4. Macroeconomic environment

4.1. Economy and the banking sector in 2014

4.1.1.   Solid growth in a turbulent environment

As generally expected, 2014 brought about accelerated economic growth, which stepped up from 1.7% in 2013 to 3.3%. The growth rate was higher than projected in most forecasts early in the year. Inflation came as an unpleasant surprise in 2014: despite expectations, it was a year of an almost monotonous decline of inflation, which fell below zero for the first time ever in July and stood at -1% at the year’s end.

The steady fall of inflation, which postponed the prospect of inflation returning close to the NBP’s target, was combined with growing uncertainty about the market conditions in Poland and beyond. A series of adverse events (slow-down in the eurozone, economic crisis in Central and Eastern European countries, mainly Russia and Ukraine) put in question the potential dynamic growth of foreign demand for Polish goods and services. Coupled with a decline of many economic indicators, these factors prompted the Monetary Policy Council to resume monetary policy easing. After cutting the main interest rate by 50 basis points in October, the Monetary Policy Council remained dovish and signalled further cuts. In the opinion of the Bank, the decision will most likely be made in March 2015.

The first weeks of 2014 were not easy for the Polish currency: an outflow of capital from emerging markets, mainly affecting Turkey which wrestled with the external imbalance and political problems, precipitated a sellout of Polish assets as well, and the zloty fell to ca. 4.26 against the euro at the end of January. Subsequent months brought optimistic statistics of the real economy as well as steadily rising expectations concerning European Central Bank initiatives. These drivers gradually allowed the zloty to strengthen to 4.09 against the euro and 2.98 against the dollar in early June. In the latter half of the year, the zloty depreciated due to a combination of adverse factors, from weaker economic activity in Poland and resumed interest rate cuts, to escalation of the Ukrainian-Russian crisis and a collapse of the financial systems of both countries, to a strong appreciation of the US dollar. At the end of the year, on a shallow market in the holiday season, the zloty fell to 4.40 against the euro and 3.60 against the dollar. The Swiss National Bank’s decision to drop the cap on the CHF exchange rate on 15 January 2015 added more volatility to the Polish FX market. As a result, the exchange rate of the Swiss franc against PLN rose from ca. 3.6 to more than 4. For more information, please see section 4.4., chapter “Impact of the appreciation of the Swiss franc on the position of borrowers, the banking sector, and mBank”.

Growth and inflation

The Polish economy started the year in full swing as GDP growth was no less than 3.4% in Q1, which came as a nice surprise to economists, and not the only one in 2014. Notwithstanding some risks and resulting concerns about the Polish economy, as well as unpleasant surprises concerning frequently published statistics, economic growth remained above 3% quarter after quarter (3.5% in Q2, most likely ca. 3% in Q4). The very good performance of the Polish economy was driven by several factors:

  • Further acceleration of consumption, supported by higher real increase of household incomes (including both salaries and other income, such as social security benefits) and a steadily improving consumer sentiment. While retail sales grew moderately in 2014, the growth of consumption was largely driven by services.
  • Strong growth of private investments, which accounted for most of the impressive 10% increase of fixed capital formation in 2014. In the opinion of the Bank, the strength of private investments derives mainly from deferred investment demand (investment projects were postponed during the economic downturn) and strong improvement of corporate sentiment at the turn of the year, as well as the need to expand the production capacity whose utilisation is relatively high.
  • Very vibrant Polish labour market: the unemployment rate continued to fall in 2014 and was only 11.4% in December (compared to 13.4% at the end of 2013). In addition, the number of persons employed grew dynamically in 2014, by 0.7% to 2% depending on the measures used and the source of data.
  • Drastic easing of the monetary policy in the preceding year, which had immediate effects reducing the debt burden of households and impacted the structure of households’ assets (cash was moved from savings accounts to investment funds or used for consumption) in support of consumer spending.

Contrary to general projections and NBP’s expectations, inflation did not begin to grow in 2014. Quite the opposite: inflation fell below the zero mark in 2014, hitting one low after the next month after month. Within the year, inflation fell from 0.5% reported in January to -1% in December. This was driven by many factors, from the sharp decrease of food prices thanks to very good harvests and the later trade wars with Russia, to the “oil shock” in late 2014 (as oil prices fell by more than 50%), whose effect is not yet fully reflected in CPI data. These stimuli were coupled with low core inflation, attributable to deflation in the external environment of the Polish economy (negative index of the prices of imported goods for the most part of the year), as well as the still incomplete recovery of domestic demand. Under those conditions, the average annual consumer price index was almost precisely zero in 2014.

