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ING Groep N.V. (ING)

Q3 2021 Earnings Call· Thu, Nov 4, 2021

$28.08

+0.02%

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Transcript

Operator

Operator

Good morning. This is Anita Hila, welcoming you to ING's Q3 2021 Conference Call. Before handing this 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 regarding future developments in our business, expectations for our future financial performance and any statement not involving a historical fact. Actual results may differ materially from those projected in any forward-looking statement. A 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 earnings 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.

Steven Van Rijswijk

Management

Thank you, operator. Good morning, and welcome to the third quarter '21 results call. I hope you're all well. I'm joined by our CFO, Tanate Phutrakul; and our COO, Ljiljana Cortan. And I'm happy to take you through today's presentation. After that, we will take your questions. We are already in November and looking back on '21 so far, I see two big themes. One is we learned to cope with COVID-19 and the effects of economies closing down and quickly rebounding. The other is climate change and the urgency to accelerate actions to transition to a low-carbon society. And we support this acceleration where we can have the most impact as a bank, which is by supporting our clients in our transition. Now focusing on our quarterly results. Our pre-provision result was good, with continued strong performance on fees, a resilient NII, net interest income and cost control. And I'm pleased that we are reporting such a strong performance despite the pressure on liability income, higher swap rates are a good development, but as I mentioned before, it takes time before we see the positive effects and overall rate levels are still negative. On lending and mortgage, we'll continue to grow. On the business side, we saw some demands from mid corporates coming back, while in Wholesale Banking repayments were at the higher level. Year-to-date, we are at an annualized 3.8% net core lending growth, so in line with our loan growth ambitions, though on the business side, there is room for improvement. Risk costs were €39 million, where lease part of the management overlays applied in the previous quarter, reflecting robust GDP forecasts and improved risk indicators in our loan book. Overall, asset quality remains strong with limited risk costs in individual files and a low Stage 3…

Operator

Operator

Thank you, sir. [Operator Instructions] The first question is from Mr. Benoit Petrarque, Kepler Cheuvreux. Go ahead please, sir.

Benoit Petrarque

Analyst

Yes. Good morning. Thanks for taking my questions. The first one is on lending growth. So we have seen some repayment of short term facilities in the wholesale banking segment. I wanted to try to get a kind of underlying view on the current loan growth in the wholesale banking. So could you help us on that one? And also, looking at lending fees up 20% Q-on-Q, I assume that your pipeline for the fourth quarter is quite good. So just wanted to have your view on, well, lending growth also beyond Q3? And then second question is on NII. Looking at the two main moving parts, and I will be the first one, the drag from the replicating portfolio. I think you guided for front book, back book gap of 25 bps on the yield. Just wondering where you are today. And at the current interest rate level, do you expect, let's say, the drag to be offset by loan growth? Or we still have still kind of at a still decent level in terms of pressure from low rates. So I just wondering where you are now. And then maybe on NII, just sub question on that. On the negative charging of EU, I think you guided for an incremental of €120 million in 2021. I was wondering if that's still the kind of overall guidance for 2021? Thank you.

Steven Van Rijswijk

Management

Okay. Thank you very much. We are riding [indiscernible] the operator said to when you came five questions, so I have to ride quickly. So let me take the – mortgage [ph] questions and then on NII and the gap yield to the direct – drag that we still experience, I will give that question to Tanate. So first of all, Benoit, on your question on the net interest rate charging. So the guidance for the next year, we have up to €300 million. That was initially €20 million believe, and that is now up to €300 million. So that has gone up. If I look at loan growth in Wholesale Banking, for this quarter, we had a growth in trade commodity finance, we see already growth in syndicated loans that also came out in our fees because they are also - part of the growth in fees came from syndicated loan fees. These are not only yet booked, but we do see an increase in those fees, and that shows that the syndicated loan market is coming back again, at least for now. And on the flip side, we do see that the number of short-term facilities have been decreased and being repaid. So we still do see a mixed picture. And like we said, if we were helped, of course, by the economic developments and by the growth in GDP in 2021 and that growth will need to continue and it's currently being expected to continue in 2022. And that will also help to resume loan growth in wholesale banking. If you look at the lending fees, I mean, like I said, the question is, am I optimistic in one of my presentations that there is more - that there can be more to come. And we believe…

