8.2 Developments in 20 76
Inhoudsopgave Voorwoord Bestuursverslag Corporate governance
Consolidated Financial Statements Company Financial Statements Pillar 3
EDTF32 Rabobank aims to continually improve the risk
management function in the organisation. In 2016 the
Rabobank has appointed a Chief Risk Officer in the board
separate from the Chief Financial Officer and combined the
directorates of Compliance, Legal and Risk. Additionally
a separate Risk Control Framework department has been
established. This was set up within the standing organisation to
further develop, implement and maintain the Risk Control
Framework (RCF). RCF includes initiatives regarding organisation
wide Risk and Control Activities supported by one way of
working, tooling, learning programme and taxonomy for all
OpRisk expertise areas. The Operational Risk Management
department continues as the Operational Risk Framework and
Reporting department.This corporate Operational Risk
competence centre focuses on themes such as Risk Appetite
Statement, Capital modelling, Stress testing, Scenario analysis
and Corporate Risk Profiling and Reporting.
Large and relevant events that took place within Rabobank in
2016 or before include:
SME Derivatives: Rabobank will follow the Uniform
Reassessment Framework proposed by the commission
for reassessing the quality of advice rendered on interest
rate derivatives in the SME market with respect to those
customers that fall within the definitions of the Framework.
Penalty interest on mortgages: An in-depth discussion has
taken place between the large Dutch banks, NVB and AFM
about the way banks calculate their loss on restructuring
of private mortgages ('oversluiten'). Rabobank is currently
following up on her internal evaluations of the process.
The Department of Justice is currently investigating alledged
ommissions with regards to AML in North America.
All large incidents include analysis and lessons learned for
appropriate follow up.
350 Rabobank Jaarverslag 2016