Interest rates

In the first half of 2014, the monetary policy remained dovish in the absence of inflation pressures in the economy. According to the consensus shared by the Monetary Policy Council with analysts and market participants, the interest rates were to remain record-low for several months. However, a change of the monetary policy took some time. Expectations of interest rate cuts emerged in May and June as domestic macroeconomic statistics declined, the trade wars with Russia escalated, and the European Central Bank initiated a new phase of quantitative easing. Data published in the summer months only reinforced the trend. Eventually, at its September meeting, the Monetary Policy Council signalled a new cycle of interest rate cuts. The decision came in October when the reference rate was cut by 50 bps (the Lombard rate by as much as 100 bps). The decisions of the Monetary Policy Council in the months that followed were affected by internal differences of opinion on what would be an adequate response to the combination of solid growth and declining inflation prospects. Although proposed by the dovish members of the Monetary Policy Council, no cuts were decided at the November and December meetings.

4.1.2.   Banking sector

2014 turned out to be moderately better than 2013 for the financial results of the Polish banking sector. The net profit of the sector stood at PLN 16.2 billion in 2014, compared to PLN 15.2 billion reported in 2013. The increase of the profits of the banking sector was driven mainly by improved net interest income, which grew by PLN 2.5 billion year on year, however, mainly owing to a decrease of interest expenses by PLN 5.5 billion. In the environment of extremely low interest rates, interest income shrank by PLN 3 billion.

2014 brought further improvement of the quality of banks’ loan portfolios. The percentage share of non-performing loans decreased from 8.5% to 8.1% in 2014 (year-end figures), including a decrease from 11.5% to 10.2% for enterprises and a decrease from 7.0% to 6.5% for households.

2014 was another consecutive year when the assets of the banking sector continued to grow. The balance sheet total of the Polish banking sector stood at PLN 1.53 trillion at the year’s end (an increase of 9% year on year). Some two-thirds of the growth in assets is attributed to expansion of lending. As for equity and liabilities, in addition to growth of deposits at a pace similar to new lending, equity continued to grow by ca. PLN 13.5 billion year on year.

The offer of the Polish banking sector was characterised by the following trends:

  • The criteria and terms of bank loans were gradually relaxed. This concerned nearly all segments of the market but the credit policy was mainly relaxed for small and medium-sized enterprises, as well as consumer loans for households. The terms and criteria of housing loans became stricter, mainly due to the minimum down-payment requirement imposed in early 2014.
  • Interest rates on retail and corporate loans and deposits decreased following the NBP’s October rate cut.
  • Mobile banking and non-cash payments continued to grow.
  • Margins on loans and deposits were reduced. With the exception of mortgage loans, credit margins were falling steadily in 2014 as a proxy of lower credit risk and improved financial standing of borrowers. Due to falling interest rates and the aspiration to compete for deposits (mainly in the retail segment), banks were often forced to maintain interest rates on deposits above the interbank rates WIBOR and WIBID.

 

In 2014, further symptoms of recovery emerged on the credit market even if they mainly concerned the corporate segment: the growth rate of loans for enterprises increased from 1.6% at the end of 2013 to ca. 10% a year later. This was largely driven by the fact that the recovery on the corporate lending market, initially boosted only by investment loans, also involved the other segments in 2014. In this context, it should be noted that the de minimis guarantee programme continued: ca. PLN 10 billion of guarantees were extended in 2014 (compared to PLN 7 billion in 2013).

On the other hand, the retail segment (households) did not report a break-through in 2014 due to a very modest increase of mortgage loan volumes and a relatively low growth rate of consumer credit. The former segment reported a growth rate under 5% in 2014 while the modest volume of new loans (under PLN 10 billion per quarter) was offset by growing repayments of the stock of loans built in the previous years. This was the case despite the record-low interest rates on mortgage loans. In terms of volumes, the key development was the decision of the Swiss National Bank to drop the cap on the exchange rate of the Swiss franc, which caused the value of CHF denominated loans to rise from PLN 136.2 billion at the end of December to ca. PLN 154 billion at the end of January 2015 according to the Bank’s estimates. However, the decision is most likely to have a minor impact on the amount of instalments paid by borrowers because the FX effect will be largely offset by the decrease of LIBOR CHF (-0.88% on three-month loans).

On the other hand, the volume growth of consumer loans was limited in 2014. The October cut of the Lombard rate by 100 bps set a new maximum interest rate on consumer loans, which was 4 percentage points lower, but it went practically unnoticed by the market and probably failed to boost demand for loans.

