, that banks should keep as much capital as possible, et cetera, et cetera. So just a confirmation of that would be helpful. Then my second question is on costs.
Costs came in a little bit worse than what the market was expecting. You know, inflation is above what probably you were expecting last time you gave guidance. Can you tell us what you expect for costs for this year, but most importantly, next. Thank you.
Yeah. Hi, Julia. Thank you very much. I'll take the question on capital, and Tanate will take the question on cost. I mean, on capital, look, we have said, also during the investor presentation in June, that we would gradually move to around 12.5% in approximately equal steps. We've also said that we are in constructive dialogues with our supervisors. As you can see, that constructive dialogue has now led to the EUR 1.5 billion that we announced today. We still have a capital level that is significantly above our target capital level, that is significantly above the requirements of our supervisors.
To that extent, we will continue to be in constructive dialogue with our supervisors, for also next steps, but we will only announce them when we will announce them. With regards to your remark of the DNB, I think that the DNB made a generic remark about banks remaining prudent and therefore also be mindful of keeping adequate capital levels, which is exactly what we do, because we have a capital level that is significantly above the target capital level that we have and significantly above the capital levels that supervisors requires from us.
Hi, Julia. On costs, you know, we have recognized that cost pressure are higher, because of inflation, and we see that in markets where there's indexations of salaries like in Belgium and in Central and Eastern Europe. I think a trend line that we see more and more during the course of 2022 is the fact that, particularly currencies in dollars or Asian currency are appreciating due to the weakening of the euros, and that has reflected also in the translated, cost increase that we see. Of the year-on-year results, which I think it's a good trend line for you to analyze, our costs are up around EUR 117 million, but about half of that is to the aforementioned FX results or some higher than usual legal expenses.
The underlying wage and procured expense increase is around 2.2%. That's maybe the underlying increase year-on-year. To reiterate the point, we continue to make sure that next year our guidance is still that we will keep costs below inflation.
Thank you.
Thank you. Our next question comes from the line of Rahul Sinha at JP Morgan. Please go ahead. Your line is open.
Good morning, everybody. Thank you very much for taking my questions. Can I have two, please, on NII? I guess the first one is just going to your new disclosure around NII sensitivity for this gradual pass-through scenario, which is very helpful. When I look at that and I take your underlying NII run rate, which is sort of around EUR 14 billion, it looks like the delta into 2023 and 2024 is obviously very significant and probably ahead of consensus just based on your Eurozone replicating result. You know, sort of the EUR 2.9 billion uplift over 2022, which is EUR 0.6 billion. Essentially, it looks like your NII is gonna be up EUR 2.3 billion on a net basis.
I guess the first question is, can you give us a little bit more holistic picture around what are the other factors that might be offsetting this when we consider the NII moving parts over the next years? Any more color on that would be helpful. Or should we take this as sort of the main driver? And then secondly, I guess related to the NII and just to understand this TLTRO hedging, can I ask what type of risk were you hedging with your derivative position and in your repayment profile versus what you had previously assumed? Thank you very much.
Okay. Thanks, Rahul. I'll take the question on NII, and then Tanate takes the question on the TLTRO hedging. On NII, I think your question is what are factors that could impact the growth in NII income and also in the replication. I think in a replication as such, it is of course the level of pass-through and, i.e., the tracking of the rates. As you are seeing, we have, because rates are moving so quickly, we have a gradual pass-through scenario assumed for now, but it is illustrative. Too, you can see the question of course is what will the lending NIM do or the lending margin do?
We are seeing some contraction in lending margin also mainly in mortgages because of a lower prepayment penalties coming in by means of the rising of the interest rates. That is currently stabilizing, so we don't see contraction anymore in that book. For the same token, of course, the mortgage duration is now lengthening. That can have an impact. Last but not least, we have loan growth. There we do expect a more subdued environment. We still see good loan growth this quarter in mortgages, and we also see it in wholesale banking, but it's lower than compared to some of the previous quarters.
For the next quarters, we see that loan demand a bit more subdued than we've seen it so far.
Rahul, on your question on TLTRO. We're clearly disappointed by this change of terms that we see from the ECB so close to the end of the program. But in fact, if you look at a TLTRO before the change, it was a fixed interest rate instrument. In terms of our asset liability management, we always manage the volatility of our interest rate margin. What we did was actually hedge our interest rate risk. What we have seen because of this announcement, as of the 23 November, that fixed instrument has become floating. That means that we need to close our interest rate position, which we have done so during the course of the last few days.
Thank you. If I can just follow up on the first one, Steven. What has been your actual pass-through so far? Just trying to think about the 30% you assumed in 2023. I know it's early days, but can you give us any indication of where your pass-through has been overall?