Tanate Phutrakul

Analyst

So Benoit, thanks for your question. I think if - we don't give guidance specifically on NII, but kind of input factors into sustaining our NII, which is the fact that we need to have somewhere around 3% to 4% loan growth. And so far, with some patches here and there, we're confident that, that loan growth at that pace will resume. The second thing that we rely upon is the fact that our origination margin on loans remains robust and that is the case during the course of Q3. We also rely on to a certain degree of negative interest rate charging and as Steven has mentioned, basically this year we made €220 million from negative rate charging, which will rise to €300 million base on action already taken this year. So those are key components. And then the last component is really about how the financial markets are moving at the moment and how the yield curve is affecting us. And quite frankly, high yield curve is beneficial for us and that we replicate approximately 20% of our savings book on an annual basis. So while it has taken time for the replicated impact to come down, it will also take somewhat a certain amount of time for the replicated benefits to come up as well. So it will be a gradual process. The only caveat I would make is, of course, if short-term rates were to move fast and it could have a more immediate impact in our results. And to give you a couple of moves that we already saw in October. Poland has, for example, today, increased their rates. And then Romania has increased rates. These are small markets for us. But that, for example, would have immediate beneficial impacts on our results in a sooner period than what I just described. Okay

Benoit Petrarque

Analyst

Great. Thank you very much, guys

Tanate Phutrakul

Analyst

Thank you.

Operator

Operator

The next question is from Ms. Giulia Miotto, Morgan Stanley. Go ahead, please.

Giulia Miotto

Analyst

Yes, hi. Good morning. My first question is on costs. So I believe that ING wants to lower the underlying cost base, excluding the greater cost, excluding one-off, excluding business access. However, the wage market and the labor market in the Netherlands and the core European market is going pretty strong, and we see inflation basically everywhere. So what are you seeing in terms of cost inflation? And how do you expect that to develop next year? So that's my first question. And then in terms of the deployment of capital, I just want to confirm that I understood it correctly. So I think you said that you intend to return excess capital via specials. Was that specifically point into special dividends rather than buybacks or the excess capital can be returned with a mix of special -- sorry, of special dividends and buybacks? Thank you.

Steven Van Rijswijk

Management

Thank you very much, Giulia. On costs, and look, we will - I will continue to be disciplined on costs. We do reinvest part of the savings that we got from the actions that we have taken, but the discipline will continue. And therefore, we also continue to monitor the right direction of our cost trajectory. We still intend to bring the cost down. And in the past, we have been able also this year to absorb inflation also in the Netherlands, but also in other jurisdictions. And we are -- we'll take that on the chin and we'll continue to see in how we will be able to compensate that. On capital, there, you ask whether that is probably means of dividend or by a share buyback or capital distribution, we don't know it yet. We will give you more information about the specials at the first quarter results 2022.

Operator

Operator

Okay. The next question is from Mr. Stefan Nedialkov, Citi. Go ahead, please.

Stefan Nedialkov

Analyst

Thank you very much. Good morning, guys. Stefan from Citi. A couple of questions on my side. On capital, I am not 100% clear how to square the comments on Basel III/IV being fully absorbed and an additional €8 billion coming out. Is the €8 billion from the mortgage floors going to be offset by a release of some of the RWA top-ups you took this quarter? If you can just kind of explain the moving parts there. And also to confirm that based on the European Commission draft legislative proposal of Basel III that was published at the end of October, based on that proposal, you're not seeing any sort of incremental impact. So that's on capital. And a second question on Turkey. Can you update us on the intragroup funding into Turkey as of 3Q, please? Thank you.