2014 was also a time of deposit base growth. In particular, despite the low interest rates, the inflow of new cash to household deposits not only did not slow down but actually accelerated throughout the year. Household deposits stood at more than PLN 591 billion at the end of 2014, representing an increase of PLN 49 billion year on year. The year-on-year growth rate of household deposits accelerated from ca. 4% to more than 9%. Corporate deposits also grew dynamically in 2014 and stood at PLN 226 billion at the year’s end, representing an increase of PLN 19 billion year on year. Their grow rate ranged within the year from 4.5% to 10.5% year on year, reflecting the turbulent story of Polish corporate finance (effects of the Russian crisis, sharp decrease of costs thanks to falling commodity prices).

4.2. Capital markets

2014 on the Warsaw Stock Exchange did not favour bullish investors: the broad market index WIG closed the year at a practically unchanged level while WIG20 stocks lost ca. 4% on average. The weakness of the Polish stock market was driven by many factors: the pension system reform and uncertainty about the future inflows of pension fund cash to the stock exchange; the Ukrainian-Russian conflict which affected companies present in Eastern markets and prompted foreign investors to reduce exposure to Russia and its neighbours; weakness of European stock exchanges in the wake of yet another wave of economic slow-down in the eurozone; debt investment funds being a more attractive investment option for individual investors; as well as factors idiosyncratic to the Warsaw Stock Exchange, including interest rate cuts which affected the revenue of banks and falling commodity prices which affected commodity stocks.

Under these conditions, the number of initial public offerings on the WSE was not significantly higher than in the previous years. There were 28 new listings in 2014 (23 IPOs in 2013, 19 IPOs in 2014), including 10 companies transferring from NewConnect, the market for small and medium-sized enterprises with a strong growth potential.

4.3. Situation on the Treasury bond market

As expected by the Bank, 2014 proved to be a good year for the Treasury bond market while the final returns on Treasury bond portfolios considerably exceeded the most optimistic expectations. In practice, from the turn of January to February when the sellout of assets from emerging markets (including Poland) peaked, Treasury bond yields were on a decrease while their prices were on an increase. The factors which supported the Polish bond market in 2014 included: low inflation in Poland and beyond; concerns about economic growth of well-developed countries, initially fuelled with the surprising fall of GDP in Q1 and later by the eurozone flirting with yet another recession (which actually did affect some of the eurozone countries); expectations of the European Central Bank’s asset purchase programme which would result in an inflow of cash to the Polish bond market; expectations of further interest rate cuts followed by actual decisions to cut the rates; falling bond yields on the base markets, especially German bonds whose yields dropped by ca. 1.5 percentage points within the year.

The bond market was also supported by a steady improvement of fiscal indicators: according to estimates, the government budget was ca. PLN 20 billion (40%) lower that the target at the end of 2014 while the government sector deficit probably dropped below 3% of GDP. This implies an earlier than expected completion of the European Commission’s excessive deficit procedure and, in the mid-term, an upgrade of Poland’s ratings if public debt follows a downtrend (which is probable). The lower credit risk is combined with lower supply of Treasuries due to the government’s smaller borrowing needs in 2014.

In the opinion of the Bank, it is too early to announce that the downtrend of Polish T-bonds is over. Bond yields have hit new records in 2015 and bonds should keep strong in the coming months (at least in Q1). The factors that make Polish Treasury bonds attractive include: further fall of inflation (the Bank expects the lowest inflation readings at -1.5% in February and March); the low yield environment in Europe supported by the ECB as well as global drivers (inflation in well-developed countries will also bottom out in Q1).

4.4. Expected trends in the economy in 2015 and their impact on the banking sector

In the opinion of mBank’s Chief Economist, economic growth should accelerate in 2015: the growth rate may cross the mark of 4% in Q4 while the average annual growth will be 3.5%. Domestic demand will remain the key growth driver in 2015 although consumption is likely to become the key force in this category while investments will grow less dynamically. This is due to the continued effect of factors bolstering consumption (good household sentiment, very high increase of real disposable income) combined with the phasing out of drivers which boosted investments in 2014 (“catching up” with postponed investment demand of enterprises).

Inflation will hit new lows in 2015 (in the opinion of the Chief Economist, annual inflation may fall to -1.5% in February and March) and then turn around, most likely at the turn of Q1 to Q2. However, deflation (understood as negative annual inflation) will persist in the Polish economy at least until the summer. This means that the average annual consumer price index will be negative for the first time in history. This will give the Monetary Policy Council the comfort to continue with interest rate cuts: the cycle is likely to being in March and to bring the NBP’s main interest rate to 1.5% or less (i.e. 50 bps below the current rate).

