Single Customer View
With the implementation of the revised DGS Directive in Dutch legislation, the payout deadline in case of bankruptcy of a bank will be reduced from the current ten, to seven working days. The Single Customer View (SCV) was introduced to ensure smooth and prompt payout within this deadline. You can find a list of current regulations and publications below.
A shorter repayment period has as 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 submit a Single Customer View (SCV, in Dutch: Individueel Klantbeeld, IKB) in a uniform manner.
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 SCVs in the Single Customer View Policy Rule (Beleidsregel Individueel Klantbeeld). 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. In addition to the yearly scheduled delivery of the SCV file, banks are required to have an audit performed on annual basis.
First round of amendments to the DGS legislation (February 2019)
The original SCV Policy Rule of 2017 saw its first amendments in 2019. DNB published the amendments in the Government Gazette in early February 2019. The principal changes to the SCV Policy Rule are the introduction of a marking of deposits acquired on the basis of a European passport for cross-border services, and the introduction of the possibility of preparing more accurate estimates of guaranteed balances held in escrow accounts for reporting purposes. The other changes were implemented in response to questions raised by banks during the transition to the SCV based file delivery. These changes were put up for public consultation at the end of 2018. The document First round of amendments to the Deposit Guarantee Scheme Rules - Final adoption presents more information and our feedback to the consultation responses. We have prepared a new version of the interactive consolidated publication (currently available in Dutch only), in which the February 2019 changes have been incorporated in the DGS regulations pertaining to the SCV ('Regelgeving Depositogarantiestelsel – Februari 2019').
Specification of data delivery
The specification of the data delivery is described in a Data Delivery Agreement (DDA), in Dutch the ‘Gegevensleveringsovereenkomst’ (GLO), which contains a Formal Logical Data Model (LDM).
The GLO defines the technical specifications of the data exchanges that are laid out in the DGS Policy Rules. It is exclusively available in the English language and is composed of a set of files and documents that can be found in the form of a zip-file in the downloads section.
The document ‘QA Transition IKB’ provides a handy overview of the most commonly asked questions that banks have submitted on the subject of data delivery, with answers.
At least once every year, banks must instruct their external auditor to perform an audit of the bank's compliance with the requirements of the Single Customer View Policy Rule. The assignment must be based on ISAE 3402 (see Section 12 of the SCV Policy Rule).
As part of the bank's three lines of defence model, the internal audit department too must assess at least once a year whether the requirements set out in the SCV Policy Rule have been met. The internal audit department’s report must be made available within a reasonable time to allow coordination of the various procedures with the external auditor (see Section 11 of the SCV Policy Rule).
The Assessment Framework for supervision of compliance with the SCV Policy Rule provides more guidance on the SCV audit. It includes the most recent version of the generic assessment framework with control objectives and internal controls.
Assessment framework for supervision of compliance with the Single Customer View Policy Rule
DNB supervises compliance with the requirements set out in the SCV Policy Rule, which is why we adopted the Assessment framework for supervision of compliance with the requirements under the SCV Policy Rule in May 2020. The elements of the assessment framework include:
- several indicators that clarify the extent to which banks comply with the requirements
- the role played by the audit of a bank's SCV system by the internal audit department and the external auditor
- a growth path for the period 2020-2023 specifying deadlines by which expected improvements are to be realised by the banks
- which measures DNB can take if targets are not met (on time)
Using the assessment framework, DNB sends banks individual overviews of the extent to which they meet the requirements of the SCV Policy Rule each year. Similarly, we describe the improvements we expect them to achieve, in accordance with the growth path set out in the assessment framework.
Assessment framework supervision SCV Policy rule
Letter 18 November 2019 to all banks on DGS regulations based audit
Control objectives and controls DGS ISAE3402 - November 2019
First round of amendments DGS Policy Rules - February 2019
First round of amendments DGS Policy Rules - Consultation - October 2018
Consultation Paper Policy Rules for the DGS