Steven Van Rijswijk

Management

Thank you very much, Stefan. On the inter group funding, that has come down from last quarter, €600 million to now €500 million. So that has come down with €100 million. And then on Basel IV, so what I meant to say was that we still have the mortgage floor that will kick in, in 2022, in the Netherlands that we estimated €8 billion currently. And that is what we call a prelude to Basel IV. So when Basel is introduced, it will have the same effect as the €8 billion. So it is not being taken off the table, but Basel IV will not add anything else because basically, by means of this floor that measure then already is taken for our mortgage portfolio in this country. And with regards to the EC legislation and the legislative proposals regarding Basel III, that does not mean further incremental capital increases for ING.

Stefan Nedialkov

Analyst

Thank you. Just to confirm, when you made the comment that the regulatory impacts have been mostly absorbed, you meant except for the €8 billion?

Steven Van Rijswijk

Management

Yes, I'm sorry, indeed, except for the €8 billion.

Stefan Nedialkov

Analyst

Thank you so much.

Steven Van Rijswijk

Management

Thank you.

Operator

Operator

The next question is from Mr. Omar Fall, Barclays. Go ahead, please.

Omar Fall

Analyst

Hi, there. And just firstly, just a couple of clarifications on numbers. How much was the prepayment penalty amount in mortgages in the Netherlands roughly? And then -- sorry if I've missed this, but what was the Q-on-Q increase negative charging benefit in the quarter? And then on - in the similar kind of numbers question, but just on the restructuring costs announced so far for the businesses in runoff Czech Republic and Austria. Is that largely complete and all that's pending is France, basically? And then ex the numbers, my question would just be on fees and commissions. Could you let us know specifically by geography, what is left now in terms of pricing changes on daily banking fees? I think in the last quarter, you readily mentioned Southern Europe. But I guess it's just hard because if 1 looks at advertised prices, it's a bit unclear where you differ from incumbents locally now. So is it a case of kind of new customer versus existing customer pricing? Or if you could just give us some specific geographies and products where there's still a material difference. That would be very helpful. Thank you.

Steven Van Rijswijk

Management

Thank you, Omar. And I'll take the questions on restructuring costs and fees on prepayment and near quarter-on-quarter, I will leave it to today. So first of all, on the fees, I mean what I can be specific on is that we already announced further payment package increases in the Netherlands, which will start as of the first of January 2022. There are also some small ATM increases in Australia that we will be going through. So we will -- we have announced several things. And as soon as there is more to announce, we will let you know, but I can, of course, not make forward-looking statements. But like I said, the lever that we have to pull in terms of the growth of our primary customers. The fact that we are still operating in low fee markets that were still behind the number of the products for other markets and that we can still develop new services that were rolling out is helping. And you have seen we have been increasing everywhere around the globe in all markets. We have been increasing all of them. On restructuring costs and restructuring, Czech Republic is completed. Austria is nearing completion, but not quite there yet. In France, you know that we are currently having a review pay vision. We just made the announcement on the provision, but the restructuring in that sense, still needs to happen. The rolling off of Payvision, which will happen in the course of 2022. So most of it is currently undergoing, but not completed yet. Tanate?

Tanate Phutrakul

Analyst

Omar, to answer your question on the first prepayment fees on mortgages, just to clarify from an accounting perspective, these prepayment fees appear in our net interest income line, right? Just to not confuse about fees because we talked about prepayment fees. I think the amount of prepayment fees in the Netherlands is approximately €49 million which is €10 million higher than the same period last year. That's to address your question on prepayment fees. And on the negative interest rate charging, as we mentioned, the full year impact is about €220 million, of which the Q-on-Q increase is approximately €30 million, okay? So that's addressing your first question.

Omar Fall

Analyst

Perfect. Thank you.

Tanate Phutrakul

Analyst

Thank you, Omar.

Operator

Operator

The next question is from Mr. Johan Ekblom, UBS. Go ahead, please.

Johan Ekblom

Analyst

Thank you. If we can just continue on the net interest income for a second. This increased guidance on negative deposit pricing for next year, does that mean that there is an incremental benefit into Q4 or into Q1 on the kind of Q3 run rate? So that would be the first part. And then secondly, you spoke briefly about the gearing to higher short-term rates. If we look at the...