The continuation of economic recovery will impact the monetary aggregates. In the opinion of mBank’s Chief Economist, the following trends will develop in 2015:

  • The growth of corporate deposits will continue in 2015 as a proxy to improving financial results of companies, which is even more likely considering that it will take place in the context of accelerating economic growth. According to the Bank’s current projections, the growth rate of corporate deposits should reach 10% on average in 2015, compared to 7.8% in 2014.
  • In the opinion of the Bank, corporate loans will continue to grow at a rate exceeding the average growth rate of loans in the economy. This is driven by the still considerable investment needs of enterprises, as well as attractive terms of new lending (low interest rates, relaxed criteria and terms of bank loans). Corporate loan volumes are expected to increase by 6.6% on average in 2015 (compared to 4.7% on average in 2014) while investment loans should make the biggest contribution, similar to 2014.
  • According to mBank’s projections, the annual growth rate of retail deposits will stabilise around 10%. Growth of household deposits will be supported mainly by continued improvement on the labour market and an increase of nominal household incomes (as a result of rising salaries and low inflation). The availability of certain, stable, high real returns on savings will remain an important decision-making factor to choose deposits as the main form of household savings.
  • Finally, the volumes of retail loans should significantly increase in 2015. For mortgage loans, the adverse impact of Recommendation S (minimum down-payment requirement) should be more than offset by the impact of improving consumer sentiment. The volumes of consumer loans are also expected to continue growing although the base effect in the latter half of the year will mitigate the growth rate of consumer loans.

The Polish banking sector will also be faced with the CHF appreciation after the SNB decision on January 15, 2015. For more information, please see section “Impact of the appreciation of the Swiss franc on the position of borrowers, the banking sector, and mBank” in the following chapter.

In addition to these macroeconomic trends, the banking sector (including mBank) will operate under the following conditions in 2015:

  • Regardless of the scale of further monetary policy easing, the banking sector will face an environment of historically low interest rates. This will exert pressures on financial results due to both lower interest income and higher costs of funding (the need to maintain high interest rates on deposits, especially household deposits).
  • Another challenge for the banking sector is the increase of the contribution to the Bank Guarantee Fund; the aggregate costs are estimated at PLN 1.1 billion in the first year of the new rules. The effect of the change will be augmented by the concentration of payments in time (one-off payment in Q1) as well as the risk of further increase of the contribution in view of the continued restructuring of the co-operative savings and loans associations SKOK.
  • Additional pressures on the financial results of the banking sector will be exerted by reduced income from payment card services. According to the Bank’s estimates, the reduction of the interchange fee in 2014 (from 1.3% to 0.5%) entails a decrease of income of the banking sector by ca. PLN 700 million per year. The effect of a further reduction (from 0.5% to 0.3%) is estimated at ca. PLN 200 million per year. According to the Bank’s expectations, the direct effect will be offset in the long term by growing volumes of card transactions.
  • A further increase of the down-payment requirement for mortgage loans (from 5% to 10%) will impact the banking sector mainly by way of limited demand for household loans, as was the case in 2014. On the other hand, it is expected that the down-payment requirement will bolster the propensity of households to save and, consequently, support the inflow of cash to deposits, providing banks with stable funding for loans.
  • Other changes in the regulatory environment, i.e. restrictions on sales of insurance products by banks as well as changes in consumer lending (additional personal bankruptcy options and more restrictive “anti-usury” rules), will play a smaller role. The former may slightly boost the cost of funding for banks; in the opinion of the Bank, the latter will affect banks much less than it will other credit institutions.

Changes in the market environment, regulations and recommendations issued by the Polish Financial Supervision Authority may be a challenge for the banking sector in Poland in 2015 and may have an adverse effect on its financial results are presented in the table below:

 

 
Factor

Short overview of a factor

Influence on the main areas of banks

YES –  the factor has impact on a given area

NO – the factor has no impact on a given area, or has a limited impact on a given area

The lowest interest rates in history

In October the Monetary Policy Council (MPC) reduced the reference rate by 50 bps (to 2.0%), and lowered the lombard rate by as much as 100 bps (to 3.0%). The decision resulted from the inflation being continuously below the NBP target (deflation in H2 2014) and slowdown in economic growth. During its December meeting the Monetary Policy Council upheld its October decision, however, in 2015 new cuts are expected.en area

 

Revenues

 

Costs

 

LLP

red-triang  YES

green-triang  NO

green-triang  NO

Lower limit of interest on loans and advances

Since the MPC lowered the lombard rate by 100 bps to 3.0%, the maximum nominal interest on the loans and advances offered by banks cannot exceed 12%. It results from the so-called Anti-Usury Law applicable from 2006 under which the interest charged per annum on loans and advances cannot exceed the 4-fold lombard rate of the National Bank of Poland, that is 12% at present.

