2018 INDONESIA BANKING SURVEY TECHNOLOGY SHIFT IN INDONESIA IS UNDERWAY - FEBRUARY 2018 - PWC
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February 2018 2018 Indonesia Banking Survey Technology shift in Indonesia is underway
2018 Indonesia
Banking Survey
David Wake
Financial Services Leader
PwC Indonesia “
Technology, technology, technology. This is the recurring theme coming out of our 8 th
Indonesia Banking Survey. Respondents said technology is the #1 driver of business
transformation and the top risk to the industry. Transactions through digital channels are
surpassing traditional branches in Indonesia for the first time. The war for talent is strongest
for technology specialists.
Lucy Suhenda Indonesia Banks are trying to keep pace with this change: only 8% of respondents said
Banking Leader
their bank has the same strategy as they did 18 months ago. Almost half have significantly
PwC Indonesia
changed their strategy in that time period. 9 out of 10 are undergoing some form of a cost
reduction program, and the most common approach to reducing operational risk is
automation.
The outlook is improved for 2018 over last year, but cautiously so. Concerns about credit
risk and net interest margins are subsiding, and there are improved expectations for
profitability.
There will be winners and losers in this rapidly changing environment. We see areas where
Indonesia banks need to take more action – clarity of strategy, a greater focus on customer
centricity, driving strategies through to execution, and investing further in systems and risk
management to move from a moderate to high level of preparedness.
We thank all of our respondents to our 2018 survey and trust it will be a helpful catalyst to
stimulating dialogue for the betterment of Indonesia banks and the industry as a whole.
Areas of Insight
Outlook Transformation Risk
Conditions and Profitability Drivers of Transformation State of Play
Margins Disruption Preparedness and Response
Credit Risk and Loan Growth Strategy Considerations PSAK 71
Opportunities Customer Experience Opportunities
3
Outlook
4
Takeaways
Expected NPL decline, but Net Interest Margin
Cautious optimism concerns on credit risk are still optimism may be
high overestimated
More effective steps to
Loan growth driven by More merger & acquisition activity
improve competitiveness
consumer lending expected
are needed
5
Cautious optimism
Measures to improve competitiveness falling short of expectations
Mixed views on extent of improvement in 2018, with
those from local banks again being the most positive In 2015, the government launched a This is an important component of
series of new initiatives to stimulate the Indonesia building its competitiveness
Q What is your view of Indonesia’s market conditions for Banking in 2018, compared to 2017? economy and improve the ease of doing for an open ASEAN market. On the
improving same worse business. Last year, respondents felt the positive side, two-thirds of respondents
55% 41% 43%
actions were positive but views were feel banks are “somewhat prepared” for
mixed on the likely direct impact to their an open market. Those from foreign
business. Bankers now feel the actual banks are perhaps most well positioned
Local
impact did not meet expectations. Only to reflect on this question, given they
Foreign 3% felt a significant impact (compared to have operations across the region -
18% expected), and 60% in fact reported they were less optimistic with 42%
no noticeable impact at all. Where there feeling that Indonesia banks were
% forecasting was benefit, it appears to be felt more unprepared.
improved market
conditions strongly among state-owned banks: 67%
feeling a moderate or significant impact
67% compared to only 29% of other banks.
42%
Few bankers believe Indonesia banks are very prepared
for an open ASEAN market
Source: 2018 PwC Indonesia Banking Survey
Q How well prepared are banks in Indonesia to compete in an open ASEAN market?
The outlook is improved, with most Like last year, respondents from
bankers feeling conditions will be foreign banks do not share the State-owned Other banks
the same or better than in 2017. same level of optimism as from
This is similar to a year ago, local banks, who are 50% more Very 10%
however that was coming off a likely to expect better
89% Somewhat 52%
difficult 2016. Given that conditions. Having said that, we
profitability already improved see almost no views that 11% Unprepared 38%
across the sector in 2017, this new conditions will worsen.
outlook could be viewed as an Source: 2018 PwC Indonesia Banking Survey
overall improvement year-on-year.
Moderate profit improvement expected in 2018
CEOs across Asia are optimistic about global Following the trend in 2017, respondents from local banks are
economic growth much more optimistic than foreign bank counterparts.
Q (2018 PwC 21st CEO Survey) Do you believe global economic growth will improve, stay Q What is your expectation for your Bank’s Net Income in 2018?
the same, or decline over the next 12 months?
+113% Increase from
i Chart shows percentage of Asia CEO
respondents answering ‘improve’.
2017 to 2018 75% 8%
41% All
83% 11% State owned
60%
89% Local private
21% 13% 58% 8% Foreign
45%
45%
Decrease Same Moderate Significant
increase increase
Source: PwC 2018 Indonesia Banking Survey
83% of bankers surveyed expected at a confidence on continued profitability in
least a moderate increase in net income 2018, albeit not a significant increase for
28%
in 2018. With loan growth falling below most players.
27%
expectations in 2017, the improvement
in profitability for many banks last year Respondents from foreign banks are
20%
19%
was largely driven by a reduction in less optimistic with more than one-third
provisions for loan losses. In our not expecting an improvement in
conversations with CEOs, we note an profitability for 2018.
improved sentiment on credit risk and
7
2012
2013
2014
2015
2016
2017
2018
Source: PwC 21st CEO Survey
Most banks expect a stable or increasing NIM in 2018
Only one-third of Indonesia bankers expect a Will NIM hold steady in the short and
Net Interest Margin (“NIM”) decrease in 2018 mid-term?
Q What is your expectation for changes in your Bank’s Net Interest Margin for 2018 only? Last year there was a clear shift towards an Larger banks were more likely
expectation of declining NIM, and in fact it did
decline on average about 30 – 50 basis to expect a decline in NIM in
54% points. For 2018, concerns on NIM decline the mid-term
50% have subsided with only one-third of bankers
47% expecting a relatively small decline. Even Q What is your expectation for changes in your Bank’s Net
Interest Margin for the Cumulative NIM change over next
more, one-third expect a NIM increase in the 4 years 2018-2021?
coming year.
40% BUKU 4 83%
When viewed over a longer horizon of the BUKU 3 71%
34%
35% next 4 years, 63% expect some decline, but
32% BUKU
45%
30% 31% again, mostly for a mild decline of 1-50 basis 1&2
28% 29%
27% points. A further 20% expect an increase in
0-50 bps 51-100 bps 101-150
24% NIM over the next 4 years. Foreign banks and decline decline bps decline
23%
larger BUKU 3&4 banks are less optimistic
but most still view the 4-year decline as being Source: 2018 PwC Indonesia Banking Survey
16% less than 50 bps.