Well, if you look at what we announced so far. We have Germany, we announced 30 basis points. Spain, I think we announced 30 basis points. Netherlands, we announced 25 basis points. Those are the biggest announcement that we've made so far.
All right, thank you.
Thank you. Our next question comes from the line of Farquhar Murray at Autonomous Research. Please go ahead, your line is open.
Morning, all. Just two questions if I may, both actually on the capital return point. Firstly, on the EUR 1.5 billion. Last quarter, you kind of indicated it didn't need to come with results, and there were incentives for perhaps moving earlier. I just wondered if you could explain why this ultimately did come with results. In particular, is the regulator in the Netherlands maybe being a little, still a little bit go slow? Looking forward, you're still talking towards converging to the 12.5% in roughly equal steps. Could you give us a sense of the likely frequency of those steps, and might there be any chance of aligning it with the full year reporting from here? Thanks.
Yeah. Thanks, Farquhar. Yeah, there is not a story behind doing it, not during the quarterly results and equally, there's also no story doing it during the quarterly results. There is no story behind that. We just are in dialogues. We look at the forecast. We do our stress testing. We submit the stress testing. We get feedback, and then we make a proposal that we discuss internally with the boards, with the supervisory boards, and then we get approval for it. Those are the procedural steps. There is nothing particular or there's no particular agenda behind doing it now or doing it before. That process, in this case, coincidentally led to us being close to the, and actually, exactly on the quarterly figure.
That was the reason why we announced today. Like I said, we remain in our contacts and good dialogues with our supervisors. We continue to do our stress testing. We continue to build up capital and profitability. We will go through the similar process steps to look at further increasing our capital towards 12.5% in the future. Again, taking that same process in mind, whenever there is a step to announce, we will announce that step. There's nothing to report on that at this point in time.
Just as a follow-on. I mean, that process still sounds quite clunky. Does that mean it probably takes six months to really do each step?
No, that's not the case. I mean, maybe I explained it quite clunky, but it is not as clunky as I explained it, so I apologize.
No, no, nothing to apologize for. That's really helpful. Thanks.
Thank you.
Our next question comes from the line of Benoît Pétrarque at Kepler Cheuvreux. Please go ahead, your line is open.
Yes, good morning. Yeah, just to come back on the cost guidance of less than inflation. I think back to June, your own macroeconomists were going for roughly 3% for 2023. Now they are expecting 5.6% for 2023. Obviously, this is a quite large gap. You know, for next year, when you say below inflation, is that below 5.6%, or could that be, you know, below 3%, below 4%? Where are you for 2023? I guess you have a good idea now about you know, the wage inflation in the pipeline. Could you update us also on the CLA negotiations in the Netherlands, please? Just wanted to come back on the asset margins. The lending margin actually.
Where you do see some pressure. Is that purely a timing issue, i.e., that should be resolved in 2023? Or are we going to see the same type of behavior we've seen in previous cycles, which is that you know, lending margins is under pressure when rates are just higher, just normal and natural effect? I try to understand because it's quite clear to us that the NII uplift will be quite significant from the replicating portfolio next year. But any indication about more potential negative headwinds you expect will be useful. That's it actually. That's two.
Okay. That is clear. I will take the question on lending margins, and Tanate Phutrakul will take the question on cost guidance. On lending margins, I mean, the pressure comes in. I mean, as you know, approximately half of our book is mortgages. What you do see with increasing interest rates are two things in that book. The prepayments are lower. People will not prepay their mortgages as quickly as they used to do. It also means that our prepayment penalty income is lower, and that prepayment penalty income is added to the interest income. Because that is decreasing, that causes one element of margin compression. That element is now largely gone, so you now see stabilization of prepayment levels in our book.
Over the last number of years, when the interest rates became lower and lower, the prepayment numbers went up, and now they went down again. I would say before negative interest rate levels. They are normalizing. The second element is that we need to refund when we refund ourselves and fund ourselves that those funding rates are only passed through gradually in our lending books. Therefore, if funding increases, the margin of our total book contracts because we fund ourselves at higher rates without having been able to pass these rates through. That takes time and is also dependent on the competitive environment. If the rates are stabilizing, then also the margin contraction will be stabilizing.
What we already see is that prepayment penalties, there is no other contraction anymore. Currently we also see margins greatly normalizing. We do expect that margin contraction on the lending side, on the lending NII to taper off.
