Fine for inadequate documentation in 2010-2013

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ABN AMRO Head Office

In 2013, the Netherlands Authority for the Financial Markets (AFM) performed a limited spot check to verify whether the records of SME clients who had contracted interest rate derivatives from ABN AMRO were sufficiently complete. The investigation involved client records for the period from October 2010 to January 2013.

The spot check showed administrative incompleteness. As a result, the AFM had insufficient means to establish whether the service provision tied in with client requirements. For this incompleteness, ABN AMRO was given a EUR 2 million fine on 20 October 2015.

Preventative measures

The bank regrets the incompleteness and has taken measures since 2013 to prevent this going forward. It has, for instance, re-evaluated the duties and procedures with regard to documentation, and assigned them appropriately. In addition, information materials have been reviewed and modified where needed, and steps have been taken to uphold continuous awareness of the importance of proper documentation.

In touch with all clients

ABN AMRO has about 350,000 SME clients. Per 1 April 2014, 4,500 SME Clients had an interest rate derivative. All these clients’ records were reviewed in the first half of 2015. Every one of these clients was sent a letter explaining the matter in April. The bank has contacted, or will soon contact clients, whose records should have been in better order or that are potentially faced with an issue. In case of an issue, the bank will offer a solution. A provision for this purpose has been formed.

More information

For an extensive description of the review of the SME interest rate derivatives, see the Interim Report for 2015​ (PDF 1 MB) (page 101). Additional information about the review process has been posted on the interest rate derivative review website the interest rate derivative review website.


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