Same
37% of respondents do not expect NIM to
decrease through 2021, and most of those
Increase
are smaller banks that are more exposed to a
Decrease
NIM decline due to smaller economies of
2011 2012 2013 2014 2015 2016 2017 2018 scale and higher cost-income ratios. We
continue to highlight that this is a risk to the
Source: PwC Indonesia Banking Survey (2011, 2013, 2015, 2017, 2018) overall sector, particularly if there is a
Base: All respondents
convergence of negative cycles at the same
8 time – NIM decline, slower loan growth,
increased credit risk and higher operating
costs.
We see a downward direction for NIM over the mid and long term
PwC View
Over the mid-term we expect a further decline NIM 12 month rolling average Mild mid-term NIM decline expected
in NIM across the sector due to a range of
Q What is your expectation for changes in your Bank’s Net Interest Margin for the
factors: Net interest margin – rolling 12 month average (all banks) cumulative NIM change over the next 4 years 2018 to 2021?
• Increased competition 6.6% % of Banks expecting a NIM decrease – next 4 years
• Government focus on lowering the cost of 6.4%
BUKU 4 51 bps
banking to consumers, and increasing 6.2%
Local State-
economic growth 6.0% Foreign Private owned
• Stable or declining inflation 5.8%
• Improved country risk 5.6%
All Banks
28 bps
• Inelastic deposit rates 5.4%
• Growth in consumer loans, particularly 5.2% 0-50 bps
mortgage loans 5.0%
Dec-15
Oct-16
Dec-16
Oct-17
Dec-17
Apr-16
Aug-16
Apr-17
Aug-17
Jun-16
Jun-17
Feb-16
Feb-17
• Increased focus by banks on cost
management and cost-income ratios
Source: OJK statistics, PwC Analysis
50%
NIM trends on their own do not give the full Given the growth environment, our advice to
picture of bank profitability. Banks with higher most banks in Indonesia is to focus on cost 50-100 bps 61%
risk in their asset portfolio – and who have and a lean environment – however, not solely
priced in that risk - will necessarily have for cost sake, but for using those savings to > 100 bps
higher NIM. Nevertheless, we believe that invest in other areas. “Cut 10 to spend 10” 79%
while there will be smaller ups and downs and a Fit for Growth strategy will position
over the next 5 years, the ‘bouncing ball’ is in banks to take advantage of the market
Source: 2018 PwC Indonesia Banking Survey
a downward direction.. potential while not sacrificing on profitability
9
Overall loan growth improved, but sluggish
Small increase in overall estimated loan growth in 2018
Q What is your Bank’s target for loan growth for 2018?
It was only a few years ago that fewer than Credit risk still the top
half of respondents even put credit risk in the
top-3 list of challenges. That grew steadily challenge to growth
until 2017 when almost all bankers had it in Q What are the top 3 challenges for achieving
> 20% 13% your loan growth in 2018?
their list of top challenges. This has not
Chart shows % of respondents noting Credit Risk as a top-3
changed significantly in 2018. i concern
16-20% 13%
2018 91%
11-15% 38%
While concern on credit risk has slightly
subsided, concerns on Margin Pressure have 2017 94%
6-10% 30% increased. In 2017, Margin Pressure was the 2015 67%
0-5%
#1 challenge to growth by 18% of bankers. 2014 49%
6%
This is now up to 29%. As margins decline, 2013 24%
more pressure is put on profitability and the
2017 level
Source: PwC 2018 Indonesia Banking Survey efficiency of the organisation becomes a
Base: All respondents
bigger factor in the bank’s ability to be
competitive on pricing or to invest for growth.
Margin pressure is
Based on responses, we estimate an Additionally, credit risk is still very
increasingly a top
In fact, for respondents from larger BUKU 3&4 challenge
increase in loan growth of between 2 high on the list of challenges to banks Margin Pressure was equal to Credit
to 3 percentage points. While there growth, hardly moving from its top Risk as the overall #1 challenge to loan Q What are the top 3 challenges for achieving
are clearly more robust plans for position from last year. We also see growth (35% each). As noted earlier, the your loan growth in 2018?
growth in the mid-range of 10 to 15% some increased concern about weak larger banks are 70% more likely to expect a Chart shows the highest rated challenge to growth noted by
(38% in 2018 vs 27% in 2017), there demand. Overall 30% of bankers i respondents
decline in NIM in both 2018 and beyond.
were also fewer bankers at the top noted this as a Top-3 concern last
end of the range (loan growth greater year, and this is now up to 47%. This Smaller BUKU 1&2 banks were instead more Credit risk 44%
than 20%). is especially higher amongst the concerned about Credit Risk as the main Margin
29%
pressure
larger BUKU 3 and BUKU 4 banks challenge (52%). Weak demand 15%
(60%) that drive a lot of the nominal
10
loan growth. Source: PwC Indonesia Banking Survey (2013, 2014, 2015, 2017, 2018)
Base: All respondents, composite calculation on respondent views on commercial and
consumer lending growthConcern about weak demand is also higher
Weak Demand is increasingly
noted by bankers as a Top-3
challenge
Chart shows % of respondents noting Weak Demand as a top-3 concern
i Concerns about weak demand are also
higher year-on-year, noted now as a
2018 47% top-3 challenge by 47% of banks.
2017 30% BUKU 3&4 respondents were more
likely to note weak demand as the #1
challenge compared to smaller banks
67%
(22% vs 8%).
BUKU 4
BUKU 3 56% This may be a reflective of overall
BUKU 1&2 weaker demand in the economy, but
35%
may also reflect tightened loan
underwriting standards by banks over
the last 18 months.
