Germany Increases Banks’ Countercyclical Buffer

On 27 May, Germany’s bank supervisor Bundesamt für Finanzdienstleistungsaufsicht (BaFin) published a recommendation of the
national financial stability committee that would require banks to hold an additional 0.25% capital cushion against their domestic riskweighted
assets (RWAs). At the same time, BaFin indicated its intention to follow this recommendation, which would become binding after a 12-month transition period on 1 July 2020. Via Moody’s.

The announcement is credit positive for German banks because it will encourage those with tighter capital cushions to set aside additional funds for risks that could surface in the case of changes to the current macroeconomic environment, foremost those related to a potential underestimation of future credit risks in a cyclical downturn, risks to collateral values in residential mortgage lending or risks related to the future interest rates trajectory.

Germany is the 13th country in the European Economic Area to introduce a countercyclical capital buffer, and in most fellow member states the first step introduction has been followed by at least one increase later. Exhibit 1 provides an overview of initial and current countercyclical buffer (CCyB) requirements.

Germany’s 0.25% proposal will apply to German exposures of all European Economic Area banks and it remains very close to the bottom of the range compared with Norway and Sweden, whose CCyBs will reach the maximum of 2.5% later this year. Even so, we believe BaFin’s moderate first step and its ability to increase the requirement will lead German banks to further strengthen their capital buffers and it clearly signals BaFin’s aim to maintain the pace of systemwide RWA growth at a sound level. RWA growth, as a result of increased lending in combination with tighter RWA measurement rules, outpaced capital retention of Germany’s largest institutions during 2018 according to the supervisor, leading to declines in capital ratios.

In setting the level of the CCyB, regulators are exercising their judgment while taking into account a range of factors including any deviation of the credit-to-GDP ratio from its long-term trend, asset price levels, business lending conditions, and any increase in the stock of nonperforming loans. While below the formulaic +2% threshold that would flag a potential need for raising the CCyB, exhibit 2 shows the German credit-to-GDP gap has been closing to a large extent in recent quarters.

The German announcement echoes a recent recommendation by the International Monetary Fund, which had laid out a similar reasoning in the preliminary view of its annual Article IV mission which assesses the economic and financial development in the Germany. Regarding asset and profitability risks observed by the financial stability committee, we share the view that the German banking system’s current profitability is vulnerable once loan-loss provisioning needs normalise upwards, since the system’s preprovision income levels have further lost ground against international peers

While the sector’s continued prudence in new residential mortgage origination benefits banks, the financing of the banking sector’s long-term fixed-rate assets through current-account deposits results in asset-liability mismatch risks that we expect will at least in part become visible once interest rates rise and if they do so at a faster pace than the banks expected.

A Change in Interest Rates Could Hit Parts of the [German] Banking System Hard

Dr Andreas Dombret Member of the Executive Board of the Deutsche Bundesbank spoke on What’s the state of play in Germany’s banking sector? He makes the point that current profitability of banks is low and links it to low interest rates.

Included in the speech was a fascinating passage on rate mismatch, which is a rising environment could have a strong negative impact. Worth reflecting more widely on this phenomenon.

German banks have expanded their maturity transformation in recent years. In order to stabilise profits in times of very low interest rates, they have increasingly extended the lives and the interest rate lock-in periods of their loans. For instance, the percentage share of longer-term loans and advances – that is to say claims with a maturity of more than five years – at German banks has risen from 60% in 2007 to just under 70%. The ratio among institutions in the savings bank and cooperative bank sector is especially high. At 83%, it is significantly higher than the 47% ratio for commercial banks.
Thus, we are in a situation in which banks and savings banks are holding many long-term, low-yielding investments in their books. Moreover, valuations for many investments are extremely high. By contrast, risk provisioning in the German banking system is very low, at 0.6% of total assets. This makes banks vulnerable to unexpected macroeconomic developments, such as an abrupt hike in interest rates or an unforeseen deterioration in economic activity.

At the same time, they have shortened the maturities of their liabilities. The ratio of overnight deposits to total liabilities towards non-banks has risen within ten years from 36% to around 60%. An important aspect in this context is that customers are parking their funds in deposits because interest rates on investments are so low. It is difficult to predict how these funds will be shifted as soon as more attractive investments become available. Historical experience gives us a rough idea, but in view of the extreme situation of the current low-interest-rate environment it is of only limited use as a guide for the future.

