ABN AMRO Bank N.V. (ABN) Earnings Call Transcript & Summary

Good day, and welcome to today's ABN AMRO Third Quarter 2023 Analyst and Investor Call. This meeting is being recorded. At this time, I'd like to hand the call over to Robert Swaak, CEO. Please go ahead, sir.

Thank you very much, and good morning, and welcome to ABN AMRO's Q3 results. I'm joined by Ferdinand Vaandrager and Tanja Cuppen, and I'll update you on the main topics for this quarter before we start the Q&A session. So let me first take you through the highlights on Slide 2. We showed a strong result with a net profit of EUR 759 million. This result is supported by high other income and impairment releases compared to previous quarter, NII was lower, and we saw this in all business segments, though the drivers were different for each segment. We see clients continue to transfer cash into interest-bearing accounts while our overall deposit volume increased. Both our mortgage portfolio as well as our corporate loan book increased despite a challenging environment. We have lowered our full year 2023 cost outlook to between EUR 5.1 billion and EUR 5.2 billion, as a result of a delay we experienced in certain investments. Our result was once again supported by impairment releases. This quarter, the net impact was a release of EUR 21 million. We maintain a solid capital position with a fully loaded Basel III CET1 ratio of 15% and a Basel IV ratio of around 16%. Turning to Slide 3. Let me say a few words on the progress we're making on the execution of our strategy. Following a quite a successful campaign targeting minors and students, we saw an improvement in our market share from new accounts. To support our elderly clients, we now have over 100 specialized financial care coaches helping these clients with their daily banking needs whilst our wealth business is helping our clients to make their investments more sustainable. Currently, around 47% of our client assets has an ESG label or is an impact investment. Our entrepreneur and enterprise proposition is up and running in all countries with our inaugural transaction actually taking place in those. Our Corporate Bank was the first to issue a digital green bond on a public blockchain to one of our clients. This type of bond fills a gap between traditional bonds and [crowd] funding. So thanks to blockchain, it is highly efficient and very client friendly. We are making steady progress on the execution of our climate strategy, and we will communicate additional carbon reduction targets in our next annual report. Turning to the Dutch economy on Slide 4. Overall, the Dutch economy continues to perform relatively well. Unemployment remained low. House prices are showing signs of improvement and consumer spending is holding up. Not all indicators are positive. The Dutch purchasing managers index remains negative as firms are reducing their output. We do expect the PMI to remain weak in the short term, which should also lead to lower inflation. House prices are starting to rise again slowly, and our Economic Bureau has revised their house price forecast upward from minus 3% to plus 2.5% in 2024. Stable mortgage interest rates and higher wages has helped sentiment among house buyers. Supply remains limited, however, also given limited new construction, so we expect transaction levels to remain subdued for a while. Now moving to our third quarter performance, starting with NII on Slide 5. NII, excluding incidentals increased almost 17% year-on-year, largely driven by improved deposit margins. Compared to Q2, NII was around EUR 70 million lower when excluding incidentals. And there's not 1 major factor driving this decline, but rather several smaller negative factors. Around EUR 20 million decline is related to a reclass to other income rate within Corporate Banking. So that does not impact our bottom line. During Q3, we saw EUR 7 billion of current accounts migrating to higher-yielding deposit products, mainly time deposits, and this deposit migration mainly impacted NII within wealth, which declined by around EUR 20 million. The remainder of the decline is largely explained by some asset margin pressure and lower results in trading activities. While our treasury result is generally somewhat volatile, it was actually flat during Q3. The benefit from higher rates is coming through slower than we initially anticipated. Now looking ahead to next year, I expect the treasury result to increase during 2024. Our replicating portfolio continues to benefit NII given current market circumstances, and we expect the current pace of deposit migration to come down during next year as we expect most of the migration to occur this year. Although we cannot predict how our margins will develop, our current view is that NII may recover a good part of this quarter's decline during 2024. So let's turn to Slide 6 for balance sheet developments. We again managed to show growth in our loan book despite a challenging environment. Business volume in Northwest Europe increased further as we continue to add new clients in our focus segments, including new energies, digital and mobility. Our market share in the