Liikanen Group survey Response by Kreissparkasse Esslingen-Nürtingen to the Liikanen Group survey Contact: Marcus Wittkamp marcus.wittkamp@ksk-es.de | Tel. no.: +49-711/398-44307 Kreissparkasse Esslingen-Nürtingen Kreisssparkasse Esslingen-Nürtingen is one of Germany’s major savings banks, with a business volume of almost €8.5 billion. It has been operating in the district of Esslingen for over 160 years. Its dynamic development from its modest beginnings in 1848 to its current significance as a leading regional bank is due to its position in an economically strong, densely populated district and to its strategy of offering financial services tailored to the market and customers. The following summary contains the main business figures relevant to the development of Kreissparkasse Esslingen-Nürtingen. 2010 2011 €8.454 million €8.464 million €8.319 million €8.317 million €5.385 million €5.623 million €4.628 million €4.814 million Business volume Balance sheet total Deposits Loans Investments in securities and in €3.438 million €3.332 million other financial institutions Profit for the year €11.2 million €11.6 million Core capital €438 million €549 million Employees 1,658 1,662 Branches / self-service express banking facilities 107 107 Cash machines 141 142 Self-service statement printers 101 9 As a regional bank operating beyond local boundaries, the bank operates 273,203 private and business current accounts and 325,995 savings and fixed-term deposit accounts. It has the densest branch network in the district and also has centres of excellence for business customers, asset management, and property and construction finance. With 1,662 employees, Kreissparkasse is one of the largest employers in the district and, with 126 apprentices, is also one of the largest businesses providing on-the-job commercial training. The business district covers approximately 650 km 2 and has a population of around 515,000, 92,000 of whom live in the town of Esslingen. Kreissparkasse Esslingen-Nürtingen Page 1 Liikanen Group survey Answers to the questions 1) To what extent are the current and ongoing regulatory reforms sufficient to ensure a stable and efficient banking system and avoid systemic crises? The fact is that the financial crisis will necessarily have regulatory consequences. In our view, however, the reforms, whether imminent or already in place, will be unlikely to create stability in the banking sector but will be more likely to make the financial institutions more preoccupied with observing the regulations (internally) than achieving their objective. For example, if we consider the requirements arising from MaRisk and Basel III, one-third of them affect merchant banks and the remaining two-thirds banks’ lending business. However, it was merchant banks which were primarily responsible for the financial crisis. The disparate implementation of Basel III is a further aspect. The USA is currently planning to implement Basel III in around 20 major banks out of the over 8,000 financial institutions but, on the other hand, it is being implemented in every bank in Europe, or at least in Germany. A further aspect is the distortion of competition, which has been increased by state intervention in the banking market. The major banks are deemed to be too big to fail, and banks bailed out by the state are engaging in cut-throat price competition, which is endangering regional institutions such as savings banks. This calls the three pillars of the German banking market into question. In this connection, the liability obligation and guarantor’s liability to the savings banks has been interpreted in the past as an inadmissible state guarantee. This guarantee now exists de facto for the major banks. 2) Which structural reforms would improve the safety and efficiency of the banking system in the EU in the near term? In the long term? The current three pillars of the banking system are efficient as far as the customer is concerned. The coexistence of the various structures on the German banking market has proved its worth in times of financial crisis and spared German savers any negative experiences. This should not be changed in any way. In this connection, it was German savings banks in particular which have been guaranteeing the supply of credit during the current crisis, by their regional business policy and fulfilment of their public duty to provide credit, whilst the major banks have been tending to withdraw and are now increasingly re-emerging as local competitors. Nevertheless, almost half of loans to SMEs come from the Kreissparkasse. The sustainable business model of the savings banks proves that local confidence is the key to the long-term success of a financial institution. Investments in the community must not be ignored here. Kreissparkasse Esslingen-Nürtingen supports many bodies on its territory with over €5,500 per Kreissparkasse Esslingen-Nürtingen Page 2 Liikanen Group survey day, which proves that it would be much more