Revenues

 

Costs

 

LLP

red-triang  YES

green-triang  NO

green-triang  NO

Limiting income from servicing payment cards

As of July 1, 2014, the amended Act on Payment Services dated August 30, 2013, has entered into force. The aim of this amendment was to regulate the basic operation principles of the market of domestic payment transactions made with the use of payment cards. Under the amendment the maximum interchange rate cannot be more than 0.5% of the commission charged for payment card transaction. This represents a decrease from 1.2%-1.3% of the previously applicable commissions. At the beginning of 2015 the maximum interchange rate will be reduced to 0.2% and 0.3% of transaction value of debit and credit cards, respectively.

 

 

Revenues

 

Costs

 

LLP

red-triang  YES

green-triang  NO

green-triang  NO

Higher fee for the Bank Guarantee Fund

In 2015 the annual fee will grow from 0.1% to 0.189% of the 12.5-fold of total capital requirements. In addition, the prudential levy introduced in November 2013 grew from 0.037% to 0.05% of the 12.5-fold of total capital requirements calculated for each of the banks.

 

 

Revenues

 

Costs

 

LLP

green-triang  NO

red-triang  YES

green-triang  NO

Obligatory higher own contribution to mortgage loans

From 2014 the PFSA tightened the rules for granting mortgage loans in the new Recommendation S. In line with the guidelines issued by the PFSA, from January 2014 the own contribution required when purchasing a real property was at least 5%, and from the beginning of 2015 it has been increased to 10% of the value of the real property. The amount of the own contribution will rise each year by 5%, to reach 20% in 2017. Moreover, the amount of own contribution will depend on the additional loan collateral, and the loan cannot be taken out for a period longer than 35 years.

 

 

Revenues

 

Costs

 

LLP

red-triang  YES

green-triang  NO

red-triang  YES

Introducing additional curbs on insurance product distribution by banks

Pursuant to Recommendation U concerning good practices relating to bancassurance of June 2014, from April 1, 2015, banks will be obliged to ensure that the client has a free choice of insurance company. The bank cannot simultaneously act in the role of the insurer and insurance intermediary, and the consideration of the bank for offering insurance products is to be set in a relevant proportion to the amount of the costs incurred by the bank.

 

 

Revenue

 

Costs

 

LLP

red-triang  YES

red-triang  YES

green-triang  NO

Consumer bankruptcy

An amendment to the Bankruptcy and Reorganisation Law, the Act on the National Court Register and the Act on Court Fees in Civil Cases, entered into force on January 1, 2015. The major change resulting from the new regulations is simplification of procedures concerning consumer bankruptcy. The consumer has now easier access to the procedure of declaring bankruptcy in the case of excessive debt. It will be a new chance for the persons who ran into financial troubles, including the banks’ clients who took out loans.

 

 

Revenue

 

Costs

 

LLP

red-triang  YES

green-triang  NO

red-triang  YES

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Impact of the appreciation of the Swiss franc on the position of borrowers, the banking sector, and mBank

On January 15, 2015, the Swiss National Bank (SNB) after nearly three years of keeping a capped exchange rate of the Swiss franc to the euro decided to drop the cap. As a result, the Swiss franc appreciated strongly against the euro and the zloty. At the same time, the SNB cut the interest rate to -0.75%, resulting in a decrease of LIBOR CHF. The sharp appreciation of the Swiss franc affects the households budgets of some 550 thousand families which hold housing loans denominated in the Swiss franc, and impacts the financial position of banks.

The Polish Financial Stability Committee (KSF) at its meeting on January 20, 2015, with the participation of representatives of some commercial banks holding significant portfolios of FX mortgage loans confirmed that the banking sector is stable and resilient to external shocks, including major volatility of the FX rate, despite the relatively high share of the CHF housing loan portfolio. The value of the Swiss franc loan portfolio has been decreasing steadily due to repayments. The impact of the appreciation of the Swiss franc on principal and interest payments should be seen in the context of the decrease of LIBOR since the original loan disbursement as well as growing average household incomes.

