Good day everyone. Welcome to Banco de Chile's third quarter 2020 results conference call. If you need a copy of the press release issued yesterday, it is available on the company's website. Today with us, we have Mr. Rodrigo Aravena, Chief Economist and Senior VP of Institutional Relations, Mr. Pablo Mejia, Head of Investor Relations, and Daniel Galarce, Head of Financial Control. Before we begin, I would like to remind you that this call is being recorded and that information discussed today may include forward-looking statements regarding the company's financial and operating performance. All projections are subject to risk and uncertainties. Actual results may differ materially. Please refer to the detailed note in the company's press release regarding forward-looking statements. I would like to turn the conference over to Mr. Rodrigo Aravena. Mr. Aravena, the floor is yours, sir.
Good afternoon, everyone. Thank you very much for attending this conference call today. In the first part of this webcast, I present our view of recent developments in the business environment. Pablo Mejia, our Head of Investor Relations, will go over strategic advances and financial results achieved by our bank during the third quarter. Let me start with our view of the economy. Please move to slide number three. Several signs suggest the bottom of the negative cycle was seen in the second quarter of this year. Sales activity is also improving when compared to most countries in the region, which is highly attributable to our sound fundamentals, a strong policy responses, and improvement in COVID-19 evolution. I will go into greater detail regarding factors later on this presentation. The chart on the top left shows the magnitude of this recovery.
After the 43% annualized drop in the second quarter, GDP increased 21% in the third quarter. Consequently, the activity reduced its annual decline rate from 14%- 9% in that period. This rebound has been explained by higher dynamism in several sectors related to domestic consumption, which have also been influenced by the withdrawal of personal savings from pension funds, as well as the implementation of other government support programs. This potential turning point in the economic cycle has increased domestic prices. The CPI went up by 0.6% in September, which was well above the market consensus and from levels observed in previous months. Consequently, the annual inflation rate went up to 3.1% in September, rising 60 basis points from August as the chart on the upper right clearly shows.
As seen in most countries, the labor market has suffered the main negative consequences from this pandemic, as shown on the chart on the bottom left. As a matter of fact, unemployment rate rose sharply from 7% in February to 13% in July. This deterioration resulted from the 20% and 15% decline in employment and labor force, respectively. Nevertheless, some potential green shoots are taking place in line with the gradual but steady recovery of the overall activity. This can be seen in the bottom right chart, where the employment has been improving since August. These positive signs are highly attributable to the gradual lift of mobility restrictions due to the lower spread of COVID-19. I'd like to briefly refer to this factor, which has undoubtedly had a key role in this recovery. Please move to slide number four.
In our previous conference call, we mentioned that Chile was under strict lockdowns since the second quarter of this year. As a result of these measures, we've seen a positive evolution in several indicators related to the pandemic, making possible the eased mobility restrictions. The chart on the other left shows the drop in active cases of COVID-19 in Chile with an impressive pickup in the number of recovered people. Additionally, the share of positive tests has remained at levels around 5%, well below other Latin American countries. Thanks to this, as you can see in the chart on the bottom left, local authorities have been reducing the number of areas in quarantine. While 54% of the population was under quarantine in July, this number went down to 19% in October. This change contributed to the greater mobility in the country as the bottom right chart suggests.
The impact on activity was greater. The proportion of GDP affected by the lockdown fell from 65%- 15% in the same period. This trend, together with a strong fiscal and monetary policy and favorable copper prices, have been critical for this improvement. All these factors have led to better expectations for the future, which I'd like to discuss now. Please move to slide number five. We are aware of the unusual uncertainty that we face, not only in Chile but also in the world. That's why in this particular environment, I'd like to emphasize three main assumptions that we take in our baseline scenario. First, we assume that social distance restrictions will remain most of the next year, which is consistent with a gradual pace of recovery in both GDP and employment. Second, we also assume the absence of further domestic shocks as we experienced last year.
Finally, we also assume that copper price will continue providing support for the Chilean economy. This table summarizes our forecast for this and the next year. We see a recovery in GDP to 4.5% in 2021 from a 5.3% drop this year, which positively compares with other countries in the region. The table on the right shows that according to the IMF forecast, Chile will have the best performance on average in Latin America. We expect the inflation rate to remain around 2.8% this and the next year, still below the 3% target set by the central bank. Since banks are a perfect reflection of the economy, this new normal has had significant implications in the financial sector, as we will discuss in the next slide. Please move to page number six. The Chilean banking industry has shown an important resilience in this pandemic.
Despite the crisis, which was accompanied by lower inflation, employment, and interest rates, banks were able to adapt their strategies to deal with this scenario. Total net income slightly increased on a sequential basis to CLP 473 billion in the third quarter, adjusted by Itaú figures. This result, however, was 19% below the same period last year. Consequently, ROE fell from 12% in the third quarter to 9% in this period. In a broad sense, profitability was affected by the following factors. First, a weaker loan mix. Second, higher cost of risk due to the new criteria to account for government-guaranteed loans and additional provisions. Third, the negative impact of low inflation and interest rates, as well as the flatter yield curves.