The bottom line here is that we see an increased vulnerability of banks to changing interest rates. This is why we have been keeping a very close eye on the topic of interest rate risk.

Our low-interest-rate survey 2017 focused on this very issue, simulating the implications of possible shocks for small and medium-sized banks and savings banks. One scenario entailing an abrupt rise in the yield curve by 200 basis points highlights banks’ short-term vulnerability. In such a scenario, profits would initially plummet by around 55% before staging a recovery in the medium term. This means that the speed at which interest rates are raised is crucial.

The stress test carried out as part of our low-interest-rate survey combined several risks at once. Besides an abrupt rise in the yield curve of 200 basis points, it simulated a simultaneous increase in credit and market risk. On aggregate, in such a case the tier 1 capital ratio would drop from around 16% to around 13%, which is to say by some three percentage points. Yet a more detailed look reveals the positive impact of substantially improved capital levels. Small and medium-sized institutions prove largely resilient to a simultaneous rise in the three types of risk.

Thus the stress test scenario presents a mixed picture overall. On the whole, German banks and savings banks are robust and in good shape. But this should not blind us to the major challenges and the associated need for adjustments that banks face. Elevated interest rate risk and the low level of risk provisioning increase vulnerability to shocks. I would therefore call on banks to focus their risk management operations primarily on the issues of maturity transformation and interest rate risk.

Risk In A Low Interest Rate Environment

The German central bank has published the results of a survey of smaller financial institution across Germany, examining the impact of current low interest rates.  Of note is their commentary on home loan lending. Bundesbank calculations show they are experiencing price hikes in major towns and cities of 15% to 30% above the level that is justified by the fundamentals. They call out the extended risks in the sector, thanks to large loans being made on the back of more affordable repayments. They warn of systemic risks, a hit to CET1 ratios, and propose actions to manage this scenario. All highly relevant to the Australian context, where our regulators remain coy about the risks in the system.

Over the past few months, we asked 1,555 institutions about their profitability and resilience – in numerical terms, that’s 88% of all German institutions. With aggregate total assets of around €3,000 billion, they represent roughly 41% of the entire German banking sector.

Thanks to the results of the survey, we can provide an exclusive insight into the current and future risk situation facing German banks and savings banks. The survey was based both on assumptions made by the institutions and on stress scenarios defined by the supervisors.

The check-up covers three areas. First, it analyses profitability on the basis of business figures – here, we look not only at the institutions’ planning and forecasts up until 2021, but also at how the annual results would change under the assumption of different interest rate levels in the future. We supplemented these quantitative analyses with qualitative questions, whereby the banks and savings banks gave a uniform assessment of the future of their institution and the banking sector.

The second area is stress testing. In this context, we analysed what would happen to the capital base of the institutions if they had to cope with particular external stress events. For the first time, in addition to the classic stress factors of interest rate, market and credit risk, we also stress tested residential real estate.

Residential real estate also formed part of the third area of analysis, in which we examined other key risks. Besides risks in the residential real estate sector, we performed a detailed analysis of lending standards and the position of building and loan associations.

Our examination centres on the question of how the low-interest-rate environment is affecting the resilience of banks and savings banks. In order to grasp the effects of possible future interest rate levels on credit institutions, we calculated how the profitability of the institutions would change if the interest rate level were to move in one direction or the other. What were the underlying scenarios we used?

For the first area, the analysis of profitability, we first asked the institutions to provide their three-years plans using a uniform template and requested forecasts for a further two years. In addition to this, we examined supervisory interest rate scenarios: a sustained low-interest-rate environment, a positive interest rate shock of 200 basis points, a negative interest rate shock of 100 basis points, and a turn in the yield curve of +200 basis points at the short end and -60 basis points at the long end, each at the beginning of this year. The institutions’ balance sheets could be altered for some scenarios, and not for others.

For the stress test, the impact of a positive interest rate shock of 200 basis points was compared with that of a continued low-interest-rate environment. The scenario also assumes a 200 basis point increase in the probability of default and a 20% increase in the loss given default. Moreover, for interest-bearing securities, risk premiums were assumed to rise by between 30 and 1,500 basis points, depending on credit quality. A 20% loss in value was assumed for other securities, such as equities.

Ladies and gentlemen, when doctors start explaining all their findings down to the very last detail, some patients might think, “Don’t beat around the bush, just tell me what I have”. So here are the key diagnoses, to start with.