Source: PwC Indonesia Banking Survey (2017, 2018)
Base: All respondents, composite calculation on respondent views on
commercial and consumer lending growth
11Stronger, consistent expectations of NPL decline
Our 2015 survey revealed significant Overall the respondents believe that the Another significant shift downward in expected
concern about rising NPLs at that time. worst is behind Indonesia banks in terms NPLs for 2018
This began to reverse in 2017, but with a of NPLs. However, with credit risk still first
large number of bankers still unsure about and foremost on the minds of bankers Q What is your expectation on the overall level of non-performing loans in your Bank in 2018
whether NPLs had bottomed out. The when it comes to loan growth, the
outlook for 2018 is a growing confidence, challenge will be whether credit risk Decreasing NPL Increasing NPL
with now two-thirds of respondents management has improved to a level
65% 2018 13%
forecasting NPLs to decrease. Of those better able to manage risk as loan growth
expecting a decrease, one-third expect it slowly increases. This is a point that we 45% 2017 16%
to decline by more than 25%. noted in our prior year survey and believe
it is equally applicable to 2018 – 17% 2015 47%
Local banks continue to be slightly more economic stress clearly plays its part in
optimistic than foreign banks, but we did the cost of credit, but is the industry better
not note the same degree of disparity in prepared now than it was 2 years ago to 2018
views we noted last year. The most manage risk? We explore this further in
significant year-on-year change in views 72% State/BPD
later sections of our survey.
is from foreign banks. Last year only 28% 61% Local private
were expecting a decrease in NPLs, and
that has now more than doubled to 58%. 58% Foreign 21%
80% Syariah 20%
Source: PwC Indonesia Banking Survey (2016, 2017, 2018)
12Most NPL concern is concentrated on corporate loans and large SME
Corporate loans by-far still the area of
most concern to Indonesia banks
Q Which area provides the most concern to your Bank in terms of potential There is no significant change in the main Apart from BPD banks, the concern regarding
NPLs in 2018?
driver of NPLs – it remains corporate lending. consumer lending NPLs is comparatively very
Areas of most NPL concern Consumer lending is much less of a concern, low, even more than in 2017.
with the exception of smaller BPD banks.
Corporate/ Consumer/ SME Micro NPL ratios in the consumer segment are low
Commercial Retail
Among bank groups: by comparison to other emerging markets,
and we expect over time to see more
State-owned 50% 12% 38% SOE banks – results are consistent with our sensitivity to the credit risk in this segment as
2017 survey. activity and growth intensifies.
Local private – concern over SME lending
Local private
56% 33% 11% has grown slightly, with it being now the #1
concern among one-third of respondents.
Foreign – As we can see, foreign banks
Foreign 79% 13%
continue to be wary of the NPL risk in
corporate loans disproportionately to other
banks. This may partly be due to the fact that
many foreign banks, particularly foreign
BPD 40% 50% 10%
branches, have a higher proportion of such
loans compared to local banks.
BPD – there is a much larger concern noted
on consumer/retail loans, but this is reflective
also of the nature of the BPD portfolios in
comparison to larger banks.
13No significant change in corporate lending growth expectations
Little change in expectation for year-on-year corporate loan growth.
Smaller banks are more bullish.
Q What is your Bank’s target for loan growth in 2018 for commercial/corporate/large SME?
2017 2018 Bankers expecting greater than 10%
corporate loan growth
12% > 20% 9%
BUKU 1&2 BUKU 3&4
12% 16-20% 13%
32% 11-15% 37%
80% 46%
32% 6-10% 38%
11% 0-5% 3%
1% Negative Local banks Foreign banks
66% 43%
Source: PwC Indonesia Banking Survey (2017, 2018)
14And challenges continue in terms of credit risk
On the whole, estimates for corporate loan Last year we noted that there was very little
growth are essentially flat year-on-year. While correlation between expectations of loan
there was a slight increase noted among growth and expectations of NPL levels. This is
some respondents, statistically it was still the case for those expecting lower levels
insignificant. We believe this is driven by of growth – in fact, 65% of respondents who
continued concerns about loan quality and have more moderate expectations for
tightened credit underwriting standards. 2017 Corporate loan growth (less than 10%)
was below expectations for many bankers, actually also expected NPLs to decrease in
and therefore although the survey result is 2018.
essentially the same year-on-year, this is
indicative of a view that there will be some For those expecting higher growth (greater
slight increase comparative growth in 2018. than 15%), there was indeed some correlation
in that 71% of those bankers also expected
Estimated corporate loan growth is much NPLs to decline. However, we note that this is
higher among smaller banks, with 80% influenced by state-owned banks who are
expecting growth in excess of 10% compared bullish on loan growth and positive on NPL
to only 46% of larger banks. It is not clear decline for each of the last 2 years.
what is driving that optimism.
Foreign banks are also more cautious
compared to local banks where 50% more
local bank respondents expect corporate loan
growth in excess of 10%.
15Consumer lending expected to lead loan growth in 2018
Consumer loan growth is projected to be As the market heats up in consumer Sharp increase in bankers expecting more than
stronger in 2018 than in 2017. Last year lending – particularly unsecured lending – 10% growth in consumer lending
57% of respondents expected loan our question for the industry is whether
growth in excess of 10%. This year, that banks have the necessary robust Q What is your Bank’s target for loan growth in 2018 for Consumer?
has expanded to 71%. systems and data analytics to price and
monitor risk appropriately. While that was 2017 2018
In 2017 the broad increase in NPLs had not the focus of our survey, we believe
the effect of putting a premium on 22% > 20% 17%
there is a risk that many banks have
collateralized lending such as mortgages. growth ambitions in consumer lending 14% 16-20% 14%
We now see an increased interest in all that are not equally matched by their
consumer categories for 2018. Clearly investment in risk management 22% 11-15% 40%
mortgages is still the main focus, but preparedness. 32% 6-10% 20%
overall we expect a higher level of
competition across all consumer 11% 0-5% 9%
segments.
3.21
Q Which product(s) are you principally targeting to drive growth in consumer loans at your Bank in 2018?
Products targeted to drive growth
Mortgage 63%
Cards 29%
Unsecured 27%
Auto 25%
2017
Micro 19%
2018
16 Source: PwC Indonesia Banking Survey (2017, 2018)Local banks in particular are focused on growth in retail lending
Both large and small banks When we additionally analyse the During that time, NPLs on consumer Credit risk is still a challenge
respondents who expect particularly high lending have also increased but are still
plan strong growth in growth – defined as greater than 15% -
to growth but margin
comparatively very low. The question to
consumer lending we see that 43% of smaller BUKU 1&2 be asked is whether Indonesia banks pressure is on the rise.
banks expect such growth. That is twice have applied lessons learned, and
Q What is your Bank’s target for loan growth in 2018 for Q What are the top 3 challenges for achieving your loan
Consumer? the level of larger banks that expect high invested or will invest more heavily into growth in 2018?
growth. Smaller banks tend to be less their credit risk management in terms of Chart shows the top challenge to growth noted by respondents
i
Bankers expecting greater than advanced in their data analytics and we retail lending as well.
highlight that the new requirements of
10% consumer loan growth
PSAK 71 (“incurred loss” provisioning #1 challenge to Consumer loan growth
BUKU 1&2 BUKU 3&4
model to “expected loss” model) will add
additional burden in this respect. Credit risk
We note again that the challenge in a
72%
77% high growth environment for consumer
lending will be whether banks are
43% Margin
prepared not only on the front-end sales pressure
channel, but also with respect to robust
Foreign banks Local banks
lending scorecards, data-analytics,
collection and overall risk management Weak 31%
systems. As corporate loan NPLs grew in demand 11%
42% 85%
the last 2 years, many Indonesia banks
realized that there was more to be done
2018
in improving their credit risk
2017
management of corporate lending.