It's also important to pay special attention to the evolution of delinquency rates, which have remained at very low levels, as the chart on the bottom left shows. Nevertheless, this should be a temporary situation since figures have been supported by specific factors. One of them is impact of SMEs reprogrammed loans, which remain in the grace period. Another factor is impact of the 10% withdrawal from pension funds, since according to the central bank, nearly 15% of these resources were spent in reducing past due loans, as you can see in the chart on the bottom right. It's reasonable to expect higher delinquency rates in the future after these effects end. Despite this complex environment, Banco de Chile was able, once again, to accomplish good results, not only in financial terms, but also in strategic advances. Please move to slide eight.
Banco de Chile has had a successful and proven track record of consistent and robust results. Since we aspire to continue being the most sustainable and profitable bank, we are continually reinforcing three key areas of our long-term strategy: digital transformation, efficiency and productivity, as well as sustainability. We firmly believe that strengthening these strategic areas will allow us to support long-term growth and will help us in the future challenges that arise in the new business and social environment. Please move to slide nine, where we begin to highlight some of our initiatives in digital banking. The pandemic has accelerated how we use technology in our daily lives. This has pushed us to work harder and faster in all of our digital banking solutions in order to provide our customers with financial products and services they demand.
We are proud to announce that in September we set a new standard for digital banking in Chile, officially launching our new digital 100% online onboarding bank account, called Cuenta FAN. This is a far superior product when compared to what is available in Chile today, and thanks to this, our launch was a total success. In less than two months, we already have 90,000 new FAN customers. The demand from customers opening Cuenta FAN accounts nearly doubled the amount raised by our main competitor, as you can see on the top right on this slide. For instance, we launched a product in the first half of this year, and we reached almost the same amount of new customers, but in a much shorter timeframe. There are many advantages to our account that are driving this demand.
Just to name a few, a Cuenta FAN customer becomes a Banco de Chile customer, allowing them to receive all discounts and benefits of a regular client. There are also no entrance or maintenance fees, and this account grows with the customer. It starts as a debit account, and later, if the client qualifies and desires, becomes a current account. As the FAN customer has additional financial needs, we can offer them other products, creating new cross-selling opportunities. Most of our new FAN customers are younger than 45 years old, and we're using this product to build closer relationships with people from this segment. Before moving to the next slide, I'd like to mention that the cost of this account is very low when compared to a traditional account. At the origination, we don't require costly credit checks and expensive customer background reviews that could affect delivery times.
It's also important to mention that ongoing costs for these accounts are marginal, since we already have the install capacity and back-office processes. Please turn to slide 10. As I mentioned in the previous slide, one of the main advantages of Cuenta FAN is that these clients have access to all discounts and benefits of a Banco de Chile customer. Our premium loyalty program includes exclusive discounts with the many delivery platforms such as Uber Eats, PedidosYa, and Rappi. We also have a unique program called Big 5, with discounts of up to 40% in big chains, including Starbucks, Papa John's, and others. In addition to this, we have partnerships for most demanded events in Chile and alliances with stores and services from a wide range of segments that go from technology, transport, to telemedicine, and leisure.
This strong loyalty program is one of the fundamental drivers of the success of our Cuenta FAN and assists in increasing our relationship with customers to become their main bank account. Please turn to slide 11. Cuenta FAN is only part of our strategy to strengthen our digital experience at Banco de Chile. We are continually renewing, improving, and rethinking how can we deliver our products and services better through the channels our customers are demanding. For this reason, we've been updating many of our front office digital platforms, bringing more agility and security to our channels. One of the latest advances is our new webpage that offers a superior customer experience and incorporates analytic tools. It's more modern, safe, secure, and inclusive. We also integrated on our webpage a heat map, which provides us with valuable information to understand our customer preference even better.
In addition to this, we renewed our apps, Mi Banco and Mi Pago, with a new technology that allows for faster, easier, and safer transactions. Behind our front office improvements, we also have significant advances in our digital back-office operation. Undoubtedly, the pandemic accelerated our digitalization. As in a short period of time, we had to deal with an important increase in the usage level of our digital channels. To mention some numbers, we received 23% of the total pension fund withdrawal and processed 100% online over 400,000 loans in personal banking to support our customers' liquidity needs. All these efforts are part of an ambitious digital roadmap that aims to make our institution the benchmark in digital banking in Chile. Now, Pablo Mejia, our Head of Investor Relations, will continue to present the rest of our advances and Banco de Chile results.
