Strategy
The Sparebanken Møre Group’s, and thereby Møre Boligkreditt AS’, long-term strategic development and goal achievement are supported by high quality risk- and capital management. The overall purpose of risk management and -control is to ensure that goals are achieved, to ensure internal and external reporting of high quality, and to make sure that the Group operates in accordance with relevant laws, rules, regulations and internal guidelines.
Risk-taking is a fundamental aspect of banking operations, which is why risk management is a central area in the day-to-day operations as well as in the Board of Directors’ ongoing focus. Sparebanken Møre’s Board of Directors has agreed overall guidelines for management and control throughout the Group.
Møre Boligkreditt AS shall have a low risk profile and revenue generation shall be a product of customer related activities related to the company’s operations and purpose, not a product of financial risk-taking. In addition, the company has introduced policies for each significant risk area: credit risk, market risk, liquidity risk and counterparty risk. The risk strategies are adopted by the Board of Directors and revised at least once a year or when special circumstances should warrant it. The approved risk policies operationalize the business strategy set forth in the company's overall strategic plan. The company has established control structures to ensure that the overall framework of the strategic plan is adhered to at all times.
Risk exposure and strategic risk management
Møre Boligkreditt AS takes into account the interaction between the various risk areas by setting desired levels of exposure. Overall, it is the internal conditions, general conditions, customer base etc. in the Group that form the basis for setting the desired overall risk exposure.
Based on an evaluation of the risk profile, management and control, Møre Boligkreditt AS has set the following overall levels of risk exposure for the various risk areas:
• Credit risk: A low level of risk is accepted
• Market risk: A low level of risk is accepted
• Liquidity risk: A low level of risk is accepted
• Operational risk: A low to moderate level of risk is accepted
Møre Boligkreditt AS is exposed to several different types of risk. The most important risk groups are:
Credit risk
Credit risk is defined as the risk of loss due to customers or other counterparts being unable to meet their obligations at the agreed time in accordance with the written agreements and that collateral held is not covering the outstanding claims. This is the company’s most significant risk area. Møre Boligkreditt AS’ main credit risk is related to mortgages to customers with collateral in residential property and housing associations. Møre Boligkreditt AS acquires the mortgages from Sparebanken Møre, originally granted to customers by Sparebanken Møre, based on group policies and limits. At the time of the transfer of mortgage portfolios, only mortgages that qualify as collateral for the issue of covered bonds, are accepted by Møre Boligkreditt AS. The eligible value of the mortgage balance in the cover pool cannot exceed 80 per cent of the total value of the property. The collateral value is monitored on an ongoing basis.
According to credit risk policies set by the Board of Directors, Møre Boligkreditt AS manages and controls credit risk by setting limits on the amount of risk and by monitoring exposures in relation to such limits. Collateral is taken to manage credit risk in the mortgage portfolios. According to the agreement relating to the transfer of mortgages between Sparebanken Møre and Møre Boligkreditt AS, the day-to-day monitoring of the mortgages are managed by Sparebanken Møre on behalf of Møre Boligkreditt AS.
The risk classification systems are used as decision support, monitoring and reporting. The risk parameters used in the classification systems are an integrated part of the credit process and ongoing risk monitoring, including the follow-up of credit strategies. Probability of default, PD, is used to measure quality.
The risk classification system is divided into ten non-default risk classes and 3 default risk classes. The classification system is based on the probability of default which is an estimate of the likelihood of a counterparty defaulting on its contractual obligations.
See also the Group’s Pillar 3 document published on www.sbm.no/investor-relations/.
Market risk
The risk of loss due to changes in fair value of financial instruments as a result of fluctuations in market prices such as share prices, foreign exchange rates and interest rates. Møre Boligkreditt AS minimizes currency risk through swap agreements with eligible counterparties. The Board of Directors sets risk limits, positions are monitored on a daily basis, and quarterly exposure reports are prepared for the management and for The Board of Directors. Fixed interest on the company's funding and fixed-rate mortgages to customers are managed through interest rate swaps with eligible counterparties.
Liquidity risk
The risk that the company will encounter difficulty in meeting obligations associated with financial liabilities that are settled by delivering cash or another financial asset. The Board of Directors sets annual limits for the company's liquidity risk, which means preparing liquidity risk limits, contingency plans, forecasts, stress tests, routines for monitoring limit utilisation and compliance with guidelines, management reporting and monitoring of management and control systems.
LCR measures institutions' ability to survive a 30-day stress period. LCR has increased the importance of high-quality liquid assets. The minimum regulatory requirement for LCR is 100 per cent.
The cover pool liquidity buffer shall cover the maximum cumulative net liquidity outflow over the next 180 days.
The CRR2 banking package applicable in Norway from June 2022 introduced a minimum requirement for Net Stable Funding Ratio of 100 % on total currency level.
Operational risk
The risk of losses due to inadequate or failing internal processes, human error, system failures or external events. Møre Boligkreditt AS has a management agreement with Sparebanken Møre. The services covered by this include administration, production, IT operations and financial and risk management. Although the operational risk of Møre Boligkreditt AS is dependent of Sparebanken Møre's ability to manage this type of risk, Møre Boligkreditt AS independently bear risk associated with errors in the deliveries and services provided by Sparebanken Møre.