Source: PwC 2018 Indonesia Banking Survey
17Growth through M&A:
Increased likelihood over next 2-3 years
What we see this year is an increase in the number of bankers
Local and state-owned banks more likely to be acquisitive considering M&A as a tool for growth, moving up from 46% to 60%.
Q How likely are you to use M&A as a tool to achieve strategic objectives in the next 2 to 3 years?
Among the large SOE banks and local banks, the likelihood is even
stronger with between 70% and 100% expecting M&A. However, one
should note that the number of bankers in the “Very likely” category is
Very unlikely or somewhat unlikely to use M&A Very or somewhat likely to use M&A still relatively low at 14% of all respondents.
40% 2018 60% The drivers for M&A also vary among bank groups: State-owned banks
look more to the opportunity for corporate synergies, while Foreign and
54% 2017 46%
Local private banks focus more on expanding business channels.
In the prior year we noted that M&A activity was sluggish and this may
2018
have been due to many willing buyers but not many willing sellers. While
100%
State it is still to early to extrapolate, we see many banks having re-evaluated
20% Syariah 80% their strategies in the last 18 months, seeking to focus on their core
strengths. This may be a catalyst for further M&A in the future.
27% Local private 73%
3.21
54% Foreign 46% Key differences in drivers for M&A
70% BPD 30% by type of bank
Q If somewhat or very likely, what is the primary driver to use M&A?
Source: PwC Indonesia Banking Survey (2017, 2018)
Expand business channels Corporate synergies
9% State-owned 64%
45% Foreign 27%
18 38% Local private 31%Growth through Syariah and Infrastructure:
Little perceived change year on year
Less optimism on future Syariah market share Syariah banking assets stand at Plans for infrastructure finance were
growth than in 2017 approximately 5% of total banking assets relatively unchanged from 2017. There is
in Indonesia. With the largest Muslim still a strong interest to participate.
Q Syariah banking is currently approximately 5% of banking sector assets in Indonesia. What is your population in the world, many are looking
forecast for this percentage in the industry by 2025? We noted that the expected involvement
at the opportunity to grow Islamic finance
Estimated Syariah market share by 2025 at a faster rate than the conventional is significantly higher for state-owned
market. However, in our survey most banks than for foreign banks. Given that
2017 2018
bankers felt that the Syariah banking the government has acknowledged that
> 15% share over the next 8 years would either foreign investment is essential to meet
stay the same or just slightly higher. Only the country’s needs, especially in
14% 11-15% 17%
22% of respondents expected it to reach infrastructure development, we believe
53% 6-10% 39% the levels equal to the government’s 2023 this gap is something that will need to be
ambition of 15%, of which two-thirds were addressed by the government, the
28% Same (5%) 40% industry and stakeholders.
from state-owned banks.
The same expectation on involvement in
infrastructure finance as in 2017 Is there a level playing field in infrastructure finance?
Q What is your expectation for your bank’s lending or involvement with infrastructure finance in Q What is your expectation for your bank’s lending or involvement with infrastructure finance in
Indonesia in the next year? Indonesia in the next year?
Expected Infrastructure Finance
State-owned 84%
2017 2018
Foreign 54%
15% Significantly more 20%
46% Somewhat more 45%
27% Same 28%
19
12% Less 7%Transformation
20Takeaways
Technology still the main
Technology spending is focused Many digital strategies
driver of business
on the customer front-end lack sufficient clarity
transformation
State-owned bank Transactions through digital
Opportunities to improve
footprint is getting channels are surpassing
Customer Analytics
bigger, and bigger traditional branches
21Technology continues to drive business transformation in 2018
Focus is on front-end customer platforms
Technology the #1 driver of business transformation Tech spending is most focused on front-end systems
Q What is the primary focus of your technology spending?
Q What will be the main drivers of transformation in your banking business for the next 3 to 5 years?
Front end Core system Back office
46%
44%
44%
33%
43%
34%
25%
17%
13%
11%
11%
14%
Foreign
Foreign
Foreign
State-owned
Local private
State-owned
Local private
Local private
State-owned
6%
Changing
Operational Risk
Technology customer Competition Competition
Regulation
Excellence management
needs What is noteworthy for 2018 is the Apart from front-end technology,
rising importance of changing state-owned banks are also focused
customer needs, which is driving on core systems, while other banks
In our prior year survey, 84% of bankers banks to rethink how they do more on the back-office. Foreign
surveyed were likely to invest in technology business. This was noted as the #1 bankers were also more likely to
transformation in the next 18 months. The driver for transformation by one-third invest in risk management systems
priority on technology continues with it still of respondents, up from 17% in (42% noting it as a top-3 priority vs
being the #1 driver of business transformation 2017. The customer-centric focus is 22% from state-owned banks).
in Indonesia banks. evident also in that most banks are
directing their tech spending to front-
Source: PwC Indonesia Banking Survey (2017, 2018)
end web/app/e-banking systems.
Source: PwC 2018 Indonesia Banking SurveyTransactions through digital channels
surpassing traditional branches
For the first time in our survey, This migration to mobile and
What is the future of the traditional branch? mobile and internet has taken internet is nothing new. But
over the top channel spot for the pace of the change in
Q What is your estimate of the proportion of the customers’ transactions which were processed through branch, customer transactions. Indonesia is significant to
internet/mobile and ATM?
Traditional branches no longer note. That change is most
% of respondents noting > 50% of dominate the transactional swift among the larger BUKU
transactions in the following channels landscape as it did only 3 3&4 banks. In last year’s
years ago. survey, 53% of those bankers
estimated that more than one-
75% In 2015, only 10% of quarter of their transactions
respondents noted that more are via mobile and Internet.