Steven Van Rijswijk

Management

Johan, your...

Operator

Operator

I'm afraid he has lost his connection. I will go to the next person for now. That's Mr. Tarik El Mejjad, BoFA. Go ahead, please.

Tarik El Mejjad

Analyst

Hi, good morning. Two quick questions please. First of all in the cost of risk, you’ve mentioned your guidance of I think below or around 20 basis points, 20, 25 basis points. I want to know, you are thinking to change this guidance for this year and next and if you can give us elements of if not why would you have any concerns on pick up of sketch [ph] fee provisions in Q4 onwards? And then second question on actually timing of your investor day next year, mid June, are you waiting for more reduction in the [indiscernible] and regulation or I would believe you would like to quickly give us more short term guidance on the high [indiscernible] more normalization of your excess capital. Just to understand why this need to mid year, next year?

Steven Van Rijswijk

Management

Thanks. I think that, the main reason for the date is because we want to pick a date in 2022, we saw that it was a good date, there we want to give you a further update on our strategy and the direction and the progress that we're making in the direction of the bank. The months of April and May are typically also busy and all kinds of other internal strategic meetings. So that's why we chose June and that there are no other reasons behind it, and we are very keen to see you there. And on cost of risk, I give the floor to Ljiljana.

Ljiljana Cortan

Analyst

Good morning, Tarik. And let me reconfirm that our risk costs for '21 will remain well below the through-the-cycle average. And we are feeling very much comfortable about it based on the strong quality of our loan book and also risk management frameworks in place, as mentioned before, that haven't changed during the pandemic or post, and we continue our prudent approach there. So no reason to see fourth quarter different than what we've seen so far.

Steven Van Rijswijk

Management

Okay. Thank you very much. Sorry, operator, do we go back to Johan? Is he back? Or do we move forward?

Operator

Operator

Mr. Ekblom is back in the call. I will go to him a moment, please. Mr. Ekblom, your line is open once more.

Johan Ekblom

Analyst

Thank you. And thanks for letting me back in. Apologies for that. But just very brief. So the first question was, is there any further sequential benefit to be had on the deposit repricing? Or is it just that -- it's not a full year effect this year, and it will be next year? And the second one was just in Poland. I mean, I think if I look at the results of your Polish subsidiary, NII was up 5% Q-on-Q. So just trying to understand what's the phasing in of the benefit of rate hikes there? Is that more or less a full benefit of the first 50 basis points in there? And can we sell as a proxy for the rate hike we had yesterday? Or is there a delay and there is sort of even more to come?

Steven Van Rijswijk

Management

Tanate will do both answers. So first is on NII, near in terms of what will come because there was a question you at before you drop off, what will come still in the fourth quarter? And how will it phase in into the next year? And the second one is on Poland.

Tanate Phutrakul

Analyst

Thanks, Johan. I think on NII charging, as we mentioned, it's about the, first of all, action we already announced and taken, right? So it's not about any future actions that may take place just to clear that up. The second one is, of course, that as things take place, for example, negative charging in the Netherlands and Belgium started in July, negative charging for a certain high net worth individual in Germany starts in November. So these will affect the results going into next year. So it's not that you see the bump in Q3, and it stays at this level. There's a certain gradual increase because of the time delay of the calendar year. So that's to address your first question. The second question with respect to Poland. The impact of the rate hike is not in our numbers because it's recently announced. I think the strong drive in terms of NII in Poland is much more to do with the strong commercial growth strong loan growth that we see in Poland at good spreads and that we are doing quite well, in fact, very successful in terms of market share in Poland.

Johan Ekblom

Analyst

Perfect. Thank you very much.

Tanate Phutrakul

Analyst

Thank you. Okay, now we move on.

Operator

Operator

The next question is from Mr. Kiri Vijayarajah, HSBC. Go ahead please.