Dutch mortgage market rose to 15%, leading to further growth in the mortgage portfolio despite, again, the slow housing market. Our noncore wind down is largely completed with now only EUR 400 million of loans remaining. Consumer lending continued to decline the trend, which has been ongoing for a while. Total deposits increased this quarter with sizable flow between various deposit types, which I highlighted earlier. Since the beginning of the year, we've seen almost EUR 24 billion of current accounts moved into interest-bearing accounts. We have seen this flow mainly finding its way into time deposits while saving accounts have remained stable over this period. The outflows out of the banks has been very limited, while our overall deposits have increased again during the year. Turning to fee income. Fee income remained stable compared to previous quarter. Retail banking fees did increase mostly due to higher payment volumes during the summer holiday, which also led to higher credit card fees. Fees in Wealth Management were more or less stable and lower financial markets led to a decline of assets under management. Other income was very strong at EUR 237 million. We booked gains on a number of disposal of assets, including buildings and our stake in the digital payment business. Hedge related income within Treasury also was a positive contributor to other income this quarter. And I mentioned the EUR 20 million reclass from NII to other income within corporate banking. Now this effect is quite stable and will persist in the quarters ahead. Turning to Slide 8 on costs. Our underlying costs, so excluding regulatory levies and incidentals increased during the year, this is partly related to 2.5% increase in wages, which was agreed in the collective labor agreement, which runs until July next year. External staff expenses also rose with these cost increases while these cost increases were partly offset by further cost savings. We achieved a total of around EUR 450 million of cost savings so far under the strategic plan we formulated back in November 2020. So we are keeping costs under control. And for this year, we expect costs to land between EUR 5.1 billion and EUR 5.2 billion. The further downward revision reflects delays in the investments we are making in our data capabilities, further digitalization of processes and sustainable finance regulation. We are now starting to make good progress, hiring additional staff and hence, these costs are rising and will lead to higher investment costs in the coming year. Turning to impairments on Slide 9. This quarter, we had again a release in impairments, mainly in Stage 2 and Stage 3 for corporate loans due to recoveries and repayments. These were partly offset by an increase in the management overlay for interest-only mortgages as we took a more prudent risk approach. Over the past years, we've seen a significant decrease in our interest-only portfolio, and we expect this to continue. The overlays related to the war in Ukraine and the nitrogen crisis, they were kept in place. In line with last quarter, we saw some provisions related to inflow in stage 3. However, this was more than offset by releases of individual corporate files. The impact of the economic slowdown on our loan portfolio so far has been limited and our nonperforming corporate loan exposures decreased further. So we do not expect to see the effect in Q4 already, so the cost of risk for the next quarter will remain below through the cycle cost of risk of 20 basis points. For Slide 10 on capital. Our Basel III capital ratio stands at 50%, and we remain well capitalized. The increase in capital from the 50% addition of our net profit was partly offset by higher RWAs. RWAs increased reflecting model add-ons, partially offset by business developments. These add-ons were taken in relation to our ongoing review for our credit models and simplification of the model landscape. Our current MDA trigger is 10.6%, and this will increase 11.2% in the course of next year. This mainly reflects an increase in the countercyclical buffer to 2 and the proposed increase of 25 basis points for our Pillar 2 Requirement. Our capital position remains strong and is well above the future MDA trigger level. So to round up with our financial targets. We're heading towards a good year with our year-to-date ROE well above our 10%, our ambition. Our NII has fully recovered from a negative interest rate environment, and we have more or less completed the derisking of our balance sheet with the wind down of our noncore portfolio. Our solid risk profile in Brazilian and Dutch economy have led to impairment releases over the 9 months of the year, which has further boosted our results. As I mentioned last quarter, our cost target for 2024 is no longer achievable as we are faced with higher inflation and additional investments. We remain committed to cost discipline and we'll update our financial targets and our capital framework over the next quarter. So with that, I would like to ask our operator to open the call for questions.

[Operator Instructions] And our first question comes from Benjamin Goy from Deutsche Bank.