Thank you very much. I think a bit more insight on inflation and cost evolution. I think we're watching very carefully these revisions in inflation to be higher next year compared to this year. Not only are we watching it, our labor counterparts are also watching it. We are in discussions with respect to our various different collective labor agreements and that we'll let you know once those things are agreed. Okay? Having said that, we continue to be disciplined on our various different programs. We continue to make efficiencies. One thing that I can assure you is that cost discipline, revenue trajectory means that we will continue to converge on our target for cost-to-income ratio of 50%-52%.
We don't see anything in the environment, despite the increased inflation, that we will not make progress next year on our cost-to-income ratio. Great. Thank you very much.
Thank you. Our next question comes from the line of Andreas at Goldman Sachs. Please go ahead. Your line is open.
Hello. Thank you very much for taking my questions. On deposit margins and the outlook for it, please, if I may. I mean, given where market rates and your euro savings rates are, would you say that you could reestablish the historical deposit margin that you had achieved before the zero lower bound kicked in or at later this year, potentially? Beyond that, can you help me think about what the new normal for deposit margins could look like? Is there anything structural that you see which would give you reason to believe in higher deposit margins than the one you have achieved several years ago? To what extent then could that be offset by a lower asset margins? My second question on that topic is more to downside risks.
I mean, the policy rate in the Eurozone is now well above your replication yield, I believe. Something we haven't seen for many, many years. Are you worried about retail customers or the public more broadly looking at 2%+ policy rates soon and pressure building for you to raise retail rates beyond what the replication yield suggests, leaving you in a way overhedged? Thank you very much.
Okay. Tanate?
Yes. If you look at historical margins on, say, well, deposits back 10 years ago, I think the margin for ING was around 1%, right? But that 1% has a very different composition from even a customer basis. As Steven mentioned, we have made a key focus on improving primary customers. As you know, primary customers bring with it a lot of current account deposits, and that is a fundamental shift in what we've seen back in 2011 today. That a significant part of our deposit base today is in current account, which attracts no interest payments for the time being. With that in mind, I don't really see any reason why we can't get back to those historical margins, because even back 10 years ago, interest rate was barely 0 as well.
It's not as if something has changed from that perspective. In terms of, I think I translate your second question is around tracking. Again, you know, we've given you a simulation of where things would go, but how that would evolve in actuality, it really depends on market forces. That remains to be seen. I think we give you an indication of how tracking may or may not happen based on the current curve.
Perfect. Very clear. Thank you very much.
Thank you. Our next question comes from the line of Kirishanthan Vijayarajah of HSBC. Please go ahead, your line is open.
Yes, sir. Good morning, everyone. Just one question really from my side. If you look at the extra NII you're going to get from the euro replicating portfolio, clearly some big numbers there. My question is, do you regret exiting France and Austria? You know, they were predominantly deposit-led franchises. Would the current rate environment have been enough for those businesses that you've exited to maybe have cleared their cost of equity? 'Cause I know, clearly cost income was a problem there, but with this rate environment, you know, would those businesses actually have been more attractive, please? Just your thoughts on those business exits you did when you first became CEO. Thank you.
Yeah, thank you. The short answer is no. In the end, you have to have sufficient businesses that are sufficient in size to be able to provide the right and superior services to our customers at a good cost income level with a diversified profile, with the right profitability. Also with these interest levels or even higher, that would not have been the case. We of course have made analysis also back then in terms of different scenarios. In the end, what you need to be successful in the market is to have sufficient scale with a sufficiently diversified business. If that's not the case, then you need to see whether you're able, in the context of that particular market, to get to that point.
For those markets, we have concluded that that was not the case. If you would ask me the question today, we would come to the same conclusion.
Okay. That's very definitive. Thank you.
Thank you. Our next question comes from the line of Tarik El Mejjad of Bank of America. Please go ahead, your line is open.
Hi, good morning. Thank you for taking my questions. The first one is on the TLTRO. I know it's a one-off small number in the scheme of things, but do you have the intention to take any actions against or discuss with the ECB? Because that could set a precedent on revising any retrospectively agreements or contracts in funding or whatever other agreements. I would ask the same question to other large banks benefiting from TLTRO, but I would be interested to have your view on that. The second question is on costs. I understand you'll be watching carefully the inflation for next year, but definitely will be higher than your early estimate of 2.3%.
Can you give me some elements of potential extra savings that will be able to offset that and keep you on track for your guidance? Or are you just hoping that the top line faster growth will more than offset that, erosion, or, I'm sorry, uptick on costs? Thank you.