Traditional than 50% of their transactions That number is now up to
branch are processed via mobile or 75%. The shift among smaller
internet banking. This is now banks is occurring but more
more than one-third of slowly (42% to 52%).
respondents. In 2015, 27%
from our survey said at least It is true that for many banks
45% one-fourth of transactions even though the volume of
were via mobile & internet. transactions is lower, the
35% This is now up to 67% of value of transactions through
31% respondents. In fact, even the branch is still high.
ATM transactions are However, we believe that the
Digital approaching the level of pace of technology change
channels 22% traditional branches (though a and move to a more cashless
20%
difficult measure given that society will drive change in
15% ATM many ATMs are ‘in-branch’). that respect as well.
10%
23
2015 2016 2017 2018Expected Fintech disruption is mild for 2018 but picks up
substantially over the next 5 years
For 2018, only 6% of respondents anticipate a Fintech disruption anticipated over the next 5 years
significant disruption from Fintech. However,
Q What is the level of risk that your bank’s business will be disrupted by new Fintech competition in the market in 2018
when viewed over a 5 year horizon that and over the next 5 years?
number jumps to 28%, with a further 52%
expecting a moderate disruption. Expected disruption to business from Fintech
Respondents from larger banks feel even
In 2018 Over next 5 years
stronger that disruption is coming: 41%
expect significant disruption over the next 5 6% Significant 28%
years compared to only 19% from smaller
banks. 32% Moderate 52%
51% Some 18%
Our survey did not differentiate the types of
Fintech: peer to peer lending, blockchain, 8% None
process automation, etc. However, there is
clearly a recognition that technology is a Don’t know
game changer.
Despite the views on Fintech disruption over Over next 5 years
the next 5 years, Fintech investment was still
relatively low among technology investment BUKU 1 & 2 BUKU 3 & 4
for Indonesia banks in 2018. Only 22% of 19% Significant 41%
bankers listed Fintech in their top-3 areas for
investment in the coming year. 52% Moderate 52%
29% Some 7%
24However, challenges remain in terms of needed clarity on strategy
Digital strategies are in need of further clarity
Q How clear is your bank’s digital strategy for reaching and transacting with customers on digital platforms such as
Half of respondents from foreign and One interesting result is that despite the
mobile, internet, smart phone, etc? larger SOE banks felt their digital rapidly changing environment in terms of
strategies were ‘very clear’. This technology, mobile banking, Fintech,
% who feel their tech strategy is “Very Clear”
compares to only 21% for all other robotic process automation, AI, etc, most
Foreign 50%
respondents, indicating much room for bankers in Indonesia feel their current
improvement across the sector. On the technology is as ready to meet future
State-owned 50% other hand, only 11% felt their strategies needs as it is to meet the current needs.
Local private 22%
were unclear. Results were almost This does not seem consistent with the
identical to those in our 2017 Survey. views expressed about clarity of digital
BPD 20% strategies.
We noted a strong correlation between
Syariah 20%
the clarity of the digital strategy and the Respondents also noted that technology
extent to which a respondent felt their skills were the hardest to find in the
bank was prepared for the future. Among market (43% noting as scarce or limited).
Moderate feeling of technology preparedness those that felt ‘very prepared’, 73% also Therefore at a time when it is critical to
felt the strategy was very clear. Among have sharp strategies and
Q How well prepared is your Bank’s technology to meet the needs of your current, and future, banking business and those that felt only ‘somewhat prepared’, implementation, skills are also difficult to
customers in Indonesia? the level of strategy clarity dropped to find and retain.
30%.
Somewhat
Preparedness of IT to meet current and future needs
Very
These results can be reflective of a lack
or very
prepared Somewhat prepared unprepared of strategy, or a good strategy that is
Current 28% 62% 11%
simply not well understood across the
organisation. We note also that our
Future 17% 66% 17% survey respondents are from among top
management of banks. A wider selection
of bank employees may have any even
lower level of clarity on strategy, making it 25
difficult to implement effectively.State-owned banks are getting bigger…and bigger
Who is growing or State-owned banks are most optimistic about
shrinking their footprint? conditions for 2018, and this shows in their plans
Expansion Reduction for expansion - more than two-thirds are
Q In 2018, what are your plans for growth in the expanding both branches and employees, while
following areas? almost none indicate plans for reduction. This is
State- Local State- Local particularly the case with respondents from BPD
Reduction No growth Growth owned Foreign private owned Foreign private banks, of which 90% expect growth.
67% Respondents from local private banks were also
61% bullish, albeit not quite to the degree of state-
owned banks.
50%
44%
Branches
On the opposite end of the spectrum were
31% Foreign bank respondents – half are expecting a
25% reduction in the number of branches and only
17% 12% expected the number to increase. These
12%
trends were noted in our 2017 Survey: state-
5%
owned banks and local banks are more
aggressively growing their footprint and getting
bigger in the process.
72%
There appear to be two very different strategies
at play. Among respondents from state-owned
51%
and local private banks expecting higher loan
Employees
50%
42%
growth (more than 10%), only 11% expect a
33% reduction in branches. This number is 69% from
26% Foreign banks expecting the same growth.
23%
17% Foreign banks are less bullish on loan growth,
but where they are, they are seeking to do so
6%
with a smaller branch footprint, and are investing
in automation and digital capabilities.Fit for Growth: “Cut 10 to spend 10”
There are a number of reasons why In other words, to be successful, A strong perceived need for cost reduction within
banks may take different strategies in Indonesia banks are not only growth environment
terms of growing their physical branch addressing investment for growth, but
network: knowledge of the local market, also how to reduce cost to make as Q How do you feel about your Bank’s cost levels in order to be able to compete in the market and
meet your Bank’s growth and/or profitability goals?
region or customer base; different much of that investment as possible
product focus (e.g., affluent vs mass
market); ambitions to grow market In our Fit for Growth approach, we
Cost are competitive
share vs a more short-term focus on recommend organisations to focus on or an advantage Cost reduction needed
doing three things consistently and BUKU
profitability, etc.
continuously: 26% 1&2 74%
However, as we can see from the
survey, there are two dynamics 1. Focus on a few differentiating 24% 3 76%
impacting all banks in Indonesia: a capabilities
42% 4 58%
growth environment, and a rapid take-
2. Align their cost structure to these
up of digital channels requiring new
capabilities
investment and a reconfigured cost
base. This is driving banks across the 3. Organize for growth Q Is your Bank currently undergoing a review of costs or a program to improve efficiency?
market to be sharper on cost to free up
investment capital. This is the case for It means to have resources, and thus Banks undergoing a cost reduction program
many bankers more aggressively cost structure, aligned to the company’s
expecting branch expansion as well; overall strategy – deployed toward the
e.g., 61% of respondents from State- right businesses, initiatives, and
93% of respondents are
owned banks expect cost reduction. In capabilities to execute the growth
undergoing a cost reduction or
fact an overwhelming 93% of agenda effectively. Fit for Growth 93% efficiency program
respondents to our Survey said their companies have the right amount of
organization is undergoing a review of resources they need to compete
costs or a program to improve effectively – no more, no less – at the
efficiency. right places.
