Rabobank’s reaction to AFM exploratory study:

‘No abuses, but some points for improvement for special asset management’

Signals from the market regularly generate the feeling that the working methods of special asset management departments are at odds with customers’ interests. This led the Netherlands Authority for the Financial Markets (AFM) to carry out an exploratory study at four Dutch banks. The study concludes that there are no abuses taking place at these banks. The AFM has, however, put forward strong recommendations that the banks make improvements primarily regarding their provision of information and customer relations.

Signals from customers and parliamentary questions

The AFM decided to conduct an exploratory study at four Dutch banks based on signals from customers and parliamentary questions in the Dutch parliament concerning lending and the working methods of special asset management departments. Rabobank is one of the banks that has willingly cooperated in this study. The bank holds a large market share in the SME sector in the Netherlands and consequently has a proportional number of businesses under special asset management. While no abuses were found, the AFM report sends out a clear message that banks should be more aware of customers’ experiences, feelings and perceptions of a special asset management process. The study findings reveal that ambiguities and misunderstandings regularly arise in the communications.

Mutual understanding

‘We have experienced this as a positive and constructive cooperation that entailed conducting a detailed study of matters ranging from administration to customer contacts,’ says Rabobank Executive Board Member Rien Nagel. ‘This has increased mutual understanding both for our position as lender and risk manager and for our responsibility to manage customers’ savings properly.’ Another key conclusion is that the AFM has not detected any unreasonable measures. ‘This confirms my impression that as a rule our employees operate conscientiously and proportionally in a process that demands a great deal from our customers and our employees: providing complex advisory services to businesses that are experiencing hard times. Fortunately most of these businesses recover, but in some cases there are insufficient prospects of recovery and difficult decisions are inevitable.’

Points for improvement

The AFM study was a catalyst for making improvements. The bank has already implemented some improvements in the field of communications and the provision of information to customers, such as complaints management. For example, customer information about special asset management provided on websites and in leaflets has been renewed and expanded. This information is now brought more expressly to customers’ attention. The AFM has also made other recommendations that vary for each of the four banks it studied. They relate to matters such as the fee structure and the use of surcharges and the course of business termination processes. The AFM says it is up to each individual bank how it acts on these recommendations.

Customer forums

‘As Rabobank we are fully aware of the necessity to communicate even more clearly with customers and to keep careful records of these communications,’ says Rien Nagel. Another issue involves looking at how we can clarify customers’ own roles and responsibilities. As a bank we should help bring about this clarity. This is crucial in order to be able to facilitate dialogues with customers and other stakeholders more effectively. For example, Rabobank recently organised ‘customer forums’ in which customers could exchange their experiences and opinions about our special asset management and share the process with the bank’s employees. ‘This direct feedback from customers was an excellent learning experience for everyone involved. We will be doing this again as it generates key insights and fosters mutual understanding.’


Customers did not only make critical comments, they also expressed their satisfaction with our commercial, economic, sector and legal knowledge. Some customers also view the bank’s role in their process of self-reflection as beneficial. The criticism of Rabobank’s operation focuses primarily on the communications and empathy. There are four spearheads for ensuring that contacts with customers – and consequently the special asset management process as well – run more smoothly:

  • Carefully transferring items to local special asset management departments and to Special Asset Management Rabobank.
  • Communicating clearly and transparently about what a special asset management process entails, what customers can expect and what we expect from customers and their consultants.
  • Clearly explaining fees and surcharges.
  • Showing empathy and giving regular updates.

In the coming months Rabobank will work on these points with our customers to further improve special asset management.