Yeah, thanks, Tarik. I will answer the question. I'll happily answer the question on TLTRO, and then Tanate will talk about costs. Why do I say happily? There's a bit of cynicism in there. We are very disappointed with the way that the ECB made that announcement. If you look at the broader light of economic circumstances and the interest rate movements, we of course understand that at some point you say, "Well, that program, a TLTRO program is not needed anymore." Then we would have expected that to be done at the point that such program would lapse and not midstream, also after banks put their hedges on to cater for interest movements on that support. Unhappy with that, disappointed with that.
I would like to leave it at that. I will also not comment on whether or not we're going to take actions that is not for this call.
Tarik, just on expenses. You talk about levels that are visible next year. I think it's the same as the ones we have disclosed before. We still have the impact of closure of some business units flowing through our financial next year that will have a reduction in cost that you will see. For example, the closure of our businesses in France, for example. We continue to be more efficient in our operations, continue to be more efficient in savings, in IT. Particularly, you see our disclosure focus on straight-through processing that allow us to grow our business scalably without adding any, you know, additional expenses to grow our business. You see that operating leverage coming through as well.
Of course, we have continued our program to move the gravity of our operational staff from our home markets to our hubs, whether in Eastern Europe or in some markets in Asia. Those programs will continue to be the case. Then just the basics of negotiating well our various different contracts to mitigate as much the, you know, suppliers asking for increases in inflationary increases. That, given the scale of our business, we believe we still have that negotiating benefit.
Thank you.
Thank you. Our next question comes from the line of Benjamin Goy at Deutsche Bank. Please go ahead, your line is open.
Yes. Hi, good morning. Two questions, please. First, I mean, you're clear on loan growth, but actually I'm more interested these days in deposit growth. It was good in the quarter, but in particular driven, I guess by Germany and Daily Banking. Wondering was that somewhat of a one-off effect, given the stop to negative rate charging?
How generally you view the outlook for deposit growth from here. Secondly, wondering about your views or how do you see the risks of bank levies, or anything like that in your three biggest markets, Netherlands, Belgium, and Germany. Thank you.
Thank you very much. I think that's Ben, if you look at the deposit growth driver was that when we stopped negative charging, deposits that were previously left the bank came back, so that has increased the deposits quite a bit. Now we continue to work on growing our deposit base and our primary customer base in Germany, we're doing very well. If you talk about the bank levies in our markets, there's nothing to report on that, there's nothing new that we are aware of that would come on stream. If there would be something coming, then we will let you know.
Wonderful. Thank you.
Thank you. Our next question comes from the line of Anke Reingen of RBC. Please go ahead. Your line is open.
Yeah, thank you very much. My first question is on your 2025 targets and the ROE target. Obviously now the NII expectations in absolute terms are higher than when you presented the plan. Is that so you think there is upside to your ROE target or offset by higher costs? Or do you think you could potentially reach your target faster than previously expected? Secondly, coming back on the buyback, your comment about the roughly equal steps, just to confirm, I guess, should we look at the EUR 1.5 billion plus the EUR 300 million, or as one step, the EUR 1.5 billion you just announced? Are you able to request a new buyback from the ECB while you're still executing your buyback? Thank you very much.
Sorry. The third question, Anke. You had one on the upside of ROE. The second one was on roughly equal steps. The third one?
Are you able to request a new buyback program from the ECB while you're still executing the EUR 1.5 billion current plan?
Oh, okay. Okay, good. Okay.
Sorry.
Look, on the buyback and on the roughly equal steps, what we mean with roughly equal steps is roughly equal steps in terms of CET1 decrease. That's how we define roughly equal steps. Then we therefore gradually, on that path, move to around 12.5%. That's how we then do it in terms of the number of share buybacks or capital distributions or that we will see, and then we will just work out over the next quarters and years how to do that. You are now seeing that we're trying to do that by decreasing our capital ratio in approximately equal steps. That's what we mean with that.
The related question is.
Equal step as that.
Yeah. The related question is, are you then able to do that while you're still executing this one? Well, look, we are in continuous dialogue with the ECB on a plurality of topics, and of course also on our capital, and also our capital is reviewed on a regular basis. We have been in dialogue, we will continue to be in dialogue, and when there's something new to report on the next step, then we will do so. When we talk about the ROE targets, it's good, I like your ambition. Let's first get to the 12%, and then we start talking further.
Okay. Thank you.
Thank you.
Thank you. Our next question comes from the line of Amit Goel at Barclays. Please go ahead. Your line is open.
Hi. Thank you. My first question actually may be a little bit along the lines of what Anke just asked, but just thinking with the better NII outlook, just on the cost income ratio target for 2025, 50%-52%, you know, is that something then that you think you can do better than or, you know, to a large extent, is the NII offset by potentially higher costs? Then the second question or related, I appreciate it was a bit, it was asked a bit earlier on, but in terms of the NII for 2023, do you mind just again remind me what the potential offsets to some or partial offsets to some of the tailwinds are likely to be? Thank you.