27Significant change in strategies over the last 18 months,
needing more clarity
Strategies are changing: 45% of Indonesia bank strategies are Strategies need more clarity in the
respondents noted a significant change in actively being re-evaluated organisation
strategy during the last 18 months. In fact,
only 10% of respondents have the same Q How has your strategy changed over the last 18 months? Q What do you feel is the level of clarity and understanding of your strategy to
people in your organisation?
strategy as they did only 18 months ago.
However, overall only 30% of bankers felt Modified strategies in the last Level of clarity of strategy throughout
18 months the organization
their strategy was well understood
throughout the organization. This varies BUKU BUKU
1&2 3&4
from a high of 63% among larger SOE
94%
banks down to only 10% among BPD
87%
90%
30%
80%
bankers.
62%
High Moderate Low
Extent to which there is a high level of
clarity of strategy
State-owned 63%
2017
2018
2017
2018
Foreign 45%
Significant change Local private 17%
Moderate change BPD 10%
28Insights: How can Indonesia banks be more successful in driving
their strategies to execution?
Winning companies close the strategy-to-execution gap with five
acts of unconventional leadership
Commit to an identity: You are what you do, not what you sell
Translate the strategic into the everyday: Build your own
5 Shape your future
distinctive greatness
4 Cut costs to grow stronger $ Put your culture to work: Make it your greatest asset
3 Put your culture to work
Cut costs to grow stronger: Stop cutting across the board. Invest
in unique capabilities
2 Translate the strategic into the everyday Shape your future: Focus on what you do best to own your own
future
1 Commit to an identity
“
Companies that commit to the 5 acts,
grow 3X faster and achieve 2X profit
Source: Strategy& analysis
Source: Coherence profiler with 4,400+
respondents, Strategy& analysis
29Where are Indonesia banks in terms of the 6 Customer Experience
Imperatives?
Well defined customer messages across touch Structured feedback gathering and improvement
Right channel and customer mix points process
Foreign Foreign BPD
State-
BPD Foreign
owned
State- State-
Syariah
owned owned
BPD Syariah Syariah
Local Local Local
private private private
Weak Moderate Excellent Weak Moderate Excellent Weak Moderate Excellent
Digitalisation and innovation to retain and Most bankers had a moderate view on their
Consistent experience across channels acquire customers response to the 6 Customer Experience
Imperatives. Only 3% of respondents felt their
Foreign Foreign bank was ‘excellent’ in these areas. On average
Foreign banks were most confident, and Local
BPD BPD
private banks were consistently the least
State-
Syariah confident. However, we note that there was not a
owned
State-
substantial difference across the range of
Syariah responses.
owned
Local Local
private private
Weak Moderate Excellent Weak Moderate Excellent
30Customer Analytics capabilities lagging behind views on Customer
Experience Imperatives
As noted earlier, changing 72% of responses were moderate Bankers are less confident about Customer Analytics capability
customer needs was seen as the or less, with 27% indicating a than with overall approach to Customer Experience
#1 driver of business lower level of maturity. Overall we
transformation by one-third of see that the confidence on Q What is the level of maturity of your Bank’s Customer Analytics capability?
respondents, only surpassed by Customer Analytics is not quite to
technology. Spending on the level of confidence about the Maturity of Customer Analytics capability
technology is also most directed respective bank’s approach to
towards front-end web/app/e- Customer Experience overall. A
Low Moderate High
banking investment. strong Customer Analytics
Customer segmentation & Targeting 3.23
capability is the foundation for
What then is the maturity of ensuring that limited resources are Profitability Analytics 3.22
Indonesia banks in terms of focus in the right direction with the
analysing customers in order to be most benefit. Channel Analytics 3.08
most effective in the delivery of a
Customer acquisition Analytics 2.98
customer-centric strategy? The most mature areas were in
terms of customer segmentation Marketing mix Analytics 2.95
and overall profitability analytics.
Least mature were customer Retention Analytics 2.86
retention analytics, measurement
Experience Analytics 2.85
of the customer experience itself,
and social media mining. Social media Mining 2.66
Customer Experience
Imperatives midpoint
31Risk
Takeaways
Technology and FinTech Capital adequacy and
disruption seen to be #1 Only moderate satisfaction with corporate governance are felt
and #2 risks to Indonesia management of risks to be strong and not a
banking concern
Impact of PSAK 71 to loan Opportunities to improve Risk
Underinvestment in Cyber Risk
provisioning potentially Culture and Integrated Risk
Management
underestimated Management strategies
33Technology now at the forefront of risk in the industry
Cyber risk and FinTech disruption are challenging For the first time we see technology Credit risk was the #2 risk in 2017, and is
related risks at the top of banker now #4. This reflects a more positive
bankers to rethink strategies and response to risk concerns for the industry in Indonesia. sentiment on NPLs, and a better overall
Q Please score the risks facing the banking industry in Indonesia over the next 2 to 3 years Both Technology/Cyber Risk and FinTech outlook, but bankers are still cautious
Low Moderate High
disruption were a clear #1 and #2. By about the credit risk that is inherent in the
Technology/Cyber 4.03 comparison, technology risk was #6 in sector. Only respondents from the large
Fin Tech disruption 3.89
2017 and #7 in 2015. FinTech disruption state-owned banks did not note credit risk
was #12 last year. in their top-5 risks (#6).