The following decisions were made:

  • Banks should include the negative LIBOR in interest rates on loans;
  • Banks should not require additional collateral for loans where the borrower’s debt increases due to an increase of the FX rate of the Swiss franc against the zloty. The Polish Financial Supervision Authority announced that it will not require banks to impose additional collateral;
  • Banks should reduce their FX spreads.

The Financial Stability Committee recommended that banks apply restructuring solutions which meet the individual needs and capacity of each client and match them to the prevailing market conditions.

The position of the Polish Bank Association (ZBP) is consistent with the recommendations of the Financial Stability Committee. The Polish Bank Association has proposed that banks should include the negative LIBOR CHF in calculating interest rates on loans; reduce the FX spread for a period of six months; and extend the timeline or temporarily suspend the payment of Swiss franc loans at the request of clients.

The Ministry of the Economy published its position on January 28. The proposed solutions include recommendations for banks, as well as recommended legal and regulatory amendments. The recommendations for banks are as follows:

  • Interested borrowers should have the option of converting the currency of the loan from CHF to PLN with no extra fee at a rate equal to the mid-rate published by the NBP on the conversion date;
  • Credit holidays for a period up to three years should be introduced into active credit agreements (also for PLN loans) and instalments should be capped at the 2014 YE level;
  • No additional collateral should be required for loans due to the FX rate volatility.

The recommended legal and regulatory amendments include:

  • The FX risk of borrowers should be capped;
  • Additional collateral required within the term of an agreement in the event of FX rate volatility should be subject to restrictions;
  • Cancellation of a loan in part should not be considered the borrower’s taxable income;
  • Credit cancellation costs should be considered eligible tax-deductible expenses of banks;
  • Claims under mortgage loans (granted for up to 100% of property value) should be capped at property value for new credit agreements;
  • Solutions which support flexible reaction to credit repayment problems should be introduced and promoted (for PLN and foreign currency loans);
  • Solutions applicable where the borrower’s personal situation is extremely difficult should be introduced (for PLN and foreign currency loans).

In recognition of the provisions of existing Swiss franc mortgage loan agreements where the interest rate is based on a margin and LIBOR, mBank follows the rule whereby the negative LIBOR CHF reduces the credit margin. In addition, the Bank reduced the FX spread and provide clients in a difficult position with a package of solutions including among others extension of the term of the loan in order to keep the amount of instalments close to that paid prior the decision of the Swiss National Bank. The new solutions include also the option of transferring CHF mortgage to a new property.

The elevated exchange rate of CHF v. PLN, if persists, will have a moderate adverse impact on the financial performance of mBank in 2015. In particular, applying an exchange rate of 4.20 to calculate mBank Group’s capital ratios as of December 31, 2014, would reduce the reported Common Equity Tier 1 Ratio and Total Capital Ratio by roughly 40 basis points.

While a large majority of mBank’s CHF mortgage borrowers should see their monthly instalment reduce compared to December 2014, benefiting from negative Libor rate, certain increase in loan loss provisions, reflecting higher loan values relative to underlying collaterals may be registered. Finally, reduced FX spreads for mBank customers, a slightly delayed adjustment of the bank’s funding cost to the negative LIBOR regime compared to the adjustment speed for customer loans and potentially increased competition for domestic deposits (as some Polish banks other than mBank might seek additional liquidity to fund their CHF loan exposures through SWAP instruments) will have a moderately negative impact on mBank’s revenues in the medium term horizon.

The chart below presents the distribution of mBank’s CHF borrowers by percentage change of their instalment compared to December 2014 – as of January 29, 2015.

4.5. Housing market

The situation on the property market in Poland in 2014 was driven, similar to 2013, by the slow but steady economic growth as well as the relatively low interest rates maintained by the Monetary Policy Council. Consequently, banks relaxed their credit policies, as mirrored by the mortgage loan offer becoming more attractive.

The Polish mortgage lending market saw no revolution in 2014 despite major regulatory changes. Although Recommendation S of the Polish Financial Supervision Authority changed the rules applicable to lending in Poland, no major change on the property market or, consequently, the mortgage lending market has been observed since the Recommendation was issued. While the minimum mandatory downpayment level was set at 5% for any mortgage loan, the number of creditworthy applicants has increased (largely due to the extension of the maximum tenor of loans for the calculation of creditworthiness from 25 to 30 years).

In addition, restrictions have been imposed on fx lending. As of July 1, 2014, only those individuals who earn an income in a given currency may apply for fx loans.

The government programme Mieszkanie dla Młodych (Apartments for the Young) was expected to bring major changes to the housing market. Unfortunately, it did not revolutionise the mortgage lending market as planned because it only covered properties on the primary market which were not always attractive to people under 35 years of age among others due to the fact that such properties were not available in smaller towns.