Kiri Vijayarajah

Analyst

Yes, good morning, everyone. A couple of questions, if I may, on the gearing to higher oil and energy prices that we're seeing. So firstly, to what extent does that feed through potentially into wholesale banking volumes from bigger ticket sizes and potentially more energy CapEx you're seeing in the pipeline? Or is it more a case that you're still somewhat cautious on growing the energy commodity side of things, I guess, particularly with ESG considerations, et cetera. And then in a similar vein, in terms of asset quality, does the higher oil price give you scope for maybe more provision releases, I'm thinking particularly on the Stage 3 book and also what kind of timing should we see that potentially with 4Q? Is that more a kind of 2022 thing? Is that higher oil and energy prices be through into your provisioning models? Thank you.

Steven Van Rijswijk

Management

So Ljiljana will take the question on the provisioning levels and the quality of our book. If we look at the oil and gas, well, currently, what we did see, we saw a small uptick in traded commodity finance as a result of the higher oil prices. What we do see is that gradually -- and that's the reason also why the book grew based on higher oil prices. But we also do gradually see higher working capital needs coming in, and that could actually then help that business going forward. Having said that, that links to your ESG comments when we talk about the upstream oil and gas sector and especially upstream oil sector, there we have a commitment made and that commitment we pulled forward from 2004 to 2025 that we will decrease our commitment to the upstream oil and gas sector by 2025 with 12% and because we want to be for that sector also at the net zero path. Ljiljana, asset quality.

Ljiljana Cortan

Analyst

On the asset quality and impact from the high energy prices. Yes, we are monitoring our portfolio very closely, and we are engaging with our clients in order to understand their positions. And I can confirm that so far, we haven't taken any additional provisions based on that as well have not released any provisions based on that. Looking forward, we will continue engaging with our clients in order to understand their needs and clearly to assess eventually identify the risks in those portfolio. So far, there is no guidance or view on whether it's going to be further released. What we can say is that clearly, as for parts of the economy, high energy prices will present the benefit, but for some other parts, clearly, there will not, and we are looking at overall picture. And clearly, we'll also assess our strategy going forward over this sector.

Kiri Vijayarajah

Analyst

Thanks.

Operator

Operator

The next question is from Mr. Jean Neuez, GS. Go ahead, please.

Jean Neuez

Analyst

Hi, morning. And thanks for taking my question. I have two questions, one is on fees and deposit pricing. So when you apply the new negative rate at the negative rates to new thresholds of clients and fees also on certain products, I just wanted to understand if we go into a rising rate environment, such as the ones that you've seen in some of your growth and challengers market, how sticky do you think these new fees and deposit pricing you can keep if the environment which pushed you to introduce them in the first place that of negative rate changes in the future? And the second thing I wanted to ask was with regards to your comment on the time to yes in the -- in your introductory remarks, is very interesting, how much you've been able to reduce it. Just wanted to understand where you think you stand versus your competitors? And whether you've seen any tangible benefit outside of simple plan satisfaction. Do you -- does that make you gain share or be able to have a better pricing just because you're faster? And related to this is, is there anything in terms of risk parameters that you have to kind of simplify or maybe overlook as you do that, just to check? Thank you.

Steven Van Rijswijk

Management

Thank you very much. And on customer experience, what we do measure and we have specific measurements in the organization is how we measure easy, smart and personal. And we have specific metrics, how we deal with that in each every market. We also look at mobile sales, for example. And we also look at the time and the easiness that we then do business with our clients. And one of the metrics here is time to yes and we also have time to cash. And we also look at how much of our loans can be pre-approved, what's the percentage greenest, the percentage red and then the percentage of gray which then is then a fallout to someone that then has to intervene. So then personally, there are personal intervention. And we have all these metrics to improve our customer experience and to make it smart, personal and easy. And we do that because we believe that the differentiation of that customer experience will also be the differentiator in doing business. And what we, therefore, measure at the same time is Net Promoter Scores, not only at an overall customer satisfaction level, but also at a product or even at a, I would say, if you look at AI, a bot satisfaction level. How satisfied are you with the usage of this chat bot [ph] in your conversation? And we mentioned that continuously because that customer satisfaction helps to improve our experience and with that mobile sales. And what we do see is that our MPS is still at very high levels. And that's what we find important because that's we believe that customer satisfaction will drive our revenues as well. We do not have figures on all the sub-elements like I just said time to years time to cash. But what we do know is what the NPS scores of our competitors. And we do track that regularly in 5 of the 12 markets that we are in. We are in number one and then we're the number two in a couple of markets, and we want to be high on the customer satisfaction because in the end, that is for us a key differentiator. Tanate?