Thank you, Rodrigo. Please turn to slide 12. The successful implementation of our strategy has provided our customers with the best experience in the industry. Even during this challenging time, we have continued to innovate and strengthen our brand and lead in many different indicators, as you can see on this slide. For example, we continue to lead the industry in customer satisfaction with a wide gap to our closest competitors. This solid track record of customer experience has been provided through our proven ability to not only have the best customer service, but also to offer the best products through the channels our customers demand. I should mention that the survey shown on this slide for customer satisfaction is a fair representation of banking customers' opinion as a whole.
These surveys use a more representative sample of banking customers and not predominantly use our own customers. It's also important to highlight that for a third year in a row, we were distinguished with the National Award for Customer Satisfaction 2020, as you can see on the right. Another relevant point I want to mention is the strength of our brand. In many surveys, we rank first. For example, we have posted once again the highest brand recognition in the Chilean industry, and we led with a very wide gap to our competitors in the surveys where customers are asked if they were to switch to another bank, which bank would they choose, as shown on the charts on the left. We are also considered to be the safest bank in terms of security and solvency, as shown on the chart on the bottom.
This leading position in both customer experience and brand is extremely valuable in light of new regulations, where it will be much easier for customers to switch from one bank to another. To date, we have more customers representing information on switching to our bank versus customers requesting to change to another bank. We are confident that these attributes should assist us in maintaining a low attrition rate, as you can see on the chart to the right. Please turn to the next slide, number 13. In our 127 years of history, we have accompanied the development of Chile and supported the country, especially in more difficult times like today. Our commitment to be a sustainable bank is a fundamental pillar of our strategy. Along these lines, I would like to share some initiatives on this matter before moving to quarterly results.
Given our concern for our customers, we were the first bank to implement the National Support Plan for our retail banking and commercial clients. This plan included a series of special measures to support our customers so that they could cover their most urgent financial needs. We are deeply committed to supporting Chile's SMEs, as we believe they are the driving force of our economy. In this line, we launched the fifth National Entrepreneur Challenge with more than 56,000 participants. Furthermore, we have also implemented many actions in order to mitigate the consequences of the pandemic for vulnerable groups in Chile. Some initiatives we would like to highlight is that we delivered essential products to almost 9,000 vulnerable families all over the country, and held a campaign that raised over CLP 16 billion to benefit elderly people affected by the pandemic.
All these efforts, among others, maintain our bank as a financial institution with the best performance in terms of actions taken during this health crisis, as seen on the chart on the upper right. Our sustainable business model was also recognized once again by the European in the Global Banking & Finance Awards 2020, in the categories of Best Bank of the Year, Innovative Digital Bank of the Year, and Best Bank for Financial Inclusion in Chile. These awards acknowledge the relevant progress we have made in digital transformation and its contribution to our business. In addition, Banco de Chile ranks first in general ranking of Merco Talento 2020, which positions us as the best company in the country to attract and retain talent. Finally, we are honored to be recognized for the outstanding crisis leadership by Global Finance.
This clearly shows how we, as a financial institution, went above and beyond to assist customers, protect employees, and provide critical support to the society at large. Please turn to slide 15 to begin our discussion on our results for this quarter. We recorded a net income of CLP 88 billion with a return on average equity of almost 10%. Our lower bottom line was mainly the result of higher provisions attributable to our prudent and conservative risk management approach that aimed at setting adequate levels of provisions. We continued this approach, particularly important today given the magnitude of the crisis we are facing globally. Net income was also affected by a decrease in NIM, which was a consequence of a combination of factors including lower CPI and the sharp decline in interest rates and loan mix. This was partially offset by strong cost control.
Despite this, it's important to highlight that we still posted the highest year-to-date net income in the Chilean banking industry, and we have by far the highest level of coverage. Apart from having the highest profitability and the best credit risk indicators in the industry, we also outperform the banking system in terms of capitalization levels. Please turn to slide 16. Operating revenues recorded a year-on-year decrease of 12%, principally due to unfavorable trends in inflation, interest rates, loan growth, and fees. Specifically, inflation dropped 0.5% when compared to the prior quarter, impacting non-customer income. Also, given monetary policy actions taken by central banks, interest rates decreased sharply this year, while yield curves flattened, which resulted in a lower contribution of our demand deposits to funding and less chance to benefit from term gapping. Additionally, we had a reduction in high margin loan products as consumer loan demand shrank.
Second, the main driver of loan growth during the second and third quarters of 2020 was focused on the FOGAPE government-guaranteed commercial loans, which carry only a 3.5% interest rate. These effects were partially offset by better performance of our AFS and trading portfolios due to shifts observed in interest rates. In this context, NIM fell from 4.1% last year to 3.1% this quarter, as you can see on the table on the bottom left. About 1/3 of this decrease was caused by the lower CPI we had this quarter. The remaining part is explained by the effect of the lower contribution of demand deposits to our cost of funding and term gapping, given sliding interest rates.