  • Small and medium-sized German credit institutions expect their profits to continue shrinking between 2016 and 2021, according to their planning. In concrete terms, they expect their pre-tax profit to dwindle by 9% and their total return on capital to fall by 16%.
  • In the same period, the aggregate common equity tier 1 (CET1) ratio is expected to rise from 15.9% to 16.5%.
  • Further cuts in interest rates would reduce overall pre-tax profitability by up to 60%. All told, however, these effects are less drastic than in the 2015 survey.
  • Under the conditions prevailing in our stress test, around 4.5% of the institutions would fail to meet the prudential requirements set out in pillars I and II plus the capital conservation buffer, taking into account hidden reserves.
  • One thing that increases in the low-interest-rate environment is competition: over 70% of institutions expect competition from other banks and savings banks to pick up – and as many as 85% see fintechs as a source of mounting rivalry.
  • On this score, nearly every second institution can see a prospect of mergers and takeovers in the medium term.
  • One set of findings I am sure you will all be interested in is from the residential real estate market. This much I can tell you already: we are seeing the unsecured portion of housing loans increasing at one in three institutions, but there is no sign of a worrying easing of credit standards.
  • And the good news is that a simulated extreme drop in housing prices in Germany would shave just one percentage point, or thereabouts, off institutions’ CET1 ratio.

2  Ongoing decline in profitability forcing banks to fight back

Let us now take a closer look at the details, starting with earnings. In this part of the survey, we asked credit institutions for their budgeted figures for the period until 2021. You can see straight away that the trend does not look good. Smaller and medium-sized German credit institutions are expecting results – measured in terms of their pre-tax total return on capital – to shrink by an average of 16% by 2021. The 2015 survey had even projected a decline by one-fourth.

What is behind this drop in profitability? This chart shows the aggregate decline in results over the 2016-21 period, broken down by type of result. The heaviest losses are projected to come from the 0.27% pre-tax drop in net interest income, corresponding to a contraction of more than 3 billion euro in absolute terms, and from the increase in loss provisions – the latter including positions such as expected credit losses. Here, the decline in annual earnings to the tune of 0.43 percentage points is equivalent to future loss provisions amounting to more than €5 billion in absolute terms.

The overall decline, however, will first be offset by an improvement in net commission income in the amount of 0.24 percentage points, corresponding to a figure of almost €3 billion in absolute terms. The second dampening factor at play here is the reduction by 0.5 percentage points (equivalent to more than 6 billion euro) in additional reserves – these factors will keep the decline in profitability in check at a negative 1 billion euro.

On aggregate, then, the banking sector is expecting to see a steady decline in profitability in the years ahead – however, there are growing signs that institutions are beginning to fight back. But these steps still don’t go far enough – further, more decisive action will be needed to turn things around.

Let’s now move on and look at what happens when interest rates change. To illuminate this point, we specified a number of uniform interest rate scenarios and asked banks and savings banks to calculate how their business figures until 2021 would change if interest rates remained static, increased or declined. The blue bar highlights the 16% decline in total return on capital I have just described.

If the interest rate level stayed low or even shrank further, their results would slump, as you can see from the dark blue line (-41%) and especially the solid red line (-60%). Assuming a dynamic balance sheet, portfolio adjustments can cushion this impact accordingly, as the red dashed red line (again -41%) illustrates. A rise in interest rates would be a different story. To begin with, the short-term burden of interest rate risk would materialise, hitting bank profitability. But on a more cheery note, over the medium to long term, results would even move back above the current figure from 2016 (+7%).

But banks and savings banks are not projecting such an upbeat scenario as this interest rate scenario is not regarded as being likely to happen.

Institutions’ earnings, then, are under pressure. This might lead them to take on greater risks, which are normally rewarded by higher returns. If that does not work out, institutions will end up taking excessive risk on board. For this reason, supervisors need to focus on the resilience of the institutions.

And as you can see from the chart, one in three institutions are expecting their CET1 ratio to contract. The left-hand side of the black bar shows institutions whose ratios are declining. Another thing the survey responses tell us is that as many as two out of three institutions are projecting a drop in their total capital ratio. However, that’s not a point we should overdramatise because the average outcome across all institutions is that while the total capital ratio looks set to shrink from 18.3% to 17.8%, the CET1 ratio is projected to climb from 15.9% to 16.5%.