difficult to hold social, cultural, sporting and educational events without savings banks. The business figures of Kreissparkasse Esslingen-Nürtingen show that savings banks which have such a “local” business model are very successful - it approved new loans worth €766.7 million in 2011. This means that the year-on-year increase in the volume of loan approvals was again significant. The total volume of loans to businesses, private individuals and the public sector (including debenture loans) increased by 4.0%. On-balance sheet customer deposits - an important figure, because savings banks refinance themselves according to the motto “local banks for local benefit” mainly from regional customer deposits - were 4.4% above the previous year’s figure in the 2011 financial year. Total savings (i.e. the growth of all on-balance sheet deposits, including securities transactions) rose by around €293 million. The stable operating result which this generated meant that Kreissparkasse Esslingen-Nürtingen already meets the equity demands of Basel III and has reserves which have been increasing for years - at 17.5%, the total under §2, sub-paragraph 6 of the [German] Solvency Regulation (SolvV) substantially exceeds the level of 8.0% set by law. The figure has consistently been at this high level for years. The introduction of a financial transaction tax in the short term is the only proper way to achieve the structural reforms to contribute to security and efficiency in the banking sector. If one considers the relationship between the current circulating volumes of OTC derivatives and BIP, the necessity becomes more than obvious and the role of the unregulated or barely regulated shadow banking ("conduit") system very questionable. In the long term, the USA must contribute to implementation of Basel III, particularly as it has not even implemented the Basel II stipulations. 3) What are your views on the structural reform proposals to date (e.g. US Volcker Rule, UK ICB proposal)? What would be the implications of these proposals on your institution and the financial system as a whole? The planned ban on US banks from dealing for their own account (US Volcker Rule) may suppress demand for European government bonds and thus contribute to the aggravation of the Euro crisis. The background is that if the US banks are no longer allowed to deal in European government bonds at their own expense, the demand for them will fall. This would be a major problem especially for Portugal, Italy, Greece and Spain, because they are already finding it difficult to sell their bonds. The UK’s ICB proposals entail the risk of the bonds being downgraded. This would be counter-productive, as we are of the opinion that the bond market has already Kreissparkasse Esslingen-Nürtingen Page 3 Liikanen Group survey priced in the changes in the economy. A further deterioration of the ratings would entail higher funding costs for the banks. This would have direct consequences for German financial institutions and their profit margins. To summarise, we assume that these regulations are only intended and suitable for major international banks. An opinion on this is also being issued by the Deutsche Sparkassen- und Giroverband, the umbrella organisation of the savings banks. 4) What are the main challenges of your financial institution as regards resolvability? Are you implementing structural changes to your institution in the framework of your recovery and resolution planning? We have made a huge effort in recent years to improve the risk management of our financial institution permanently. Difficulties for savings banks are generally extremely unlikely. In this connection, we wish to mention the comprehensive introduction of rating and scoring systems in all customer segments. We use the credit portfolio view to manage our loan risk. Other types of risk are also controlled strictly and efficiently using existing methods, and our risk coverage capability is clearly adequate for covering existing risks. In addition, as a savings bank, Kreissparkasse Esslingen-Nürtingen is a member of the bank guarantee system of the German Savings Banks Finance Group. Should a financial institution be unable to overcome difficulties itself, the bank guarantee system will provide solvency and liquidity. Within the scope of risk monitoring, these aspects are evaluated in every savings bank and the risk profile of the respective savings bank categorised by a traffic light system. If a financial institution has a red traffic light, additional escalation measures are implemented to improve its risk situation. Against this background, we consider the greatest challenges to lie less in the risk situation and equity ratio, and more in fulfilment of the Basel III liquidity requirements. In general, however, we are auditing each of our business fields and considering the structural changes required for our business model, e.g. as a result of Basel III. Kreissparkasse Esslingen-Nürtingen Page 4