It's also worth mentioning, as is mentioned in previous calls, our net interest income has also been affected by the negative impact of mortgage loan renegotiations that took place in the second half of 2019, and the regulation regarding automatic payments of overdraft lines that went into effect in January 2020. The drop in NIM has also been explained by greater exposure to low margin and low-risk assets, such as the Central Bank short-term bonds used to comply with the reserve requirements linked to the strong increment posted by demand deposit balances. Also, since strict lockdowns began to be lifted by mid-August, our fee income has been impacted during the last quarters. Particularly, revenues from transactional services such as checking accounts, credit cards, and debit cards, as well as ATMs, were down due to the lower transactionality and spending.
Similarly, fees linked to loan origination, such as insurance brokerage, also decreased, while fees related to assets under management dropped as a result of market volatility that led customers to switch from higher margin equity funds to fixed income. Nevertheless, the good news is that we have begun to see an improvement in different indicators across the bank that could imply the worst for fee income generation is behind us. Before moving on to the next slide, I want to highlight that we continue being the leading bank in the industry with a wide gap to our peers in fees and in net operating margin, as you can see on the charts to the right. Please turn to slide 17. Total loan growth reached CLP 31 trillion this quarter, increasing 6% year-on-year and up 1.5% quarter-on-quarter.
Demand for loans, excluding COVID loans, improved slightly in the third quarter from the weak levels reported in the previous one, in line with the third quarter 2020 Chilean Central Bank Credit Survey. This report shows both demand and supply had improve slightly quarter-on-quarter for all retail loan products. That credit restrictions had been reduced to companies. Nevertheless, this was accompanied by a weaker demand for loans from the latter, due to partly the high volume of COVID loans and the still uncertain outlook for the economy. For Banco de Chile, most of the dynamism in loan growth was created by FOGAPE loan program, as shown on the diagram to the right. Specifically, total commercial loans grew CLP 2 trillion year-on-year, CLP 1.8 trillion was related to these loans, with government guarantees for companies with sales of up to $10 million per year.
As a reminder, COVID loans were part of the government stimulus package for companies that provided guarantees of up to 85% of working capital loans. We are pleased that we have assisted our customers in Chile by taking part in this program. Most of these loans were provided to small and medium-sized enterprises, which explain about 21% of the growth, as shown on the chart, which explains the 21% growth level that's shown on the bottom of the slide for estimates. On the other hand, personal banking loans only grew 1.3% year-on-year and actually dropped 0.9% quarter-on-quarter, as you can see on the chart on the bottom right of the slide. This result is consistent with the subdued economic growth. This caused a reduction in household spending, which meant less demand for both consumer and mortgage loans.
We expect that the dynamism of personal banking loans should begin to improve gradually in the next months as the economy recovers. In this regard, data revealed by the National Chamber of Commerce shows that household consumption, for instance, would be showing some signs of modest recovery. Please turn to slide 18. Our leading funding structure has been made possible through our ability to provide the best service experience that our customers value and ultimately establishes Banco de Chile as their primary bank account for both retail and wholesale customers. Over the past 12 months, our solid brand and soundness has provided us with strong increases in demand deposits, which rose an impressive 45% year-over-year and an equally remarkable 11% on a quarterly sequential basis. Consequently, our funding structure has significantly changed year-over-year.
Today, our demand deposits represent 32% of total funding, well above our peers, as shown on the bottom right chart. More importantly, DDAs held by non-financial counterparties, which are a stable source of financing, represent around 80% of the total amount. Also, we took advantage of the liquidity of facilities provided by the central bank, from which we obtained mid-term funding denominated in pesos and bearing the monetary policy interest rate. These funding sources have mostly replaced time deposits held by financial counterparties, particularly in local currency. Our well-diversified funding base, as seen on the chart on the left, is undoubtedly an important competitive advantage for Banco de Chile. Finally, our strong Tier 1 capital base of 11.6%, together with our superior credit risk ratings, allow us to place debt with good conditions, giving us a leading level of cost of funding of only 1.6% in local currency.
We are confident that we can take advantage of the opportunities that will be presented during this period to strengthen our relationships with our current customers, as well as continue increasing our share of wallet, especially through digital contact channels. Likewise, initiatives like the FAN Account should allow us to keep expanding our customer base while bolstering our market-leading position in core demand deposits. Before moving on to the slide, I'd like to mention that we are well-prepared to face Basel III future phase and requirements, which is in line with our historical guidance. Our solid track record of generating an attractive bottom line has been a result of our consistent and prudent risk policies that focuses on growing responsibly and sustainably over time. Please turn to slide 19.