Two questions, please, 1 on net interest income and the other on cost. Can you maybe talk a little bit more about the impact from the mix shift you're seeing, so from -- so what's the drag actually when you see outflows? Is it 2.5% roughly? Or what's kind of the impact from current accounts to time deposits? And I guess, to savings at 1.5%, but maybe can you give a bit more color. And then secondly, on costs, so you essentially keep on upgrading your near-term guidance, but it's mainly due to delay in investments. I mean, I think we're talking 1 in 100 million -- so just maybe you can give a bit more color what massive investments, significant hiring you plan to do? Or is there also some underlying improvements in these upgrades included.

Thanks, Benjamin. I'll ask Ferdinand to take the NII, I'll take costs.

Yes, Benjamin, as said already, if you look at the underlying levers you mentioned 2 of them. One is the reclass effect. Well, what this means the reclass effect that's why we're transferring existing swap contracts from markets on trading into hedge accounting in the banking book. So this is really related to a transfer of existing receivers, swaps with lower rates to the banking book. And as said, the effect might persist for a while, but we can also take steps to avoid further reclass effects. So we do not expect this to increase over the coming quarter. Then the other element in the quarter-on-quarter, but specifically towards deposit migration. We've basically seen the same trend as the previous quarter, specifically an outflow from current accounts into time deposits, mainly in our wealth department. So here looking forward, we've seen year-to-date roughly EUR 24 billion outflow from current accounts, which is just over 20%. And if you would combine that with the current interest rate outlook and also historically through the cycle, what our base of current account is, we expect that to -- that migration to slow down. So the biggest part of it that will have taken effect this year.

And maybe on cost, Benjamin, we did lower it to EUR 5.1 billion, EUR 5.2 billion range. It is in a sense, consistent with the explanations we were giving last quarter. Ultimately, we were faced with the delay of hiring additional staff. These are predominantly staff that we hire in the areas of data capabilities, continued digitization of the bank, but also SFR regulations, the expertise that we need within the bank. So we see a delay of the hiring. That is predominantly due to tight labor markets. We do see now an increased progress in hiring. So for the full year '23, we expect the EUR 5.1 billion and EUR 5.2 billion, we will expect the hiring to continue into '24. And to your second part of the question, yes, we have realized cost savings since 2020. But as we've also talked about, the inflationary pressure that we were faced with, including some of the CLA effects have partly offset the cost savings that we had realized when we started this back in 2020. So I think sum total, we will remain to that very same cost discipline, and we will then update and that's why we're only giving the guidance now for the full year '23 as we expect to give a full update in Q4.

Understood. Maybe a short follow-up. I think it makes sense to comment on Wealth Management. Just wondering how concerned are you about moving excess liquidity from retail clients? Or is not -- or isn't there much on average?

Can you repeat that question, Benjamin. We mentioned the migration effect, specifically the shift on the wealth side, what your questions are related to what we see on the retail side.

Yes, indeed, it's about a risk in retail or whether it is just the excess liquidity is -- or there isn't much so there's not much to shift into time deposits?

Well, as I said as wealth, specifically looking for time deposits. If you look at the shift into savings accounts, what we've seen earlier this year, that has actually been kept stable as you look at the overall demand deposits, which were roughly flat at around EUR 100 billion. As with outflows there is always a question of what will competition do? And what are the different interest rate scenarios, but I go back to my earlier comments. If you look overall at the migration effect of, we do expect this to slow down going forward.

Our next question comes from Giulia Miotto from Morgan Stanley.

Yes. Just going back on the NII discussion, so where do you expect the mix ultimately to land? So should we look back at history or any comments on your expectation on the mix and ideally, the deposit beta that you see in your base case? That's my first question. Then secondly, going back to capital, I think, you mentioned that there are some further methodology changes leading to RWA inflation. Can you quantify those? And also I'm curious on the Basel IV capital ratio, why doesn't it move? Because it is always around 16%. But in theory, you should be building capital and you shouldn't have much of the inflation other than the organic business growth.

Thanks, Giulia. Freddie if you take the NII and Tanja, the RWA.