The main question, though, is what the one in three institutions which are expecting the CET1 ratio to drop are planning to do. The institutions in this group, which account for a handsome 32% of participants, are planning to increase their total assets and exposures, but not to step up their equity capital to the same extent – on aggregate, this will slightly reduce the capital ratio.

These are all early warning signals of a heightened propensity among credit institutions to take risks, and we are monitoring developments very closely indeed.

3 Continued intense competition a catalyst for merger plans

But why are institutions taking on greater risks? One likely reason is that there aren’t any superior straightforward alternatives. Efficiency gains can only be achieved through costly optimisation measures. And low-risk investments are hotly contested in Germany’s banking sector, plus their returns have been depressed by the low-interest-rate environment.

In this setting, speculation has long been rife over further consolidation, and not just in the German banking sector. Our survey now delivers clear indications not only that competition remains as fierce as ever, but also that institutions are even expecting it to intensify – and not only because of fintechs, but also due to other credit institutions, especially regional ones.

It is hardly surprising that consolidation continues to make headway under these conditions. But what we did not expect were the figures on future mergers: Around every tenth institution is already in the process of implementing a merger or has specific merger plans. What’s more, almost half of all banks can envisage a merger in the next five years. However, considerably more banks see themselves as the acquiring institution rather than as the institution to be acquired. That’s another reason why I expect we will ultimately see fewer mergers than the responses might initially suggest.

The number of German institutions is likely to continue falling in the years ahead, too. In our role as bank supervisors, we only want to warn banks that not all mergers are sustainable. In this respect, too, banks would do well to carry out a comprehensive check-up to identify avoidable problems in good time.

4 Elevated risks through housing loans

And now we come to a new element of our check-up: the housing market. Fear of a housing market bubble and rising real estate risks in banks’ balance sheets has been the subject of heated debate for some months now, not least because of constantly rising property prices. Bundesbank calculations show that we are experiencing price hikes in major towns and cities of 15% to 30% above the level that is justified by the fundamentals. Credit growth in Germany has likewise gathered momentum of late, notably at the smaller institutions. But this needs to be put into perspective: growth is still comparatively moderate compared with the euro area in the early 2000s.

And our survey currently sounds something of an “all-clear” for Germany. We see no far-reaching loosening of credit standards or conditions. If these were significantly softened, this would point to the emergence of a housing bubble capable of threatening financial stability. But we have found no sign of that.

What we certainly do see, though, is a growing tendency among institutions to incur greater risks. These movements have been minor so far – but we need to be especially alert to them.

What exactly do we see? First, in the current low-interest-rate environment, there is an increase in mortgage loans in banks’ balance sheets – both the overall volume and the average loan size have risen distinctly. Customers seem to be taking advantage of the low interest rates to offset part of the price increases – and because rates are so low, they can also finance their purchases without any additional costs. Moreover, the rate fixation period is simultaneously being extended. On top of that, institutions also seem to be willing to grant loans against less collateral. The sum result of these factors is increased risk-taking on the part of banks.

Parallel to this, the interest rate margins, that is the interest they demand minus their funding costs, have contracted significantly over the last two years. One reason for this appears to be the fierce competition for mortgage business, which remains a safe and therefore attractive business segment for banks.

Let us move on now to the housing stress test. How well would banks and savings banks cope with a bust in the housing sector? To put it in no uncertain terms: we do not see any real estate bubble that should give us cause for concern. Nevertheless, we do need to be on our guard. That is why we took the precaution of performing the housing stress test. To this end, we simulated a decline in housing prices and examined how such an occurrence would impact on banks in terms of losses and their capital ratio.

Therefore, we first needed to simulate a macroeconomic setting appropriate for the hypothetical house price developments, using a suitable model. This then enabled us to determine both the impact on default probabilities and on loss ratios for housing loans. Based on the changes in these parameters, we were able to derive the hypothetical increase in impairment charges as well as the losses in interest income, both of which diminish the capital base. Furthermore, using the standard approach, the banks’ risk-weighted assets expand on account of the reduction in the value of eligible collateral. These partial effects cause the CET1 of the banks in question to shrink.

From the upper chart you can see that we simulated very pronounced price corrections which, however, experience in other countries has shown to be plausible in a crisis situation. The dashed lines show the development of housing market crises in other countries. The dark blue line represents our extreme scenario, which simulates how a drop in prices similar to that experienced during the Spanish housing crisis from 2011 onwards would have affected the banks in our survey. In this simulation, prices plunge by 30%. The light blue line represents the less extreme, yet still severe, scenario – which we call “adverse”. In this case, prices fall by 20%, which is not exactly a small margin either.

