Advertising Code Committee
Private individuals and corporations can submit complaints about advertisements to the
Dutch Advertising Code Committee. During 2010, a total of six complaints were submitted
in connection with statements made by Rabobank, Robeco, De Lage Landen, Obvion and
Rabobank International. In three instances, the Committee ruled in favour of the client.
The other complaints were rejected.
Netherlands Authority for the Financial Markets
In 2009, as part of a sector-wide survey, the Netherlands Authority for the Financial Markets
(AFM) reviewed how Rabobank has interpreted the rules for mortgage advice. AFM went on
to raise a penalty of EUR 150,000 against Rabobank in 2010.
AFM concluded that Rabobank would grant well-educated, young first-time buyers slightly
higher mortgages because of their jobs and education, and their promising perspectives on
the labour market. AFM felt that Rabobank did not have enough regard for the customer's
individual circumstances. AFM also established that, when advising clients about life insurance
and incapacity insurance policies, Rabobank does not go into sufficient detail, and that
arrangements made with clients should be documented better.
In Rabobank's opinion, well-educated first-time buyers who have a good job were not
automatically offered a higher mortgage. Loan applications were consistently followed by
a broad and in-depth consultation with the client, and decisions on potential increases in
a client's income were always taken in dialogue with them.The basis for this process was
data published by Statistics Netherlands and the bank's empirical knowledge. In Rabobank's
experience, this group of first-time buyers is particularly well equipped to bear higher
mortgage costs. AFM's decision forced Rabobank to revise its policies, which have now been
amended. With a view to expected legislation, Rabobank has chosen not to appeal the
penalty imposed by AFM.
AFM claims that Rabobank did not document clearly enough, in advising clients on their life
insurance and incapacity insurance policies, what the exact considerations were that led up to
the insured amount. Rabobank feels that it has provided its clients with appropriate advice on
these insurance policies. Any arrangements made with clients were documented in their files.
The products were transparent and offered value for money. Rabobank has also adjusted its
procedures in this respect.
Balanced advisory model
With regard to charges and fees for services provided to clients, Rabobank aims to charge
amounts that are appropriate to the service provided. In 2011, the relevant subjects will be
identified in further detail.
Safety, security and privacy
Rabobank gives high priority to the safety, security and privacy of clients and employees.
In connection with this, a number of long-term ICT and other programmes have been
introduced to improve the quality of logical access control and the security of virtual channels.
Employees are given specific training on security risks and desirable behaviour. During 2010,
Rabobank updated the ICT Code of Conduct. New additions to the code include rules governing
the use of online media for communication. In this way, we are preparing our employees to
work and communicate securely in an increasingly digital society.
Clients can go to www.rabobank.nl for advice on security aspects of online banking and
mobile banking. In addition, Rabobank has actively contributed to the launch of a new 'secure
banking'campaign by the Dutch banks.
Rabobank pays constant attention to cyber crime, a form of fraud that primarily targets online
banking. We invest heavily every year in maintaining the security of virtual channels. In 2010,
the quality of monitoring improved sharply. This has put Rabobank in a better position to detect
and stop fraudulent transactions.
Annual Report 2010 Rabobank Group