Yes, Giulia, on NII also there, we try to say outflow for NII that we see support into 2024 of the overall interest rate backdrop. So that is on one hand, on our replicating portfolio and on the other hand, also on the overall treasury results, which can be more volatile on quarter by quarter basis, but outflow over the medium term, this should be support. Coming back to your question in terms of overall predictions on beta, I think, what we see so far in the Netherlands, the pass-through has been higher than some of our surrounding countries. Overall, we have not seen any outflow in our total deposit base year-to-date. Actually, in inflow, liquidity position is extremely strong with loan to deposit of around 95%. So from that perspective, there are no reasons to expect a significantly higher pass-through. But at the end of the day, it will be all driven by market circumstances and competition. So it's very difficult to give an exact prediction to you.

Yes. On the RWA development. So maybe first on the Basel III and you see our overall RWAs have been up at EUR 2.1 billion for operational risk and market is actually stable and operational risk, it's good to know as well as that we have already moved there to standardized approach, also anticipating Basel IV. And the main increase is therefore in credit risk. So that's also EUR 2.1 billion, largely from methodology changes and model redevelopments. And there are some smaller releases in RWA due to the fact that our portfolio improved in credit quality and that led to some releases. So the actual impact of methodology changes and model reviews is somewhat higher than the EUR 2.1 billion. And this model update, of course, also translates into Basel IV, although a Basel IV impact is smaller, given that [floors] are being used in Basel IV and the fact that you still see the 16% as Basel IV number for CET1 is related to the fact that well Basel IV regulations are still not final, and we are working to all the technical details. And once we have all the technical details clarified, we are expecting to give a more accurate number with -- well, not around that number like we have today. So the number is indeed fluctuating in our own calculations, but we round it to 16%. And it has moved over time from a rounding down to rounding up to 16%. And so there are fluctuations there, but as the regulation is also still in development, it's hard to publish the numbers with more accuracy.

Our next question comes from Raul Sinha from JPMorgan.

Just the first one on NII, just a follow up on the discussion so far. Can I just check how much of the NII actually relates to trading activity? Because on Slide 5, you're obviously indicating that this quarter, there were lower results in trading activities. So I guess the question is just to understand the volatility within the NII line, how much of this is trading? How much of it is treasury. And then just piecing together your comments so far, it sounds like you expect the net impact of the negative from deposit migration and the positive from the replicating portfolio to become a net positive into 2024. I was wondering if you might be able to shed a little bit more color on the timing of that. Is that the first half, '24, second half of '24. It just would obviously have quite a big impact in terms of where we end up modeling NII for '24? And then just a follow-up, supplementary, if you don't mind. Regulatory costs, it looks like they will be down in 2024. Could you give us some guidance for '23 and '24, please?

Freddie?

Yes, Raul, thank you. Let me start with your question on trading activities. We try to provide some drivers of NII this quarter. So there are also many smaller elements, lower results and trading activities are mainly related to, for example, increase in funding costs at trading desk, higher collateral costs, et cetera. Therefore, in the bigger scheme of things, these are not enormous deltas, but worth mentioning and trying to sort of explain what the gap is and the other smaller element next to the sort of shift in NII to other income and deposit migration is some asset margin pressure of several portfolios. Then going to your next question, what is the outlook on NII. I think the most important one here, and that is -- can be a bit more volatile on the shorter term, that's the outflow of treasury results. If you look over the medium term, the biggest element here is our invested equity position, and this is not a ring-fenced portfolio of swap contracts. It's really the result of all on and off-balance sheet interest risk exposure we have, which is dynamically hedged. But over time, it should be similar in return to a duration portfolio of up to 4 years. But on a shorter term, hedging the interest rate risk is always a dynamic process. So other elements in the treasury results are also mortgage prepayment penalties, rehedging post if you need to lengthen the duration of your mortgages, but also mortgage of just premium and as well as now the tiering effects, which will come into here as of Q4. So can you then really say is the first half higher than the second half. Last quarter, we expected a faster rebound in the treasury results. So we still do see a recovery of the negative bridge we are seeing this quarter, but that's all swap positions are [essentially booked] it's not always that easy to extract all swaps related to interest bearing. So positive steer here into next year. But no specific guidance has come early in the year or later, so a little bit of a long answer, but -- and then going to the regulatory costs. Overall, the expectation is EUR 340 million for this year. And as we said already in the overall cost outlook towards 2024, we do expect this to come down to EUR 200 million. we have seen already in the previous quarter, a lower single resolution fund. So part of that effect has already been seen.