The credit institutions would sustain heavy losses under the extreme scenario: the result would be a drop in their CET1 ratio of 0.9 percentage points. In this case, the small and medium-sized German banks and savings banks would have to raise additional capital of around €12 billion in order to lift their CET1 ratio back to its original level. And even under the somewhat less dramatic, adverse scenario, the CET1 ratio would still fall by 0.5 percentage points. Here, capital would have to be topped up to the tune of €5.6 billion.

So you see, the risks stemming from the residential mortgage market are relevant for banks. What is more, taking contagion into account would intensify the impact considerably. We see signs of growing competition to secure mortgage loan business in the low-interest rate environment. Nevertheless, the stress test shows that banks need to look closely at how well they would be able to cope with the associated risks in the event of a crisis.

The message to banks and savings banks, then, is that they ought to make provisions if they want to stay healthy in the long term – that is and remains, without a doubt, the best medicine.

German Bank Profitability “Too Feeble”

Dr Andreas Dombret, Member of the Executive Board of the Deutsche Bundesbank discussed the state of play in Germany’s banking sector as they unveiled the Deutsche Bundesbank’s Financial Stability Review.

He said that first, the supervisory environment for banks has become even more European since the last Financial Stability Review. Second, German banks have boosted their stability still further – equity capital ratios are up again, leverage is down again. Third, persistently weak earnings are taking their toll on German banks. The low-interest-rate environment will particularly make itself felt at small and medium-sized institutions over a medium to long-term horizon. Institutions will need to tackle these challenges head on if they are to safeguard their stability and profitability.

dbund-pic The latest financial stability review identified some key risks:

  1. In the current macroeconomic setting, there is a danger of risks being underestimated. Low interest rates, low risk premiums and high valuation levels are affecting all sectors of the economy – firms, households and general government. The incentive is there to amass more debt. This increases vulnerability to future changes in prices or interest rates.
  2. The current macroeconomic setting can favour a credit-financed real-estate boom. Prices are rising in the German real-estate sector, and lending is on the rise. However, there are no acute signs of an easing of credit standards. Preventive measures can mitigate future risks, though.
  3. Risks are accumulating in financial institutions’ balance sheets. The amount of low-interest long-term loans is rising, while the share of low-yielding assets has increased. This is leading to increased liquidity and interest rate risks. Persistently low interest rates would hit precisely those financial institutions whose business models depend heavily on interest rates.

German banking sector still stable …

I’ll start with the good news: German institutions have substantially increased their capital levels – and thus their resilience as well – since 2010.

The tier 1 capital ratio of the German banking system as a whole rose by just a slim 0.16 percentage point between June 2015 and June 2016, leaving it broadly unchanged at its year-end 2015 level of 15.7%. But this underlines the long-term trend improvement in capital adequacy, which is the key determinant of any banking sector’s resilience. In early 2008 – the year of the global financial crisis – the tier 1 capital ratio averaged no more than roughly 9.1%.

A major effect that impacted positively on the tier 1 capital ratio in Germany came from the decline in risk-weighted assets since 2008. That is to say, banks have stepped up their investment in assets with lower capital requirements.

The results of this year’s EBA stress test confirm that the German institutions which took part in that exercise are more robust to macroeconomic shocks today than they were just a few years ago. To sum up – there can be no doubts as to the solvency and liquidity of the German banking sector.

… but profitability is too feeble by international standards

Yet having a stable capital base alone isn’t enough to ensure sustained resilience. Banks need to generate sufficient profits as well.

Let’s start by looking at Germany’s major banking multinationals. Compared with their total assets, these institutions have slightly improved their operating income, which is up from 1.31% in 2009 to 1.51% in 2015.

However, the major banks saw their return on total assets dip again for the first time last year. While it is true that the provisions made by one major institution had a negative impact on the return on total assets in Germany, if we exclude that particular institution, the remaining group of banks saw an increase in return on total assets, at 0.35%. All in all, that figure is still low by international standards, however. German banks as a whole are likewise lagging behind the international field – their aggregate return on equity, for example, languishes at just under 6%.