Tanate Phutrakul

Analyst

Jean, to address your point with respect to fees and rates movement. I think fees, as Steven mentioned, our fee levels for comparable product as due low compared to competitors. So I think with rising interest rate, we believe post remains good value and remains sticky for our customer base. Then on the rates itself, I think just going back even 18 months ago during the period of COVID, our retail deposit book is one of the most stable and sticky part of our balance sheet, right? It's one of the great strengths of ING, if I may add. And I think as long as the rate hike by central banks are happening in a gradual manner, we think that we can reprice our assets ahead of our liability book. So I think we're also confident that the deposit book, given not too steep, not too sharp rate increases. We can keep that asset prices rising beyond the liability side.

Jean Neuez

Analyst

Okay. Thank you very much.

Operator

Operator

The next question is from Mr. Raul Sinha, JPMorgan. Go ahead, please.;

Raul Sinha

Analyst

Hi. Good morning, all. Some of us probably don't want to wait until June next year. So I wanted to ask you about the 12.5% ambition again. And we see the gap keeps expanding every quarter as you build capital. Maybe to ask it slightly differently, Steven, consensus currently models your CET1 ratio reducing to 14.9% next year but remaining stable at 14.9% in 2023. Do you think that appropriately captures the pace at which you want to normalize to your ambition?

Steven Van Rijswijk

Management

Right. Okay. So basically, from what I got, Raul, your question is for me to comment on the consensus of the pace of the capital decrease. Is that what the question is?

Raul Sinha

Analyst

Yes. Basically, we are expecting the some total of expectations in the market is that your CET1 is still going to be almost 15% till 2023. Is that fair?

Steven Van Rijswijk

Management

Yes. Okay. Okay. Well, look, I leave the consensus for the consensus for now. But I think what I think -- what I find important is that we have just taken a first step by doing a share buyback, which we have not done for -- And so -- and we got approval for that share buyback. And we've also said that after we have completed a share buyback, we will announce new specials. And I do realize that with our dividend policy of 50% of resilient profits that require us to pay a significant higher amount to be able to bring capital down. Now I cannot tell you about our conversations with the supervisor. I will never do that. But I would like to point out of the good outcome and the pleasant conversation that we've had with the supervisor when we talked about the share buyback that we're currently executing. And that is in that conference, I want to exuberate when we move to the next steps when we talk about the specials to move to us to 12 to 12.5% over the next couple of years.

Raul Sinha

Analyst

Okay. Did I hear you correctly, when you said, you will update on the next distribution in Q1 2022, does that mean we should expect an update at full year results?

Steven Van Rijswijk

Management

That means that you should expect some update at the first quarter results 2022, yes.

Raul Sinha

Analyst

So that's in May? Okay.

Steven Van Rijswijk

Management

Yes.

Raul Sinha

Analyst

Got it. Thank you.

Steven Van Rijswijk

Management

That's before June.

Raul Sinha

Analyst

Yeah.

Operator

Operator

The next question is from Mr. Robin van den Broek, Mediobanca. Go ahead, please.

Robin van den Broek

Analyst

Yes. Morning, everybody. Thank you for taking the questions. First question is on the flexible credit compensation that you took in cost. I'm just wondering, I mean, you have more variable rate products in your product portfolio. Could you just talk a little bit about what kind of tail risk you could see on those products and now there is some consumer claims or some claims organizations still out there that are paying the drums on that? Secondly, in your RWA waterfall, you have €11 billion of ongoing redevelopments of internal models and EBA guidelines impact. The work ongoing, I guess, is just a reflection that you'll have ongoing internal model redevelopments, but not necessarily of negative impact as big as we've seen in Q3. I was just wondering if you could comment a little bit on that. And lastly, I want to spoke to your Investor Relations department this morning. They also mentioned that you had a change in tax rate guidance planned for this fall. I think I haven't heard that yet. So just wondering about that. Thank you.