And our question comes from Kiri Vijayarajah from HSBC.

Yes. A couple of questions around NII again. So firstly, I appreciate it's early days, but how worried should we be about this ACM investigation into pricing competition in the Dutch savings market? Is there any time line that we should have in mind? And could we see banks preemptively bumping up savings rates in advance of any conclusions or findings from that investigation? And then secondly, on your slides, more on the asset side, you mentioned limited asset margin pressure. But I wonder if you could tell us a bit more specifically on mortgage pricing. Where are you on the front book versus back book pricing. Because I think in previous calls, you mentioned that, that was moving in the right direction. And I just wondered where we are today and should that mortgage front book, back book dynamic remain kind of a headwind into 2024? Or is it kind of more neutral thinking about next year?

Thanks for the question. I'll take the one on the ACM and Freddie will take the follow-up questions. Now on ACM, we've had questions that were raised by initially also by the Ministry of Finance around how pricing was determined in the Dutch market, and that was building on a sentiment in the Dutch environment. And that sentiment was based on the steep increase in ECB rates and then clearly, the way the rates were developing in the Netherlands -- deposit rates were developing in the Netherlands. I think it's good when these questions do arise that there is an independent investigation into the questions that are being queried. We don't have timing of the investigation. Suffice to say that if we're to participate, we will clearly cooperate fully. And so we'll just await the results of the outcome. I think it's -- we're getting a little ahead of ourselves. We start to talk about outcome. At this point, from our point of view, we've always said there is a transparent market. There's different product combinations possible in the market. And so we'll have to wait and see what the authorities, the ACM actually will come up with.

Yes, Kiri, and then going to the asset side, the mortgage indeed, what we said the previous quarter, if you look at the new production inflow that it is around the level of the outflow mortgage book, and that is still the case despite quite a competitive environment in a lower production market. So that is one. But we do see -- still see outflow of the book of higher-margin mortgages. So that is dampening the effect a little bit. The second one is the current mortgage markup is up to 10 years, but it's also the level of the state guaranteed mortgages where the average barrier was at 355,000 in 2022. It will be -- it was increased already by 50,000 this year and another 30,000 next year. So that means that roughly 1/3 of the new production is within the NHG guarantee. It's good for RWA. Of course, your capital next to that is lower, but these mortgages are also clearly hedged at a little bit lower margin. So this is overall the effect you're seeing on mortgages. The other effect is specifically in consumer loan, it's a relatively small portfolio of roughly EUR 10 billion. There you do see the effect of duty of care of crediting in the Netherlands, which has become more strict and there is also a statutory and maximum interest rate you can charge off on those accounts. So those are the 2 elements, if I talk about asset margin pressure that you see that effect.

Our next question comes from Benoit Petrarque from Kepler Cheuvreux.

Yes. Thank you for the time. So I was trying to, again, understand the net -- the underlying net interest income thinking about 2024. Yes. So we have EUR 1,533 million now as a starting point. We have this EUR 23 million from MR. So let's assume we have kind of clean at EUR 1,510 million. How much recovery from treasury do you expect? Do you still think you kind of recover the EUR 50 million roughly you've been losing in Q2. And the question is when you think that could recover? And then thinking about Q4, we've seen a savings deposit pricing. So rates going up to 1.5%. I think the pass-through rate delta on average in Q4 is relatively high actually versus the previous quarters. So do you think the net between replicating portfolio and your kind of repricing effect on deposits will be kind of negative again in Q4? Or you think it could be neutral or positive? That's the question number one. And then coming back on the term deposits, how much is a realistic level for next year in terms of inflows. Because so far, I think, we've seen about EUR 29 billion for the first 9 months of term deposit inflows. What do you see in the fourth quarter, we're already in November? Do you still see inflows? And I appreciate your comment that, that will slow down, but are we going to get EUR 10 billion, EUR 20 billion, EUR 25 billion next year? I mean, -- those are big figures potentially. So could you help us to model also the kind of the term deposit mix effect?