A key component of managing risk in Banco de Chile is the governance structure for this topic, in which the board of directors plays a vital role in actively participating in the whole process, including assessment, strategies, and guidance of the bank for accepted risk levels, for developing and validating provision models, as well as to define additional provisions. As you can see on the chart on the left, cost of risk this quarter rose to CLP 113 billion, up from CLP 89 billion last year, but below the level posted of CLP 139 billion during the previous quarter. However, NPL continued dropping from 1.17% in the third quarter of 2019 and 1.33% in the prior quarter to a mere 0.98% this quarter.
The year-on-year rise in loan loss provisions was due mostly to a recalibration of our internal provisioning models for group-based evaluated portfolios in order to incorporate new information in the context of COVID-19 with an impact of CLP 71 billion. This was partially offset by a release of additional provisions during the month of September for CLP 78 billion of the CLP 105 billion of additional allowances that we proactively recorded in the prior months this year. This was only a small portion of the total additional allowances we have booked on our balance sheet over the years and as you can see on the chart to the right, we have by far the highest level of these reserves in the industry. To note is that these allowances, even after this release, are three times larger than our main competitor.
This figure of cost of risk also includes the full impact of growth in COVID FOGAPE loans, most of them granted during the third quarter, and the full adoption of the provisioning treatment set by the regulator for these types of loans. It's important to note that we continue to see a positive payment behavior from our customers and that this has translated into low levels of NPL and the reduction of charge-offs. It's also important to note that we had a temporary rise in NPLs and charge-offs as a result of the weaker macro environment in Chile due to the social crisis that began in the fourth quarter of 2019. As a result of decisions that were undertaken during these events, our early overdue portfolio began to rise. Nevertheless, we adjusted our collection procedures and began an improving trend in overdue loans.
Despite this change, some overdue loans were not recovered and in line with the temporary rise in NPLs, we saw a brief rise in regulatory charge-offs, which has now more than normalized. As we mentioned earlier in the presentation, we must pay close attention to how these indicators evolve as they are benefiting from the financial assistance that customers received from both the government and banks as part of measures taken during the crisis. We can't rule out in the coming quarters to see a rise in delinquencies as these payment holidays and other benefits come to an end. Our prudent risk policies have made Banco de Chile the most prepared bank to continue facing this weak cycle. All of what I've talked about demonstrates the quality of our portfolio, and our prudent risk management is bearing fruit during this difficult period.
By having a consistent commercial and risk strategy, we have been able to grow our portfolio responsibly and profitably over the long run. We are confident that this risk approach should distinguish us among other banks in the coming quarters. Please turn to slide 20. During this quarter, we continue our focus on cost control as we believe that reaching efficiency in our operations is even more relevant in this challenging scenario. As you can see on the chart on the left, total operating expenses fell 5.9% year-on-year, equivalent to CLP 13 billion of savings. The drop in the yearly cost was driven by lower salaries as well as a reduction in administrative expenses as shown on the chart to the right.
Particularly, we had a reduction in salary expenses related to lower severance indemnities from organizational restructuring that took place in 2019, as well as lower variable compensation as a result of the current situation. As for administrative expenses, the main savings were associated with higher expenses in 2019, associated with the development and implementation of internal projects in order to improve our efficiency and deploy digital transformation initiatives. In addition, we introduced changes in our service models that allowed us to reduce cost and outsource services. Likewise, the use of more effective channel for advertising and customer loyalty enabled us to reduce marketing expenses. Thanks to our cost control efforts, we recorded a slight improvement in our accumulated efficiency ratio that reached 44.6%, clearly outperforming the average level posted by the industry that actually increased during the same period.
We also recorded a positive indicator of expenses to total assets of 1.86% this quarter versus the 2.33% recorded one year earlier. Please turn to slide 21. Even though it's difficult to predict how this pandemic will evolve, since some countries are evidencing increases in COVID cases and a return to lockdowns. We clearly see some signs suggesting that the worst is behind us. As you can see on these charts, we have begun to see a gradual increase in the origination for consumer mortgage loans, as well as a steady rise in terms of new current account openings. We're also seeing a slight improvement in credit and debit card purchases. The low figures seen in prior months was due to the strict lockdowns and the low mobility in Chile, and this caused a significant impact to the credit origination as well as activity in our transactional products.
We are pleased to see a gradual normalization in these figures. This should translate into better income generation as well as in the coming quarters. We are confident that these better perspectives for the economy, together with our superior competitive advantages, will allow us to continue being the best long-term alternative for our investors. Thanks. If you have any questions, we'd be happy to answer them.
Okay. Thank you, sir. The floor is now open for questions. If you have a question, please press star then one on your touchtone phone at this or any time. If at any point your question is answered, you may remove yourself from the queue by pressing star then two. Questions will be taken in the order they are received. We do ask that when you ask your question, that you pick up your handset to provide optimum sound quality. Again, it is star then one to ask a question. Please hold while we poll for questions. The first question we have will come from Tito Labarta of Goldman Sachs. Please go ahead.