The evaluation of the management and control of operational risk is of high focus in the Group's annual ICAAP. The operational and established internal control system in the mortgage company is also an important tool for reducing operational risk in terms of both identifying risk as well as follow-up.
The internal control system is designed to ensure reasonable certainty with respect to attaining goals within the areas of strategic development, efficient operations, reliable reporting and compliance with acts and regulations, including compliance with intragroup and company-specific guidelines and policies. A well-functioning internal control system also ensures the mortgage company's risk exposure being within the adopted risk profile. Reports are submitted to the company's Board concerning operations and the risk situation throughout the year. The Managing Director submits an annual report to the Board containing an overall assessment of the risk situation and an assessment of whether the internal controls are functioning satisfactorily.
CLIMATE RISK
Climate risk is the impact resulting from climate change, and climate risk will impact the company’s credit risk. When assessing climate risk, two types of risks in particular must be assessed: physical risk and transitional risk.
- Physical climate risk arises as a result of more frequent and severe episodes of drought, flooding, precipitation, storms, landslides and avalanches, as well as rising sea levels.
- Transitional risk is the risk associated with changes to, and the escalation of, climate policies/regulations, the development of new technologies and changed customer preferences (consumers) and investor requirements that may result in sudden changes in the market value of financial assets.
For additional information, see Sparebanken Møre’s consolidated annual report at www.sbm.no
Capital management
Møre Boligkreditt AS acquires mortgages from Sparebanken Møre funded through the issuance of covered bonds, with paid in equity and a line of credit in the parent bank.
Capital adequacy rules and regulations
The EU’s capital adequacy directive’s purpose is to strengthen the stability in the financial system through more risk-sensitive capital requirements, better risk management and control, more stringent supervision and more information provided for the market.
Banking package IV is applicable in the EU from 01.01.2025 with the implementation of the capital requirements regulations CRRIII and the capital requirements directive CRDVI. However, CRRIII cannot enter into force in Norway until CRRIII is incorporated and in force in the EEA Agreement.
The Department of Finance in Norway has decided to increase the risk weight floor for mortgages from 20 to 25 per cent, effective from 1 July 2025. This will result in increased risk weights for mortgages and reduced capital coverage.
The capital adequacy directive is based on three pillars:
• Pilar 1 – Minimum requirement for equity and related capital
• Pilar 2 – Assessment of aggregate capital requirements and regulatory follow-up (ICAAP)
• Pilar 3 – Publication of information
Møre Boligkreditt AS applies the IRB Foundation Approach when calculating capital adequacy for credit risk, the Standard Approach for market risk and the Base method for operational risk. Møre Boligkreditt AS’ Board of Directors ensures that plans for the capitalization of the Company are in place, both during economic downturns and periods of strong economic expansion. Capital assessments (ICAAP) are conducted annually, and the company’s capital strategy is based on the risk in the company’s operations, having taken into consideration different stress scenarios.
Reporting
Møre Boligkreditt AS focuses on correct, complete and timely reporting of the risk and capital situation. Based on this, a number of different types of periodic reporting have been established that are intended for the Board of the company. The most important reports during the year are as follows:
ICAAP (Internal Capital Adequacy Assessment Process) is carried out and reported at least once a year. Møre Boligkreditt AS is included in the assessments of the overall ICAAP for the Sparebanken Møre Group, and the Managing Director of Møre Boligkreditt AS is involved in the process. The process is led by the Risk Management department in Sparebanken Møre. Specific guidelines have been prepared for ICAAP in Sparebanken Møre. ICAAP is reviewed by the bank's management team and the Board of Directors.
Møre Boligkreditt AS’ Internal Liquidity Adequacy Assessment Process (ILAAP) is included in the company’s Internal Capital Adequacy Assessment Process (ICAAP).
A performance management report is prepared every month. The report presents the status and performance of the most important aspects of goal achievement in Møre Boligkreditt AS. The report is an integral part of the reporting to the Board of Directors.
A risk report is prepared every quarter and is a key element of Møre Boligkreditt AS' continuous monitoring of its risk position. The risk report is reviewed by the Board of Directors in quarterly board meetings.
Internal control reports are produced annually. In the report, an assessment is made of whether or not the internal control is adequate in relation to the risk tolerance. This includes an assessment and comments on internal control work performed, a review of important risk areas, an assessment of compliance with external and internal regulations, and suggestions for and planned improvement measures. The internal control report is discussed by the Board of Directors. Møre Boligkreditt AS’ internal control report is consolidated in the Group’s total internal control reporting.
Reports from external and internal auditors and from the independent surveyor, and also compliance reports, are reviewed by the Board of Directors, as well as the Risk and Audit Committees of Sparebanken Møre.
A reporting portal has been established in the Sparebanken Møre Group, and each member of staff with customer responsibility have access to reports showing the position and development in the credit risk in his or her portfolio. The portal has a hierarchical structure, allowing managers in Sparebanken Møre and Møre Boligkreditt AS to monitor performance within their area of responsibility. The reports are also used to analyse customers, portfolios and different industrial, commercial and other sectors.
Finance and accounting reports are prepared monthly (and include calculations of expected credit loss, as well as quarterly loss reviews of portfolios with a focus on the need for individual impairment). The reports are reviewed by the Board of Directors.