What’s causing these problems? The diagnosis is relatively simple. Profitability is exceedingly weak among German credit institutions, and the persistent low-interest-rate environment is only making matters worse. Credit institutions whose business models are heavily geared to net interest income, in particular, might encounter serious medium to long-term problems if the phase of rock-bottom interest rates persists. The longer rates remain low, the more the pressure on net interest income in Germany will intensify.

But for now, we can cautiously sound the all-clear, particularly for small and medium-sized German institutions, because although the low rates are leaving a dent in their profits, most banks and savings banks are still bearing up. Net income from traditional interest business for German banks as a whole was down by €0.9 billion at €78.1 billion, but that decline was offset by an increase in net fee and commission income, which was up by €1.2 billion at €30.5 billion. Credit cooperatives and savings banks – institutions that are heavily reliant on interest business, relatively speaking – also managed more or less to maintain the previous year’s net figure.

But the low-interest-rate environment is also posing a threat to the financial system. As higher-yielding legacy loans mature, they are being replaced by ones generating lower returns, some of which have longer tenors.

Moreover, the narrow spreads between short-term and long-term interest rates are squeezing the margins that banks can generate from maturity transformation. Together, these effects are crimping net interest income. Furthermore, banks are recording stronger flows of short-term deposits, which increases their exposure to interest rate risk. Ever since 2011, we have been seeing an almost steady rise in the Basel interest rate coefficient, which is a measure of interest rate risk. What this means for German credit institutions is that they should actively manage and hedge their higher interest rate risk – having an adequate capital base helps as well.

A major risk associated with a low-interest-rate environment materialises when that spell comes to an end. In this scenario, pre-tax net income would probably suffer a short-term slump, especially if interest rates were to climb abruptly following a long period of low rates. This would not only generate present-value losses in the short run, but might also cause interest expenses to outpace interest income in the medium term. Moreover, German institutions are now carrying more risky assets in their books than they were just five years ago. Not just that: they are also extending the average residual maturity in their proprietary business, which is exposing them to more credit default and market risk.

But from a long-term vantage point, an interest rate hike would help the banking sector recover and regain stability. And that’s precisely why it’s so important for the banking system to be adequately capitalised, since that would help it cushion shocks over a short to medium-term horizon.

Supervisors are closely monitoring German institutions in this setting. Following on from our exercises in 2013 and 2015, we at the Bundesbank are planning to conduct another survey on the low-interest-rate environment next year among the institutions we supervise directly – this time with added interest rate, credit and market risk stress tests. We hope this survey will give us an insight, early on, into any critical and risky developments in the banking sector and assist supervisors in their dialogue with institutions.

Past survey results tell us that credit institutions are responding to the new setting and pushing up their earnings from commission business – which includes, amongst others, account management and payment fees – and also increasingly passing on negative interest rates to major customers. We have also been seeing a steady flow of consolidation and mergers in the savings bank and cooperative sectors.

For all the progress we have made, there’s still one topic that continues to worry me. Roughly eight years on from the onset of the financial crisis, a number of European banks are still saddled by disturbing amounts of non-performing loans (NPLs). Therefore, scaling back these legacy exposures is one of the foremost aims of banking supervisors in the euro area, and rightly so.

There are two main reasons why we’re interested in NPLs. One, they make banking systems more vulnerable because they drive up both capital requirements and funding costs. Two, they make it harder for the banks in question to supply credit; this, in turn, puts the brakes on growth in the euro area. As a consequence, NPLs don’t just weigh on credit institutions’ earnings; they also intensify solvency risk and obstruct economic activity in Europe.

In this context, I would like to highlight the public consultation on the draft guidance to banks on NPLs which was initiated by the ECB and ran until yesterday. Equipped with this guidance, banking supervisors will be in a position to uniformly assess banks’ internal handling of NPLs as part of their regular supervisory dialogue.

But as far as financial stability in Germany is concerned, I see no immediate cause for alarm. NPLs are far less of a problem in the German banking system than they are in some of the other euro-area countries. At roughly 2%, the NPL rate in Germany last year was well down on the euro-area average. That figure also includes non-performing shipping exposures, and they certainly do worry me because there are still no signs that the economic situation in the shipping industry is about to recover. It goes without saying, then, that we shall continue to keep a close eye on banks with substantial exposures to shipping loans.

As for the institutions saddled by NPLs, we expect them to take measures that are conducive to promptly reducing legacy exposures and bolstering their resilience. These measures include not just thoroughly cleansing their balance sheets of both existing and anticipated losses but above all conducting appropriate credit risk management and holding an adequate level of capital.