Hi, Rodrigo and Pablo. Thank you for the call. A couple questions. I guess, first in terms of your margin, just to understand how we should think about the margins going forward. Maybe to start, how much of your margin is impacted by the FOGAPE loans, and how long do you think that'll continue to impact your margins? How should we think about margins for next year? Do you think you can get some improvement in the margin or increase in the margin? Second question in terms of your provisioning and your cost of risk. Do you feel that, I think you've mentioned, you provision now for everything. Do you think your cost of risk next year can already begin to come down or even in the fourth quarter?
How do you feel about your provisioning versus kind of your expectations for asset quality, going forward, given that the real impacts on NPLs will only happen going forward? Thanks.
Hi, Tito. Okay, well, in terms of NIM, we recorded this quarter a level of four point or 2019. I think it's important to go over a little bit where we're coming from. In 2019, our NIM was around 4.2%. Year to date in 2020, we recorded 3.5%, and in the quarter, 3.1%. It's important to note that if we look at the 2019 numbers, we have to take into consideration certain things that occurred. For example, there's 20 basis points we have to reduce from the level from last year, the 4.2, because of the huge re-level of renegotiations of mortgage loans because the interest rates were very low. That took place mid-2019 when customers began renegotiating.
This, together with the implementation of a new regulation that obligates banks to pay off overdraft lines of credit when customers have funds in their accounts, affects our NIM by about 20 basis points. In summary, for the 4.2% level that we recorded last year, in reality based on the new market conditions and regulations, it's closer to 4%. It's also important to mention some things that happened this year. We have, due to the huge amount of demand deposits that we received, this affects our net interest margins as well because we have to place a portion of those funds in high liquid assets. That's about 10 basis points. For the 3.5% that we recorded this year, if we look at it on an adjusted basis, it should be closer to around 3.6%.
We're comparing 4% and 3.6%. If we look going forward, there's some things that we should take into consideration. First, the inflation should return to the levels of 3% at some point in the future. For every 100 basis points of change in inflation, that's around 15-16 basis points in NIM based on our current gap on our balance sheet. The low overnight rate of 0.5% is temporary. After this crisis is over, it's reasonable to expect that the long-term rate should move back up to the level of 3%- 4%, which is positive for margins, especially us, because we have a huge amount of non-interest bearing liabilities that fund our assets.
For every 100 basis point change in the overnight rate in the long term, this is something around, when we say long term, three to five years, it has a benefit or impact of around 30 basis points, everything else equal. Third, loan mix is super important because in terms of the commercial loans for the FOGAPE loans, they have a low interest rate. If you look at it in terms by segment, it brings down margins, but as a whole for the commercial loan portfolio, it has a higher interest rate than the average interest rate of our commercial loan portfolio. By segment for SMEs have a higher interest rate because they have a much higher level of risk. For the entire commercial loan book, it's actually positive for interest rates. Commercial loans for the FOGAPE.
What's occurring negatively is that the high margin products, such as consumer loans, are decreasing around 12%- 13% for us in the industry. Also those SME loans that normally would grow aren't growing because customers took advantage of the FOGAPE loans. When we look forward, we should think that we should be able to have a better growth in consumer loans, high margin products such as the consumer loans I mentioned and the commercial SME loans. That should, in the medium term, return us to levels higher than what we have today of the 3.5% adjusted. The 4.2% would have to be other market conditions, long-term levels. It's a different portfolio than we had before and regulations. In terms of risk, I think some things that are important to mention is that the environment that we're facing is highly uncertain.
It's something very new to us and the world. This crisis doesn't have an economic root, and it's impossible to anticipate the impacts of the recession on asset quality. This is one of the reasons why it's difficult for us to provide guidance for the future. However, there's some essential things to keep in mind. As we mentioned in the presentation, there's a gradual recovery in the economy for 2021. This is after this important contraction this year. Based on this, we recalibrated our risk models in order to reflect this better way to evaluate this current economic situation. From a prudential point of view, it's undoubtedly much better to have these models that reflect the new normal in the economy.
That's why we use a portion of these, or we basically use a portion or reclassify the portion of these additional provisions that we had recorded throughout the year into this new model. We actually didn't release provisions. We reclassified these provisions, and our actual provision levels are actually higher than they were before than lower. The net effect is actually an increase in provisions this quarter. This change followed with other measures earlier in the year. For example, there is a significant increase in group provisions for companies that were exposed to sectors that were affected by this. The individual loan book portfolio, we are very conservative in terms of that portfolio. We increased the provisions there. This is part of our proactive management for risk approach.
Finally, I think some things to consider is that we have the highest coverage ratio, the very diversified loan portfolio, proven track record of risk management, and we think that this will be key attributes that will allow us to better preserve the value of the bank in the long run.