In 2014, the Monetary Policy Council stabilised the interest rates at low levels. The reference rate was 2% while WIBOR 3M was less than 2% in November 2014 and reached 2.1% in December. As a result, new loans (including mortgage loans) offered very low costs to borrowers; due to low interest rates and a more attractive credit offer, their creditworthiness was stronger.

A final change came in December 2014 with the introduction of reverse mortgage. It is a loan for persons who have a legal title to property; the loan is secured with a mortgage on the property. However, no bank in Poland has launched reverse mortgage products to date.

Situation on the private property market

On the private property market in 2014, demand for apartments grew while the price per square meter first increased moderately and later stabilised, both on the primary and the secondary market. The government programme Mieszkanie dla Młodych (Apartments for the Young) made it easier to meet demand for apartments despite the introduction of Recommendation S, which could pose potential barriers to mortgage lending. Demand for apartments of higher standard at prime locations clearly grew. The average size of the most popular apartments ranged from 40m² to 50m².

In 2015, the provisions of Recommendation S will continue to be implemented, including among others an increase of the required downpayment by another 5% (to 10% of property value). The Recommendation is designed to unbundle the business of banks and insurers. The government programme Mieszkanie dla Młodych (Apartments for the Young) is expected to become more attractive as subsidies to the downpayment grow to 20% of the apartment value for families with two children and to 25% for bigger families while the size of properties eligible for the programme grows from 50m² to 65m². The Monetary Policy Council is also planning further interest rate cuts in order to boost consumption and investments.

The figures below present the expected growth rate of mortgage loans in Poland as well as in the Czech and Slovak markets where mBank is present.

 

Source: mBank’s own study based on PSFA figures and the Deloitte report CE Banking Outlook. North-South Divide on the Road to Recovery (September 2014)

Situation on the commercial property market

In 2014, Polish demand for retail and office properties grew as local consumption was on an increase and Polish companies expanded. Demand for new commercial space, especially retail space, was very strong. Investors were mainly interested in prime properties. The biggest share in the commercial property market was that of office properties followed by retail space and industrial properties. The number of transactions in these segments increased by ca. 10% year on year in 2014. Supply of office space was bigger than demand in 2014 for the first time since 2000. In particular, the number of new investment projects in the segment was high. This augmented the already harsh competition, also price-wise, and encouraged capital investments in such properties but proved insufficient for demand to match supply. At the end of 2014, the total stock of office space in Poland was 7,5 million m², while vacant space in Warsaw and in the regional markets (Kraków, Wrocław, Tricity, Łódź, Poznań, Katowice) was 776,800 m², at 15.5% of the total stock in Warsaw. The vacancy rate in Warsaw is expected to reach 20% in 2015, suggesting a negative trend in the office property segment. In the retail property segment, demand for space in shopping malls continues to grow. Many retail trade formats, previously located outside shopping malls, are moving to the malls which offer easy and prompt access to customers. New investments are still planned in large commercial properties which attract both potential tenants and their clients, even if the total stock in the segment is no less than 11,5 million m². New supply in 2014 was 460 thou. m², another 850 thou. m² is currently under construction. Industrial properties in 2014 enjoyed a boom akin to that witnessed six years ago. Demand for industrial properties was some 50% bigger than a year earlier while supply increased by ca. 30% year on year, suggesting record-high performance of this market segment. Importantly, while the biggest volume of transactions in commercial properties was still reported in the biggest Polish cities (Warsaw, Kraków, Wrocław, Poznań and Gdańsk), smaller cities (population of 100-400 thousand) were increasingly attractive thanks to lower costs of land and construction. This is good news from the perspective of demographics as it could revert the current trend of migration from rural areas and small towns to the biggest cities. In 2015 and beyond, the trends on the commercial properties market are likely to continue. With expected further interest rate cuts, investors will pay relatively little to buy retail, office and industrial properties. Commercial property market data are sourced from the Knight Frank report Commercial Property Market in Poland, January 2015.

4.6. Changes in recommendations of the Polish Financial Supervision Authority (KNF) and legal acts concerning banks

 
A legal act / Recommendation

Date of entry into force
and a summary of new challenges 

Influence on the main areas of the Bank

YES –  the regulation has an impact on a given area

NO – the regulation has no impact on a given area, or has a limited impact on a given area

Basel III (the Regulatory package CRD IV/CRR)

2014

January 1, 2014

Introduces new requirements in the scope of capital, liquidity, corporate governance and remuneration policy. The process of adjusting domestic regulations to CRD IV/CRR package is underway.