Macro-economy 3.63
Business Model risk has risen sharply up At the bottom of the list, capital availability
Credit risk 3.51 the list from #11 in 2017 to #5 for 2018. is the least of concerns to bankers in
Business model
Given the extent to which technology is Indonesia. Capital adequacy levels are
3.40
rapidly changing the entire financial generally high and banks do not feel this
Quality of risk mgmt 3.23 services sector, bankers are concerned is a risk. That is an overall positive factor
whether the current business model is for the industry as a whole, however we
Pricing of risk 3.23
appropriate. Blockchain, payments, peer- see that the challenge for Indonesia
Human resources 3.22 to-peer lending, cryptocurrency, digital banking is not currently constraint in
channels – new risks are emerging. terms of capital and finance, but rather
Interest rates 3.20 one of competitiveness, agility and ability
Risk in the macro-economy had been the to manage risk. The one exception here
Currency 3.12 top risk since 2015, and this has fallen to is among respondents from smaller
Regulation 3.09
a distant #3 as many concerns about the regional BPD banks where capital
Indonesia economy have subsided and availability tied for #6 in their ranking of
Political interference 3.06 global optimism is much improved. In our industry risk.
recent PwC Global CEO Survey released
Economic crime 3.00
at the World Economic Forum in Davos,
Liquidity 2.97 60% of CEO’s in Asia expect improving
global economic growth. That compares
Conduct practices 2.91 closely to the 57% of Indonesia bankers
2.75
in our survey who expected improved
Corporate governance
conditions for the sector in 2018.
Source: PwC 2018
Capital availability 2.65 Indonesia Banking SurveyForeign banks are most confident in their ability to manage top risks
relative to the market as a whole
While technology risk is noted by many, bankers have All respondents feel their bank is more prepared to
diverse views on other risks address the risks than the industry as a whole
Q Please score the risks facing the banking industry in Indonesia over the next 2 to 3 years Q How well prepared is the industry in Indonesia to address top risks?
Low Medium High
State-owned Foreign Local private BPD
Industry preparedness 3.23
Technology Technology Fin Tech disruption Credit risk 10%
Fin Tech disruption Fin Tech disruption Technology Fin Tech disruption Respondent preparedness 3.54
Business model Credit risk Macro-economy Macro-economy
Macro-economy Macro-economy Credit risk Liquidity
Interest rates Regulation Business model Technology State 3.25
Foreign 3.83
Respondents from foreign Banks are Foreign banks not only feel the most Local private 3.17
much more sensitive to regulation than confident about their own ability to BPD 3.60
other bankers. While they noted manage top risks, but they also have the
regulation at #5, other banks rank it only largest gap (25%) between their view of
as #14. Of particular concern is data- the industry’s ability to address top risks
onshoring, IFRS 9 and KYC/AML. and their own ability to address those
risks. This gap was much lower for other
BPD banks note liquidity as the #4 risk bank groups where all were less than 5%
and capital adequacy as #6. This points to difference.
potential challenges unique to these
smaller banks. They are generally less
diversified and have a smaller market
footprint.
Source: PwC 2018 Indonesia Banking Survey
35Lower satisfaction with credit risk management is driving changes in
local banks compared to foreign banks
Indonesia Banking Risk Focus Map - 2018 Credit risk management still under a dynamic
Q Which are your top risk management focus areas in 2018? pace of change
Credit Liquidity Market Operational Compliance Technology Q Which are your top risk management focus areas in 2018?
State Satisfied Satisfied Satisfied Expected change in Credit Risk Management
None Minor Moderate Significant
Foreign Satisfied Satisfied Satisfied Satisfied
Enhance scoring 2.06
Local Satisfied and approval
private Limit exposure to Foreign
1.75 banks
certain industries
BPD Enhance loan 2.39 Local banks
monitoring
Syariah Satisfied (incl. State-
Enhance owned)
collection process 2.22
High focus = greater than 60% said a top-3 priority Satisfied with risk management = 3.67 or more
Unsatisfied with risk management = 2.33 or less Data analytics 2.19
Medium focus = 30 to 60% said a top 3 priority
No indication = “neutral”
Low focus = less than 30% said a top 3 priority
The Indonesia Banking Risk Focus Map It makes sense that bankers would As we can see, respondents from 54% of respondents were satisfied with
highlights the main risk management direct their attention towards risk areas foreign banks and large state-owned their management of credit risk
focus areas of bankers, and whether where they are less satisfied with banks are overall more satisfied with compared to 65% in 2017. The level of
bankers are satisfied or unsatisfied with progress. However, these areas, their level of risk management. We satisfaction with the management of
their actual management of that risk. particularly Credit Risk and Technology noted a strong correlation between credit risk was highest among
Risk, are also noted as top risks for the banks that have an integrated risk respondents from foreign banks (75%),
Generally, we see that bankers are industry as a whole by almost all management strategy and their compared to 44% among state-owned
most satisfied with their management of respondents. The lack of satisfaction satisfaction with risk management. banks and 39% in local private banks.
risk areas they see as lower priorities - with the management of those risks
Liquidity Risk and Market Risk – and As a result, Local banks are expecting to
should be a call for action for Indonesia be much more active in making changes
less satisfied with higher priority risks banks to invest more heavily into those
such as Credit Risk, Operational Risk to their Credit Risk Management in
areas. 2018, particularly in enhanced loan
and Technology Risk.
monitoring and collection.
Source: PwC 2018 Indonesia Banking SurveyLarger banks are addressing Operational Risk through Automation
Following a similar trend from 2017, As we can see, Cyber security was Larger banks investing in automation to reduce Operational Risk
larger BUKU 3 and BUKU 4 banks are fairly low in priority as a strategy to Q What is your strategy to reduce and manage operational risk in 2018?
investing more into Automation to manage operational risk.
Top-3 initiatives to reduce Operational Risk
reduce Operational Risk. On the other
hand, smaller banks are investing Smaller banks Larger banks
more into foundational areas such as
58% Automation 93%
People Development, a review of
Standard Operating Procedures, Risk 87% People development 72%
self assessments and Internal audit.
68% Review SOPs 52%
39% Risk self assessment 31%
6% Cyber security 24%
10% Compliance 14%
32% Internal Audit 7%
37Banks may be underestimating their response to Cyber Risk?
Although Technology Risk was We believe the industry in Only one-third of Indonesia
Global CEOs’ concern about
viewed as the top risk to Indonesia Indonesia is underestimating the banks have a CISO
Cyber threats spikes banking, there does not seem to be effort needed to address Cyber
Q Does your bank have a Chief Information Security Officer?