Yes, Benoit. Let me start -- quite a few questions. I thought I addressed a few of them already. So if you look at the delta of EUR 50 million in treasury results, what is the confidence that we will recoup that in 2024. That said there, we still expect that the effect there will be later than earlier anticipated for all the elements I mentioned earlier. So yes, we think the negative effect we've seen will rebound in 2024. Then on your question on deposit pricing, and outflow of the deposit delta we are seeing there. Do we expect an acceleration? No. And we always look clearly at interest rate increases if they go faster, then you are also replicating a yield, then it will be negative. But as I said earlier, there are no indications or no needs. We don't see any deposit outflow. Loan to deposit is very low. But clearly, I do not have a crystal ball, but it depends very much on market development and competition. But from our perspective, there is no need to be more competitive than what we currently are...

What I mean here is that your pricing was at 1% on deposits end of June. Now you have 1.5%. So what I mean is more like the Q4 effect of the repricing will be quite negative, I will assume or this is not something you see. And that could be more negative this effect than the positive you might get from the replicating portfolio in the fourth quarter. Assuming rates stay at 1.5, yes.

Yes. If you stay at equal, then still, as I said earlier, the replicated portfolio, if you say this will still be a tailwind for the overall outflow of NII. Then to deposit inflow, did you mean inflow or migration, I think we addressed that question as well. It was mainly a time deposits coming from wealth, but...

What I was referring to is the EUR 7.8 billion inflow in term deposits in the third quarter, which was EUR 4.6 billion in Q2. So there's an acceleration actually on the inflows on term deposits. And I was wondering if you could maybe guide us a bit just specifically in the fourth quarter because we've seen term deposit pricing going up recently. So I will assume more clients will move money into term deposits also in the fourth quarter. So you can help us on that.

No. And it's also here what we did say is what we've seen so far. And the trends we're seeing in the EUR 7 billion now. But if you look at the overall outflow from current accounts, we've seen in our client deposits, which is just over 20% that we expect that most of the deposit migration happens this year, and there might be some residual flow next year, but we expected the trend to slow down versus what we have seen so far. And also I mentioned already, it's also looking back of the sort of stable base of current accounts is what we've seen of previous cycle. So our expectation is that the rate of migration is slowing down, Benoit.

Our next question comes from Amit Goel from Barclays.

Two questions for me. One, just in terms of your capital and thresholds on a Basel basis. So I appreciate we'll get the new thresholds with the Q4 results. Just wondering if you think you'll be able to guide more precisely on the Basel IV CET1 ratio by then or whether we should still think about it with a kind of plus/minus 50 bps kind of range. And then secondly, I just wanted to follow up on the EUR 120 million potential additional SRF charge. What you have provisioned for or haven't provisioned for? Just wondering whether we should expect a final conclusion on that case before the end of the year and/or if it's a kind of a risk to your OpEx guide?

Tanja, on Basel IV and Freddie, you may expand on the ESR.

Yes, on Basel IV, as I mentioned, the discussions on the final regulations are still continuing. And well, we had expected already that they would be finalized, but that's not the case. And dependent on when they will be finalized, it will take us time to make sure that we capture everything in our systems. And so we will do our utmost to be as accurate as possible, but it depends very much on the final regulations and the time it requires us to get that into our system. So there are no promises there yet.

Yes. Amit, then coming back to the overall regularities. As we said earlier that we are in disagreement with single resolution board specifically regarding the calculation and methods for our mortgages. So this is for the period as of 2016. And what we have done, we have paid EUR 120 million, but the overall [claim is] under protest. So this has been booked as other assets, so no P&L impact for now. And we are challenging this in courts, so we do not expect in a short period from now, any sort of conclusions from this. So most likely, this will be possibly a lengthy process because, I think, we might not be the only bank protesting against the single resolution board and we consider it clearly more likely than not the challenge for [indiscernible].

Did it answer your question, Amit.

