This has as the consequence that banks are required to provide insight into their customer deposits at short notice, to ensure timely payment of the covered amount. To this effect, a new payout system has been devised by DNB, which requires that banks compile and deliver a Single Customer View (SCV) (in Dutch: Individueel Klantbeeld, IKB) in a uniform manner.
Please find below an overview of current regulations and publications.
Purpose of the Single Customer View
The SCV is an overview of all depositors’ deposits supplemented with relevant DGS data, structured on the basis of the data model prescribed by DNB. The bank itself will compile the SCV and supply it to DNB. On the basis of the SCV, DNB will determine the amount to be paid out to each depositor. DNB has set out the requirements for the SCV in the Single Customer View Policy Rule (The publication in the Staatscourant is in Dutch only. However, the policy rule has been translated in the consolidated document below). The Policy Rule prescribes how a bank has to guarantee that the customer administration, procedures and control measures are implemented in such a fashion that it enables a bank to compile the SCV timely, accurately and correctly. Banks are obliged to facilitate this in their systems and processes. Additional to the yearly scheduled delivery of the SCV file, banks are required to have an audit performed on annual basis. You will find further guidance on these audits in the enclosed documents.
First round of amendments to the DGS legislation (February 2019)
In the beginning of February 2019, DNB published the first amendments to the DGS legislation in the Government Gazette (Staatscourant).
The major changes in the Single Customer View Policy Rule are the introduction of a marking for deposits acquired on the basis of a European passport for cross-border services, and the introduction of four possible options to provide a more precise estimate of the covered amount of escrow accounts for the periodical reports.
Other changes are partly the result of input from the banking sector during the SCV transition. These changes were publicly consulted in the end of 2018. You will find a further explanation and feedback on the responses on the consultation in document ‘First round of amendments DGS Policy Rules – Final adoption – February 2019’.
DGS Policy Rules (July 2017)
The Single Customer View Policy Rule was published in the Government Gazette in July 2017. DNB has drawn up an interactively consolidated document with all DGS regulations set by DNB concerning the SCV (Policy Rules for the DGS – July 2017). DNB publicly consulted the regulations in March-April 2017.
The specification for data delivery is set out in a Data Delivery Agreement (DDA), in Dutch ‘Gegevensleveringsovereenkomst’ (GLO) and a Formal Logical Data Model. The DDA further elaborates on the requirements of the DGS legislation and sets out the technical specifications for the exchange of data. The DDA is published in the English language. You can find the DDA and related documents at the page Specification of the data delivery.
The DGS Data delivery manual explains the DGS regulations in more detail, offering practical support to banks with the implementation of the SCV.
A bank instructs the external auditor at least on an annual basis to form an opinion on whether it can be stated with a reasonable degree of certainty that the bank complies with the provisions of the IKB policy rule. The instruction is based on ISAE 3402 (see article 12 of the IKB policy rule).
As part of the bank's 'three lines of defense', the internal audit department too must check whether the requirements of the IKB policy rule are met. The report of the internal audit department must be available within a reasonable period of time in order to play a role in coordinating activities with the external auditor
(see article 11 of the IKB policy rule).
On 30 September 2019, DNB evaluated the assessment by the external auditor on the basis of DGS regulations with a delegation of banks and audit firms. As a result, a letter was sent to all banks on 18 November 2019 expanding on our letter of 3 September 2019.
A new version of the control framework has been published, with control objectives and internal control measures.
In July 2017, DNB published the Single Customer View Policy Rule (IKB). With the implementation of the IKB it becomes possible to reimburse covered deposits to customers within seven working days, in case of a DGS payout situation. In the context of DNB supervising compliance with the requirements of the policy rule, the Assessment Framework for supervision compliance with requirements Single Customer View Policy Rule has been established.
Included in the assessment framework are:
- a number of indicators that clarify the extent to which banks are compliant
- the role of the assessment of the IKB system by the internal audit department and the external auditor
- a growth path for the 2020 – 2023 time period that clarifies when expected improvements have to be realized
- Which measures DNB can take if targets are not met (on time)
The Assessment Framework can be downloaded here.