How concerned are you about Cyber Threats? a similar intensity to managing that Risk. It is not a question of “if” but
Showing only “extremely concerned” risk. rather “when” the organization is Showing only “Yes” response
subjected to a successful cyber
Only 5% of respondents noted attack. While many response plans All banks 31%
2018 40% Technology as the #1 risk and roles exist on paper, in our
management focus area. Similarly experience most banks do not run
2017 24% only 6% of smaller banks and 24% simulations with multiple Local 17%
of larger banks noted Cyber stakeholders when testing whether
2016 21% Foreign 52%
Security as a top-3 strategy for those plans will be effective in
2015 21% managing Operational Risk. practice.
2014 14% The level of respondents’ overall In our recent PwC 21st CEO
Source: PwC 2018 Indonesia Banking Survey
satisfaction with the management Survey, global CEOs expressed a
Source: PwC 21st CEO Survey (2018) of Technology/Cyber Risk was high sharp increase in concern about
at 62%. However, two-thirds of Cyber threats compared to past
respondents noted their bank does years.
not yet have a Chief Information
Security Officer. Only 17% from
smaller banks had a CISO.
38
“ The average estimated total financial loss as a
result of security incidents in Asia is $2.6 million.
Source: PwC Global State of Information Security SurveyPwC’s Global State of Information Security® Survey 2018
Our Global survey reveals that organisations in Indonesia are actively exposed to
the top vectors of Cyber security incidents compared to global responses
40% 26 %
29 %
23 % 27 % 15 %
Employee Software
Phishing Exploited Vulnerabilities
30 %
26%
28 % 23 %
Consumer Indonesia
Mobile
Tech
Device Global
Exploited
Exploited
Source: PwC Global State of Information Security Survey
39Increased compliance risk anticipated for KYC/AML
Fewer bankers expecting an increase in
Compliance Risk in 2018
Q Do you foresee your Bank facing increased legal and compliance risk in 2018? Compliance Risk has been seen to be Smaller banks were expecting the most
on the increase for the last several increase in Compliance Risk in terms
Bankers expecting increased Compliance years. However, for 2018 most of fraud – 69% noted this as a Top-3
Risk in 2018 Indonesia bankers (55%) do not expect risk. There was also a sharp difference
an increase in Compliance Risk. between foreign banks and local banks
in this respect: 80% of local banks
The areas of most focus are related to noted Fraud Risk in their top-3, as
67% Know-your-customer (KYC, AML) compared to only 25% of foreign
which was a top-3 risk noted by 75% of banks. This may be reflective of a
58% larger banks. number of foreign branches that have
smaller retail portfolios. Nonetheless,
Increased KYC/AML risk KYC – high on the list for foreign banks
45% Q Which are your top risk management focus areas in - is closely related to Fraud Risk as
2018? well.
Areas of increased
66%
compliance risk (Top-3)
59%
59%
93%
38%
24%
2015 2016 2017 2018
protection 10%
Source: PwC Indonesia Banking Survey (2015, 2017, 2018)
Consumer
Tax
KYC
Other
Regs
Fraud
AML
40The clock is ticking on PSAK 71 implementation
Only one-third of respondents noted that Among those who had a view, 61% of
Most bankers expecting a PSAK 71 their bank has completed an impact respondents expect increased volatility in
impact of less than 25% assessment of PSAK 71. As a result, there reporting results as a result of PSAK 71.
may not yet be sufficient knowledge from This was as high as 78% from local
which to draw a conclusion about the private banks and 71% from state-owned
Q What is the estimated expected impact to the level of your Bank’s cumulative impact on provisions for banks Furthermore, 42% of respondents
loan impairment provisioning from the implementation of PSAK 71?
impairment. However, at this point most expect an impact to the way loans are
respondents estimated an impact of less priced.
Expected increase in loan impairment than 25%, which is below our experience
provisioning due to PSAK 71 from other markets.
Larger banks are farther ahead in their
progress in that 48% are in advanced
52% stages of impact assessment compared to
only 10% of smaller BUKU 1 and BUKU 2
banks.
1 Jan 2018 1 Jan 2019 1 Jan 2020
10 months 12 months
IFRS 9 PSAK 71
effective date effective date
23%
16% IFRS 9/PSAK 71 requires an “expected-loss” impairment model for more timely recognition of expected credit losses.
9% This requires entities to account for expected credit losses from first recognition of the loan and to recognize full lifetime
expected losses on a more timely basis. Entities will be required to use not only historical losses and current
information, but also reasonable and supportable forward-looking information.
No change 41
0% 25% 50% 75%Two-thirds of Indonesia banks have not yet assessed the impact
Challenges Mitigation
PSAK 71 presents a number of practical • Definition of BM by senior management • Use of existing BM documentation and
challenges that go beyond the core
Classification & Measurement Considerations
• Selling decisions with impact on accounting portfolio structures as starting point
Business model
classification and measurement issues. • Processes and systems required to document BM and • Informing SM about requirements and
System modifications, FV models, reasons for sales strategic options (e.g. on transition date)
communication management with
stakeholders, forecasting and sensitivity
• SPPI assessment at instrument level • Improvement /implementation of systems
analysis, training, engagement with OJK Contractual
• Required information not available • Clustering & use of efficient questionnaires
just to name a few. cash flows
• Business units to be included • Training of business units
Only 8% of respondents to our survey
were in a “very advanced stage” of
• High quality FV needed for (structured) loans
implementation, 80% of which are foreign Fair value • Implementation of FV models for loans
• FV needed for modified loans
banks whose parent companies typically measurement • Improvement of existing IT systems
• May result in P&L and Equity volatility
must already comply with IFRS 9 as of 1
January 2018. Although, as of the date of
• Identify data gaps and capacity of existing IT
this survey publication, 22 months remain
• Availability of data on transition systems
for implementation of PSAK 71, we Transitional impacts • Determining opening position impacts • Deploy simulation tools to identify and quantify
recommend that banks who have not • FV may be needed for loans currently at amortised cost impacts
already started an impact assessment • Develop, build and test FV models for loans
begin to do so as soon as possible.
Looking to IFRS 9 as an example, large
• Reconciliation between PSAK 55 measurement and new
banks globally began their assessments at • Mock up of disclosures
measurement categories under PSAK 71.
least 3 years before the standard’s • Regular contact with regulators and investors
Disclosures • Additional qualitative and quantitative information is required
• Potential for national disclosures and / or
effective date. to be disclosed.
guidelines
• Need to communicate clearly to investor base.
42
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