Yes, thank you.

Tarik Mejjad from Bank of America.

One observation and 2 questions, please. First of all, I'm still really amazed how the guidance on NII, it looks like difficult for you to provide something more clear. I mean I understand the volatility in treasury reserves. But I mean, you look like you have a very good view on each of the moving parts of NII, but we can't put it together and have some -- at least some slightly -- I mean, the miss this quarter shows really how the market is struggling to capture that. So what's in Q4 and full year results, you will have more information to give us a guidance for the revenues and NII for the year and the medium term. So then my question is on costs. I think you suggested that some of the costs will be delayed into next year. Should we see that as higher cost in '24 versus the new guidance, '23? Or it's just some delayed cost that will actually divert you away from the EUR 4.7 billion that you walked away from in Q2. And lastly, on capital, why did your Pillar 2 R actually went up 25 basis points? Can you clarify what's the point? And on capital return, what actually will make you think that now is the time to distribute more excess capital to shareholders in Q4? What are actually the drivers that will make you more comfortable?

Okay. Thanks for the questions. NII, maybe Freddie to explain.

Yes, Tarik, I understand your observations. So I will not repeat this. Is it the difficulty or not? We try to provide a good underlying sort of explanation on the different moving parts. But going into next year, we just reiterate that there is more upside than downside from current levels. But clearly, we cannot predict all factors and then how much it will develop. And I will not repeat what I explained earlier overall on the treasury results what the underlying elements are. Are these also observations for us, how to deal with you and be more explicit and what the expectations are, but as I said, we will come back to you with an update of our financial targets. So we will take this into consideration.

And maybe, Tarik on costs. Clearly, there is a cost spillover into '24 as a result of some of the delays that we've had to do. I think it's too early to begin to guide toward where '24 cost levels will be. That is the process that we're in the midst of now and that we expect to conclude on -- at Q4. So we can give you more guidance on where we think '24 cost levels and subsequent cost cycles will move to. Your question on P2R it really is an outcome of a process that has been concluded that P2R requirement has now been included in our capital as we disclosed. It doesn't really impact our minimum capital. The 17% is still far away, significantly away from our NDA. So we've absorbed the P2R. In terms of capital return, again, I would -- we will update us at Q4. We will then look at the entire capital framework and that would include considerations on potential capital return. So I would wait until Q4, so we can give you more details on that.

No, I understand you have to wait for Q4, but I really [indiscernible] we're trying to understand your -- your thinking here in terms of what are the constraints? What's actually make you change? I mean capital framework was a wide term. I mean, to talk about your capital management, but -- what are the areas that's really concerning. I mean to you were transparent saying there is an M&A component, uncertainty about the macro. So we understood basically why you were reluctant, but now we don't know really what are the drivers for you to distribute or not?

For sure, we will clear that up in Q4. What I can tell you is that we've moved on from 2020. That is one of the reasons why we want to reconsider the framework, the capital framework now we'd be getting ahead of the actual considerations. But I do think it's fair to say that since 2020, we have had -- and we've executed parts of the strategy that led to coming up with the 200 basis point thresholds that we talked about. So that is why now at this time, we are reconsidering all those factors in order to come up with an updated capital framework. So it is taking very much into consideration the effects of our strategic choices over the last, what is it 2.5 years.

Anke Reingen from RBC.

I just have 2 follow-up questions, please. Firstly, apologies if I missed it, but did you actually give us like the deposit beta for like latest Q3 and Q2. And then in terms of the delayed investments, I mean, they are quite sizable absolute amounts. What is sort of like the implication in terms of the revenue outlook? Or are they -- were they just fine-tuning? Or are there more material in terms of your direction.

Maybe, Freddie, on the NII, I will take cost.

Yes. We didn't say anything about expectations on deposit beta. As I said earlier, we don't steer on beta, Anke. We look at the overall replication vis-a-vis the overall saving rate. But we did say that if you look at the Netherlands, the overall deposit beta is relatively high for versus other countries. And if you look at overall liquidity profile and increasing deposits for us there, so no need to be more aggressive on that front. So that's all we said, Anke...