 

Capital base

 

IT and HR Resources

 

Financial result
(excluding IT/HR costs)

 

Client and offer

red-triang  YES

red-triang  YES

red-triang  YES

green-triang  NO

Foreign Account Compliance Act (FATCA) & Competent Authority Agreement (CAA)

July 1, 2014

FATCA requires identification and monitoring of the status of banks’ clients and reporting on assets and investments of US tax residents.
Failure to comply with FATCA results in imposing a 30% withholding tax on all financial transfers made from the USA to non-US financial institutions.

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

red-triang  YES

green-triang  NO

red-triang  YES

Recommendation D

December 31, 2014

The aim of the amended recommendation is to improve the quality of management in the areas of IT and ICT security at banks, in connection with improvement of the supervision in these areas.  

 

 

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

red-triang  YES

green-triang  NO

green-triang  NO

European Market Infrastructure Regulation (EMIR)

2013-2015

It refers to operation of capital markets, introducing new requirements mitigating risk.  The regulation imposes an obligation of clearing transactions via central counterparties and reporting transactions to trade repositories, which results in an increase in costs of concluding transactions in financial and derivative instruments.

 

 

Capital base

 

IT and HR Resources

 

Financial result
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

red-triang  YES

red-triang  YES

green-triang  NO

Recommendation S

July 1, 2014

Changes including limitations in granting loans in foreign currency and in the maximum lending period. Limitations also concern an annual reduction of limits on the debt to income ratio and a minimal own contribution.

 

 

Capital base

 

IT and HR Resources

 

Financial result
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

green-triang  NO

red-triang  YES

red-triang  YES

Announcement of the Polish Financial Supervision Authority regarding Screen Scraping

July 14, 2014

The ban imposed by the PFSA (KNF) refers to the use of screen scraping, i.e. intra-bank transfer of clients’ data bases.  Information about finances of clients from other banks was used to customize the banking offer for clients’ needs and simplified the lending procedure; however, in the opinion of the PFSA, this solution increased a threat to the security of information in the Internet banking.

 

 

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

green-triang  NO

green-triang  NO

red-triang  YES

Payment Services Act

July 1, 2014

January 1, 2015

The amendment to the Payment Services Act imposed a maximum interchange fee - reduction from 1.2-1.3% to 0.5% starting from July 1, 2014 and a further drop to 0.2% for debit cards and 0.3 for credit cards from February 1, 2015.

 

 

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

red-triang  YES

red-triang  YES

red-triang  YES

BRRD (Bank Recovery and Resolution Directive)2015

January 1, 2015

The directive obliges banks to prepare remedy plans, and a resolution authority appointed for this purpose will draw up resolution plans. Furthermore, banks are obliged to maintain the right structure of obligations to guarantee proper level of instruments, which, in the case of a resolution, may be written down or converted into capital shares. BRRD implementation also entails creation of a resolution fund, which is to gather funds totalling 1% of deposits insured in BGF. 

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

red-triang  YES

green-triang  NO

red-triang  YES

green-triang  NO

Recommendation U

March 31, 2015

Introduction of a reporting requirement whereby the bank clearly specifies its role in the offering of insurance services. In addition, under the recommendation, the selection of an insurer is at the client’s discretion. totalling 1% of deposits insured in BGF.

 

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

green-triang  NO

red-triang  YES

red-triang  YES

Recommendation P

June 30, 2015

The amended Recommendation P aims at updating the standards of liquidity risk management after the financial crisis experiences. It provides for defining the acceptable liquidity risk, liquidity measurement and management. red in BGF.

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

red-triang  YES

red-triang  YES

green-triang  NO

Act on Macro-prudential Supervision 

2015

The Act aims at strengthening the financial system stability and reducing the probability of financial crisis. For this purpose, it appoints a Systemic Risk Council with powers to issue warnings and recommendations to banks.  

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

red-triang  YES

green-triang  NO

green-triang  NO

green-triang  NO

Act on the Bank Guarantee Fund

2015

The amended Act on the Bank Guarantee Fund introduces a prudential levy for stabilisation fund (maximum rate is 0.3% of the total risk-weighted exposure).  The prudential levy for 2014 totalled 0.037%, whereas for 2015 - 0.05% of the 12.5-fold of total capital requirements calculated for each of the banks.  

Capital base

 

IT and HR Resources

 

Financial result 
(excluding IT/HR costs)

 

Client and offer

green-triang  NO

green-triang  NO

red-triang  YES

green-triang  NO

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