All right. Thanks, Amit. On the offsets, it is prepayment penalties, but like I said, prepayment penalties have come in because I mean that people are holding on to their mortgages longer. It is the longer duration of the mortgages which the people holding on longer. It also means that we need to hedge our funding at higher levels, so that could be an offset. Loan growth, that is not necessarily on replicating portfolio, but that is on NII. That was good this quarter, but we expect at least for next quarter is a more subdued environment given the economic circumstance.
The last one is, of course, I think there was also, I think, a question asked by one of your colleagues, I think it was Chris Hallam, about, okay, how much of the replicating portfolio will be tracked, and what are your views on that? That's what Tanate Phutrakul gave. Those will be the main factors that would influence that. With regards to then, can you do better on your cost-income targets, again, you're in Anke's camp, which is, let's do better, which we always want to do better. This is our target. We are confident about our targets. By the way, we pull on all levers. We pull on higher income, more diversification of income that I've talked about previously.
We talk about our scalable tech and operational foundations, our end-to-end digitalization programs, our hubbing of our skill sets, and all of the way that we work on capital velocity in Wholesale Banking. All of them will work towards these targets. It's not that we just work on one lever. We also continue to work on our cost lever, bearing in mind that we also want to make investments there where we can make good return, and so we also need to balance that.
Thank you.
Thank you. Our next question comes from the line of Flora Bocahut at Jefferies. Please go ahead. Your line is open.
Yeah, thank you. The first question I wanted to ask you is on the NII again, just a clarification on the negative deposit charging. You know, out of the EUR 300 million run rate for the full year, I wanted to understand how much was already gone in Q3 and how much of a quarter-on-quarter decline we could therefore see again in Q4, if any. The second question is on the regulatory cost. I'm not sure if this was answered before. I'm sorry if it was, but you had guided at Investor Day, I think for a EUR 0.4 billion decline in bank taxes in 2025 versus 2021. I wanted to check if that still holds from today's standpoint.
Just one quick clarification, if I may. The one-off of -EUR 350 million that you're gonna have in Q4, is this gonna have the NII? Because you only mentioned pre-tax profits. Just to be sure. Thank you.
Okay. I think on the where does it fall, the EUR 315 million. By the way, EUR 315 million is pre-tax, but that's accounting. We're not gonna disclose it as yet. In terms of regulatory costs, are they still going down with EUR 400 million? That's currently our assumption indeed. That has not changed. On NII, how much was already gone in Q3 in the further downsides, that I will give to Tanate Phutrakul.
Yeah. You know, the NII impact this quarter is around EUR 66 million, and then it will be gone next quarter. It's getting very minor. In fact, most of the benefit, whether TLTRO, negative interest charging, all gone in Q3.
Thank you.
Thank you.
Thank you. Our next question comes from Adam Terelak from Mediobanca. Please go ahead. Your line is open.
Morning. I just had one follow-up on the NII guidance. You've given EUR 600 million for 2022. How much of that is in the current run rate, and how much is gonna come through in Q4? I'm just trying to think what the uplift in NII could look like for Q4 versus Q3 versus that guidance, and then clearly, quite important for thinking the year-over-year, that EUR 2.3 billion versus EUR 0.6 billion this year, to get the run rate NII for 2023 on the basis of that guidance. How much of that EUR 600 million has been booked year to date in terms of replication benefit? Thank you.
First of all, I think, Adam, thanks for the question. Again, we want to say we don't give forward guidance. We give you a simulation based on what the yield curve would look like, right? I think, that's what we see. What you see really in terms of replication is that 40% of our replication is within one year. You see that impact already tracking. I think what is the best thing that you can look at is look at the pickup in our NII in a single quarter alone, right? From Q2 to Q3, it's up 6% in a single quarter, which basically informs you of how fast the tracking is taking place.
Again, I don't want to repeat the answer that Steven gave, which is that replication, it depends on many factors, deposit growth, tracking speed and all that. That will be what we will see next year.
We can't comment on replication benefit booked year to date?
Maybe I would like to let you talk with our investor relations team after the call. Okay?
Will do. Thank you.
Thank you. As that was the final question on the line, I'll hand back to Steven for the closing comments.
Yes. Thank you very much, operator. Thank you very much, everybody, for dialing in, for your time, for your good questions. I wish you a fantastic day. Thank you very much.
This now concludes the conference. Thank you all very much for attending. You may now disconnect your lines.