Yes. So an implied beta. Yes. And in terms of your question on cost, actually, the reason why we're investing so heavily in both digitization and for upgrading of our own infrastructure is because it allows us to accelerate our revenue growth. We have taken some very clear decisions in terms of how we want to transform the bank. It means that we are increasingly, as we begin to close down our offices, we only now have 25 branches left. We are accelerating our digital propositions. And at the same time, we also saw this quarter, we are starting to grow in some of the target segments. We've identified for ourselves and that includes the younger side of the population, if I can call it that, and that means that we do have higher requirements for our digital infrastructure. So it will allow us to not only serve these clients better, but also allow for revenue growth. That's why we're investing.

[Operator Instructions] The next question comes from Flora Bocahut from Jefferies.

Yes. The first question is actually on the replicating portfolio. It seems that the benefit from higher rates on your replicating portfolio is continuing to level off. Can you maybe remind us the size and the duration of that portfolio? And I don't know any comments you want to make specifically on the replicating portfolio here. Then a question on the model reviews. Obviously, quite some impact on Basel III RWA this quarter again. I guess, again, in Q4. What about 2024? Is this something that you think will continue into next year? Or do you consider the bulk is behind you and it will slow from here? And just a follow-up on the regulatory levy guidance because -- do I understand correctly that you continue with the same guidance of a EUR 200 million decline next year despite the recent change in the Dutch Bank levy.

Yes. So on that last question, we do -- we maintain the guidance that we have regulatory levies. On the replicating portfolio, Freddie?

Yes, because on the regulatory levies also for, it is -- if you look at overall the banking taxes here, it's an increase for us of roughly EUR 30 million annually. So it's a 30% increase still needs to pass [in senate], but it's in our base assumption that will be approved there. Then going to your replicating portfolio? Is it level enough? Well, clearly, deposit margins recovered from negative rates. So replication portfolio is no longer the main driver of NII development, but we still expect it to be a tailwind into 2024 for our -- for NII. Size of the replicated portfolio is now around EUR 117 billion ahead because normally, if you see deposit migration to time deposits, time deposits are clearly not part of the replicating portfolio. And what we have disclosed earlier roughly 45% of the replicating portfolio reprices within 1 year, and the overall portfolio has roughly -- it's more invested in barbell structure. But the overall duration is roughly, roughly 3 years.

Tanja, maybe on expected model reviews.

Yes. So the model reviews will continue. That is -- that's what we continue to do. And actually, a model review takes also quite some through put time given that regulatory approvals are required on our IRB model. So I expect that, that will continue. But clearly, we have taken quite some additional RWA migration for model review, sorry. And so we have the majority there behind us. And then maybe as a -- apart from the upside pressure that we see, we will also see that once Basel IV comes in there will be a reduction in RWA on some of our portfolios, given that floors are lower in Basel IV than Basel III. So still upside pressure, but also some correction in the Basel IV.

That is useful. Can I just ask you for the number, how much RWA increase you saw from model reviews year-to-date?

I would have to -- so as I said earlier in this call, this quarter, it was somewhat higher than the 2.1 net increase, but I would really have to look it up for the full year because that's not the number that we track. And you can imagine there are a lot of things going into RWA development. So also portfolio development. So it's always hard to compare that like-for-like given that portfolio changes during the year as well.

We have a follow-up question from Benoit Petrarque from Kepler Cheuvreux.

Yes. Just a short one on the capital framework. Do you think you will be able to base your capital framework on the Basel IV CET1 ratio of 16%? Or what do you think, for the time being, given all the uncertainty you will be using like the Basel III capital? That's my question.

Yes. I think it's indicative, it would be Basel IV, but we need to complete our analysis coming into Q4. So I think it is early days to make those final calls, but indicative, we would be thinking about Basel IV.

Thank you. That's all questions we have for today. And with this, I'd like to hand the call back over to Robert Swaak for any additional or closing remarks. Over to you, sir.

Well, thanks, everyone, again, for joining on the call, and I look forward to the continued conversations. Thank you.

Thank you. This concludes today's conference call. Thank you for your participation, ladies and gentlemen. You may now disconnect.