Okay. Thanks, Pablo. That was pretty clear. Just to, I guess, on the cost of risk, and I know it's uncertain, but how normalized can 2021 be? Do you think maybe first half of the year, your cost of risk needs to remain somewhat elevated, and second half you can get back to normalized levels? I know it's difficult to predict, but just to help a little bit in the modeling, is that the right way to think about it? Maybe higher in the first half and lower in the second half, getting back to normalized levels in the second half?
I think it's difficult to estimate for how this will evolve, especially that there's a lot of government aid and different things have occurred in Chile. For example, the withdrawal of pension fund money, which has helped customers pay their loans. There's still payment holidays for the SME loan book, which come due later on this year or beginning of next year. There's still a lot of uncertainty, which could happen, especially if we look at what's happening in Europe and other areas of a second lockdown. It makes it difficult. Probably before seeing an improvement, there will be still some uncertainty in the medium term before we get to normalized levels.
Yeah. I would like to add, when I hear Tito, we are not providing more guidance for the next year because there are very high uncertainty. It's not clear, for example, how will be the relation between the employment recovery relative to the GDP growth. What we've seen is a positive sign in the Chilean economy, some green shoots, as we mentioned in the presentation, that since we have a very high uncertainty, we think that the most responsible from here is to not provide more guidance for the next year.
The next question we have will come from Neha Agarwala of HSBC.
Hi, thank you for taking my question. My first question is regarding the repayment behavior. Could you give us some color on what percentage of the loans that you had reprogrammed actually came due, and what is the payment behavior of those loans? I'm still not quite sure what was the reason for releasing some of the additional provisions, given that you feel that there's a lot of uncertainty in the environment. What made you take a step like that? I'll ask my second question.
In terms of the additional provisions, I think it's important to mention that those provisions are used for uncertain times. What we did is we updated the models to take into consideration more of these market aspects that were occurring today in the actual provisioning models. We basically reclassified from one part of the book to another, but the net effect this quarter was higher provisions, higher coverage ratio. It was just something that was evaluated on how we could implement this methodology. This was how it was considered the best method to record allowances for the bank.
It's important to mention as well that we have a new macro scenario, perhaps we have a new normal with different parameters. It's very hard to imagine, for example, that the probability of delinquency rate in the future is the same today relative to the previous scenario. What we are trying to do is to reflect on a better way the current economic situation, the current probability of default, for example, in the current economic model. Basically, the idea here is to adapt our models to the new normal in the economy. That's the main idea, Neha.
Understood. On the repayment behavior?
In terms of the repayment behavior, we've had very good repayment behavior from the customers that have had their loans being postponed. Today, most of the customers for the consumer loan book have already repaid. A portion of the mortgage loan book is repaid. We have the SME loans, which still have a little while to go for us and the industry, because that program of FOGAPE, what it entailed is that a customer that took a FOGAPE loan would have all the other loans at that bank would get a six-month grace period. Since this happened during the second quarter of the year, probably the end of this year, beginning of next year, we'll have more information on how that evolves.
What we're seeing today is our postponed book is performing better than the level of our total overdue loans of our average retail loan book prior to the COVID crisis.
It's very important to analyze how the economy will evolve in the future, given the uncertainty. Far, it's been very unexpected, but we have to be cautious relative to the evolution of the economy in the future.
Okay. My next two questions are first on capital and payout. What is your expected impact on capital ratio from Basel's implementation next year? Do you expect any delays in implementation, or it should happen early 2021? What do you think about the payout ratio that you can maintain given that you have the strongest level of capital? My second question is more on the economy. We had the referendum recently. What impacts do you see from the constitutional level? It's a two-year process, how do you think the final impact would be on Chile? Thank you so much.
Hi, this is Daniel Galarce. As you know, we don't have the old regulatory framework yet. The Chilean regulator has published most of the specific regulations regarding Basel III, but we just know the final norms for no more than five or six of them. Far, as we have mentioned in previous calls, regulations are quite similar to our first estimate. We don't see any significant deterioration regarding what we estimated in the past for the impact of Basel III on our capital ratios. Yet, the regulator has imposed or has taken the implementation of Basel III starting in December 2021 until December 2025. We have some time in order to amend any need of reinforcing capital if we believe that it's not enough. However, we are quite confident because we have taken steps in the past in order to bolster our capital base.
As you know, in 2019, we issued subordinated bonds, and also we need to know how the new regulation will evolve and how the market will evolve in terms of Additional Tier 1 capital. We still have a lot of room in order to prepare our capital base and up in order to address the new regulation.
We don't see significant deterioration in our capital ratios due to Basel III, as long as the implementation is gradual. Okay?
Neha, This is Rodrigo Aravena again. In terms of the impact of the potential new constitution, I think that it's very important to say that it's too early as to anticipate potential changes in the constitution as well as in the economy, since it has to be discussed in the new body, and each article has to be approved by 2/3 of members of the elected body. Even though the uncertainty in the process, we are aware of the importance of preserving those critical aspects that have been important in the development of Chile, but it has to be discussed during the next year.
