Regulation and Supervision
To strategise, develop and coordinate the company’s positions on important public and regulatory affairs issues, ING is actively involved in public policy and regulatory developments in its relevant constituencies. It does so with the objective of enhancing (implementation of) financial regulation and supervision that support the interests of ING’s stakeholders.
Regulatory and International Affairs (RIA), is a corporate staff department responsible for ING’s positioning within the national as well as international regulatory and policy community.
The department’s three main objectives are:
- Influencing regulatory developments for an outcome compatible with the interests of ING’s business, its stakeholders and the banking industry as a whole. For this purpose, it analyses relevant proposed regulation and developments in ING’s relevant constituencies, researches their potential effects on the company and its stakeholders, and supports ING’s businesses in formulating their standpoint and strategy.
- Coordinating ING’s engagement with its banking supervisors, notably the European Central Bank as its main supervisor.
- Maintaining the company’s dialogue on financial regulation and supervision with politicians, government authorities, industry associations, civil society organisations, think tanks and academics, and supporting the company’s efforts to enhance international business opportunities for its customers through joint public-private partnerships.
Approach to public advocacy
ING’s purpose is to empower people to stay a step ahead in life and in business. Therefore, the interests of our stakeholders, invariably serve as our guideline in determining our positions with regard to the regulatory and supervisory developments that shape our operating environment. However, the interests of these diverse groups do not always coincide and sometimes actually conflict with each other. To strike a right balance, we carefully weigh up the interests of all parties concerned. We do this to align our business processes and strategy as best we can with our stakeholders’ expectations, and because it is simply our duty to comply with our statutory obligations as well as our own values.
We continuously seek feedback from our stakeholders on relevant (regulatory) issues and we engage with them in a constructive dialogue to reflect on our positions.
To conduct this dialogue, we
- Regularly organise information and discussion sessions
- Participate in, or are a member of, various international bodies and industry associations
- Initiate roundtable sessions with policymakers and academics
- Maintain direct relationships with regulatory and government authorities and civil society organisations (including non-governmental organisations, labour unions and industry associations)
- Contribute to legislative consultations
- Actively communicate our positions and standpoints with our stakeholders via our own communication channels (e.g. our annual report, our www.ing.com website, which has a separate section dedicated to regulation and supervision) or, sometimes, external media.
ING adheres to openness and transparency about our objectives in the legislative processes and the positions we take with regard to developments in financial regulation and supervision. This means that we consider it our responsibility to inform our stakeholders about our activities in the regulatory and supervisory domain and to explain the arguments and considerations underlying our positions in the most comprehensible way. Therefore, we publish so-called Viewpoints on the most important regulatory developments affecting the financial sector in addition to the information already provided on our website and in our annual report.
The careful consideration we give to all interests involved may sometimes prevent us from publishing all details about our contacts with supervisors or other stakeholders, for instance if we believe that the information we share with supervisors or government agencies must be kept confidential for competitive reasons or as part of the supervisory relationship. For this reason, we do not publish information about all individual contacts or standpoints on financial supervisory and regulatory matters.
Registrations and memberships
ING staff is registered in the EU Transparency Register. ING therefore adheres to the code of conduct of the EU for organizations and self-employed individuals engaged in EU policy-making and policy implementation. Apart from the fact that ING is a signatory to the EU Transparency Register, ING public affairs professionals are on a personal title, members of the Society of European Affairs Professionals SEAP.
SEAP advocates self-regulation as the most effective way of supervising public affairs professionals. The SEAP code of conduct is based upon this principle. The code itself lists the various ethical rules which its signatories must abide by. SEAP’s aim is to have a code that is clear and concise, setting out the general principles that govern our profession.
Within The Netherlands, the ING public affairs professional that works in The Hague on a permanent basis is registered in the lobbying register of the House of Representatives (NB it is only possible to register one person per company).
In addition, ING’s representative in The Hague is a member of the Dutch Association for Public Affairs.
As a globally operating financial services provider, ING participates in and/or is a member of, a number of industry and business associations in the various countries in which it operates. Some of these have a clear focus on supporting the interests of the financial industry and/or strengthening its regulatory and supervisory framework, whereas others serve the interests of ING’s customers or society at large. Insofar these organisations engage in legislative processes or in the public and political debate around banking, they generally do so on behalf of all their member organisations, but not always based on their full consent. As a consequence, their views and standpoints do not necessarily reflect the individual positions taken by ING. An overview of the most relevant memberships is given below.
Banking industry associations
- American Bankers Association (ABA) (sub: BAFT)
- Argentine Banking Association (ABA)
- Association of Banks in Bulgaria (ABB)
- Association of Banks in Singapore (ABS)
- Association of German Banks (AGB) (Bankenverband)
- Association of Russian Banks (ARB)
- Australian Bankers' Association (ABA)
- Austrian Bankers’ Association (ABA) (Bankenverband)
- Bankers Association of the Rebublic of China (BAROC)
- Banking & Payments Federation Ireland (BPFI)
- Banks Association of Turkey (BAT)
- Belgian Financial Sector Federation (FeBelFin)
- Brazilian Federation of Banks (FEBRABAN)
- British Bankers' Association (BBA)
- Czech Banking Association (CBA)
- Dutch Banking Association (DBA) (Nederlandse Vereniging van Banken, NVB)
- European Banking Federation (EBF)
- French Banking Federation (FBF)
- Hong Kong Association of Banks (HKAB)
- Indonesian Banks Association (PERBANAS)
- Italian Bankers Association (IBA) (ABI)
- Japanese Bankers Association (JBA)
- Korea Federation of Banks (KFB)
- Luxembourg Bankers' Association (LBA) (ABBL)
- Polish Bank Association (PBA) (ZPB)
- Romanian Banking Association (RBA) (ARB)
- Slovak Banking Association (SBA)
- Spanish Banking Association (SBA)
- Swiss Bankers Association (SBA)
Theme-oriented memberships and think tanks focusing on financial regulation
- American Chamber of Commerce in the Netherlands (AmCham)
- Association for Financial Markets in Europe (AFME)
- Bankers Association for Finance and Trade (BAFT)
- Bruegel, European Think Tank in economics (Bruegel)
- Dutch Association of Covered Bond Issuers (DACB)
- Eurofi, European thinktank to financial regulation and supervision (EUROFI)
- European Capital Markets Institute by the Centre for European Policy Studies (CEPS - ECMI)
- European Mortgage Federation (EMF)
- European Parliamentary Financial Services forum (EPFS)
- Institute of International Finance (IIF)
Memberships supporting customer interests and market potential & developments
- Dutch Securitisation Association (DSA)
- Environment Research Funders’ Forum (ERFF)
- European Covered Bond Council (ECBC )
- European Financial Services Round Table (CEO's) (EFR)
- Federal Association for Information Technology, Telecommunications and New Media (Berlin) (Bitkom)
- International Capital Market Association (ICMA)
- International Swaps and Derivatives Association (ISDA)
- Loan Market Association (LMA)
- Netwerk Internationaal Ondernemen (NIO)
- Prime Collateralised Securities (PCS)
ING’s positions on various regulatory and policy developments
ING viewpoints on current regulatory issues can be found below
A European digital single market for retail financial services
Banking Union needs a European Deposit Guarantee Scheme
ING Viewpoint on EU Retail Financial Services
ING Viewpoint on macroprudential policy in the Banking Union
More information on ING’s stance on various regulatory and supervisory issues can be found in the ING Group Annual Report.