Steven Van Rijswijk

Management

Okay. I'm now looking fondly at Mark Milders, like what are you been telling. But I will that question to Tanate. On the other two, if you talk about KiFiD basically we are following the KiFiD independent mediator which basically looks at complaints of clients and then comes to a verdict and that was put in place to actually make sure that there was an independent party. He overseas that and can come to a very pretty quickly so that those elements can be then taken into account by banks and then if need be compensates the customers. And that is what we're doing. We're following exactly these guidelines of KiFiD. Based on those guidelines, we want to compensate our customers for a market rate that whilst not a consistent market rate in past, it was not a clear market rate, so the information provision to our clients was not sufficient clear. And therefore we then use the market rate that we should have used to then composite our clients on the basis, in line exactly with what that buddy KiFiD is saying that we should do. And we are currently also talking to the consumer organization to see how to best do that and then contact our clients as of December to then pay these amounts in 2022 and then be done with it in 2022. This is our current best estimate. And based on what we can see, we've taken all elements of KiFiD into account, and that's where we currently are. So for -- as far as we can see, we have provided prudently for that. With regards to our models, yes, you're right. I mean there's always model updates. We have a number of rating systems, which consist of PD, LGD, IFRS, EAD models and so forth and so forth. And I have also some financial markets more. I can bore you with this for ages. And Ljiljana looks now very enthusiastic. She wants to talk about this. But we will not do that. But we have regular model updates and sometimes it will be in up and sometimes it will be down. but there's just nothing out of the ordinary. So €11 billion was a, in that sense, a special event. What we meant with the EBA guidelines is that we need to have certain compliance here with some which model redevelopments as per the first of January 2022, and that is now being taken into account. Tanate, what the hell that Mark Milders is saying?

Tanate Phutrakul

Analyst

So its just on tax rate, I know you guys needed to calculate our net profit after tax the weighted average tax rate. And also to calculate our ROE. And so from time to time we gave guidance with respect to the effective tax rate. Our previous guidance was to have our effective tax rate in the range of 28% to 30%. And now we're giving a different guidance that we expect in the coming periods that our effective tax rate will move down from that level to 27% to 29%, okay? And this is due to changes in our deductibility in terms of certain items and also geography some of our profits are shifted to lower geographies, so on a tax perspective, so this is a move that we wanted to flag to you, the shift in tax rate.

Robin van den Broek

Analyst

Thanks. So Steven, just one follow up on the KiFiD [ph] I was also referring to other products at variable rate, like mortgages or SME loans, where the pocket range for the [indiscernible] where you may not have to reflect the reductions in market rate to your clients appropriately. Do you see any fill rates coming on that side…

Steven Van Rijswijk

Management

No, okay…

Robin van den Broek

Analyst

Something you worry about?

Steven Van Rijswijk

Management

No, I'm not so sorry about that because I mean on mortgages in these types of private individual products, they were all linked to public market rates. It was for that for some of the variable loans or credit cards, there was no public market rate that was referred to. So the banks refer to an internal rate and for customers that wasn't clear, but that's not the case with mortgages.

Robin van den Broek

Analyst

Okay. That’s very clear. Thank you.

Steven Van Rijswijk

Management

Thank you.

Operator

Operator

[Operator Instructions] This was the last question.

Steven Van Rijswijk

Management

Okay. Then I would like to thank you very much for your attention, and I hope to speak soon. In any case, we'll speak in 3 months time. Thank you very much, and have a great day.

Operator

Operator

Ladies and gentlemen, this concludes the conference call. Thank you for attending. You may now disconnect your lines. Have a nice day.