It's important to keep in mind here that the ability of conducting this process with a discussion based on a long-term view that takes into consideration empirical evidence and also learns from international experience will be a positive factor in the discussion and, of course, in the future development of Chile. We think that the most prudent thing is to wait for the discussion to be held in the process during the next year. It's more prudent to wait for the discussion. Having said that, I think that it's very important to keep in mind that Chile has had a very positive recovery in the economy during this year relative to other countries.
In fact, according to the IMF estimate as well as the market consensus forecast, et cetera, Chile is expected to have the best performance on average during this and the next year as a result of the solid fundamentals that we have, as well as the very active response from the Central Bank and the central government as well. We are aware of the potential increase of uncertainty, but it's too early as to anticipate any specific impact coming from this discussion.
Great. Very helpful. Anything on the payout ratio?
Yeah. Regarding payout ratio, we should maintain our dividend policy more or less over the next years. Actually, it has been very consistent over time.
Yeah, I think it's important to mention, however, that this is something that is decided at the board level, and we don't have information until January of this year on how this will evolve. It depends on many different market factors, but in the long term, as Daniel mentioned, it should be similar to the level. In the shorter term, we have to take into consideration what will happen in the short term and how our board of directors will decide to capitalize.
Okay. For next year, it could be lower than 60%? It's not decided yet.
No. There's no decision today for the dividend that we'll pay in March 2021. It's still something that's being analyzed, under discussion, and it's something that the board of directors will review.
Perfect. Thank you so much for your answers. Very helpful.
You're welcome.
Again, as a reminder, if you'd like to participate in today's Q&A, please press star then one on a touchtone phone. Again, that is star then one to ask a question. The next question we have will come from Claudia Benavente of Santander. Please go ahead.
Hi, I have a question. Is it possible or fair to compare the changes that you made to the provisioning model to IFRS 9 that eventually Chilean banks will have to comply with? Do you believe that the important increase that you made on the consumer book reserves would be enough to comply with IFRS 9? Thank you.
Thanks, Claudia. The important increase in provisions, I think you have to take into consideration it depends on the cycle and how this evolves and what point you're in. The models in Chile don't only use non-performing loans. Generally, the difference, the accounting difference of the reconciliation for the 20F, for example, isn't so large an impact like it is in other countries. It's reasonable to expect that this would bring us closer to those levels if we had to apply IFRS 9 in Chile today. The model is different. It's not the same model as IFRS 9.
No, I understand.
I just wanted to make sure if, because at the end, like you mentioned before, that the change could translate into an expected loss base, so it should be kind of more similar to IFRS 9, so it probably can help you to at least comply with the new regulation in a way?
Yeah. For IFRS 9 in the 20F, for example, it is around a similar level of the CLP 70 billion that we recorded. It is a similar level, not exact, but it is similar. In terms if we had to apply it in the reconciliation, the impact wouldn't be so significant anymore.
Perfect. Thank you.
Welcome.
Next we have Domingos Falavina of JPMorgan
Hello, good morning, everyone. Thanks for taking the question as well. Just want a quick recap. I know it changes based on your balance sheet at the quarter, looking at your balance sheet today, 100 basis points of higher UF inflation, what impact would it have on either NIMs as well as on tax rate? The ballpark estimates you're referring to, and sorry if you mentioned that before I couldn't join the whole call.
In terms of the gap on the balance sheet, we have about CLP 5.8 trillion gap on the balance sheet. It runs between CLP 5 trillion and CLP 6 trillion. For 100 basis point change, that changes net interest income between CLP 50 billion and CLP 60 billion, which is around 15 basis points in net interest margin on how we calculate it. When you look at the effect of tax rate, you have to look at two things. One is that operating, because we have more assets in UF than liability, we have a positive impact of higher inflation. But at the same time, the tax authorities use inflation accounting to calculate the price level restatement expense. You have to take the net non-monetary asset position. We have more liabilities linked to UF than our assets linked to UF that are non-monetary.
Our assets are fixed, our equipment, property, et cetera, and our liabilities is equity. You take basically that position, multiply it by the inflation for the period, and that's your price level restatement loss. The calculation, generally, when it's running around 3% inflation, generally, Banco de Chile should be around effective tax rate of 23%, 24%.
Very helpful. Thank you very much.
if it was zero, it would be closer to.
Well, no further questions at this time. We will conclude the question and answer session. I would like to turn the floor back to Banco de Chile management team for any closing remarks. Gentlemen?
Thank you for participating in this conference call, and we look forward to speaking with you for our year-end results.
Thanks.
All right. Thank you, gentlemen. This concludes today's presentation. At this time, you may disconnect your lines. Thank you again, everyone. Take care and have a great day.