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ALM. Brand A/S
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Hello, and welcome to the Alm. Brand Interim Report First Quarter of 2020. [Operator Instructions] Today, I'm pleased to present Lars Holm. Please begin.
Thank you, and good morning, everyone. And thank you for taking the time to join us on this call on Alm. Brand's results for the first quarter of 2020. As said, my name is Lars Holm, and I'm heading the Investor Relations department at Alm. Brand. And with me today, I have CEO, Rasmus Werner Nielsen; and Senior IR Officer, Mikael Bo Larsen. As usual, we're going to take some time to highlight the results for this quarter. And after this, we're going to hand over the phone to you, so we can have a Q&A session. And with this, I hand over the microphone to you, Rasmus.
Thank you, Lars, and good morning, everybody. This morning, we announced a set of results in line with our expectations. And as such, we are pleased with the development in all our business areas. It's been a quarter with a busy agenda, and we have made progress in adjusting to the new setup that we introduced at end of January. But it has also been a quarter with challenges and changes to our operations, as Denmark has been partially locked down from mid-March. I'm proud to say that our organization has met the challenges in the positive way, and that Alm. Brand has successfully serviced our customers in a time when they needed us the most. Please turn to Slide 2. The first quarter of the year was satisfactory, and although group profit amounted only to DKK 33 million, the underlying development in each of the 3 business areas were in line with our expectations. Despite all the turmoil in the quarter, the majority of our business was stable and in accordance with our forecast. Denmark was partially locked down on March 11, which triggered a number of effects on our business. But all in all, this only had a little direct effect on underlying earnings in the quarter. However, our business is not shielded from the effects of COVID-19. But the turmoil -- both the turmoil in the financial markets and the effect on the credit ratings in the loan portfolio has hit our earnings the most, as seen in the investment result in the securities portfolio in the Non-life Insurance. On the internal agenda, focus has also been on a gradual implementation of the strategic initiatives announced late January, and we are making steady progress on this with the ultimate goal of creating a more customer-centric platform. Overall guidance for the full year is unchanged compared to the updated announcement on March 19. However, we're now able to provide a little extra detail on how we see earnings developing in each of the business areas. Finally, with all the turbulence in both macroeconomics and business environments, I would like to stress again that our business is operating in a relatively stable setting. We are not unaffected, but the major part of our operation is pretty resilient to what is happening right now. Thus, I'm confident we're committed to our plan to reach our ambitious financial targets by the end of '22. Please turn to Slide 3. On this slide, I've summarized and quantified how we see the implications from COVID-19 in each of our 3 business areas. Non-life has seen changes in the insurance claims after the lockdown of Denmark. Travel restrictions were put in place, and activity, in general, has been reduced. Consequently, we witnessed a large increase in travel insurance claims. And when comparing before and after March 11, then the number of claims more than doubled. But almost everything else went down, claims on motor insurance, on commercial accident, on private accident and so on, all went down. And in total, the number of daily claims after the lockdown was down at an estimated 12% compared to the first part of March before the lockdown. In total, the net effect on earnings for the quarter has been very modest, partly because of a higher average cost per accident on some of the insurance categories. The investment portfolio in Non-life has taken a hit of approximately DKK 100 million in the quarter, a combination of losses on equities and bond. In the Life business, the financial markets, of course, also affected the investment results. The investment portfolio consists primarily of bonds, and the equity exposure is relatively modest. Thus, the impact on the policyholders' investments has been relatively low, and the bonus rate, although down 3.3 percentage points, is still at a high level. Banking is affected in various areas. Trading income, investment return and write-downs on loans are all directly hit by the situation. So although underlying business is not affected to any large degree, these areas have a negative impact of around DKK 45 million in the quarter. When adding it all together, we get to a total negative impact in the quarter of around DKK 150 million with the biggest single driver being the development on equity and credit bond prices. But as you know, April has seen a positive development with a number of key markets regaining more than 50% of the loss. And now please turn to Slide 5. The Non-life business made a pretax profit of DKK 25 million in the first quarter of the year. The technical result amounted to DKK 131 million, and the combined ratio was 90.4 with underlying performance in line with our expectation. In total, major claims and weather-related claims was in line with what we have witnessed in previous quarters, but not as low as in Q1 '19. As mentioned, the lockdown in Denmark had an impact on the number of claims, but not enough to translate into a real positive effect on the bottom line in the quarter. Please turn to next slide. Premium income grew by 3.7%, and as you see in the graph shown on the right side of the slide illustrated by the dark bars, this is a very good number compared to previous quarters. Our premium income is split between private and commercial customers, almost 50-50. And especially for the private customers, we have successfully increased premium income, although we continue to see a fierce competition. A lot of effort is put into shaping our products, so that they better support individual and personalized advice to our customers. This has been well received. Further, we have made some price adjustments to specific parts of the portfolio where claims have been high compared to the premiums with the aim of assuring the price -- that the price reflects the risk. This is an ongoing process. But we will need to adapt to any softness in the market due to general changes in the economy, not at least due to COVID-19. Thus, you should not expect the same positive development in the coming quarters. Please turn to Slide 7. The claims ratio, excluding runoff gains, was of 74.7 against 69.3 in the first quarter of '19. Although higher, we must remember that the '19 number was exceptionally low. The expense rate was 17.6, as the FX from the cost savings program has started to kick in. And all in all, this leads to a combined ratio, excluding runoff gains, of 92.3, which is in line with our expectations. The runoff result amounted to a gain of DKK 26 million, which caused bonds to almost 2 percentage points against 2.8 points in the first quarter of '19. On this, we have seen positive results from building, accident and motor insurance, but continued negative impact from the workers' compensation insurance. Unfortunately, we continue to experience a higher number of cases from the labor market insurance at a higher-than-expected claim, which are the reason for the small negative runoff again in Q1. We are obviously not satisfied with this development and will take measures to fix this. The combined ratio, including runoff gains, amounted to 90.4. Please turn to Slide 8. Weather-related claims amounted to DKK 54 million or 4% points and as such, within normal range, but somewhat higher than the very low level of only DKK 29 million back in Q1 '19. Although snow has been absent this year, then we have had a very wet and windy February, which has cost somewhat. Major claims amounted to DKK 51 million or 3.8 percentage points, and thus, at a low level. But again, not as low as seen back in Q1 '19 when we came to only DKK 31 million. In total, the major weather-related claims amounted to DKK 105 million against only DKK 60 million in the first quarter of '19. Compared to the previous quarters, this is a number pretty much in line -- pretty much in the middle of the range of what we have seen, and we are pleased with that level. Please turn to Slide 9. The combined ratio for private customers remains at a satisfactory level of 87.8, i.e., flat against the first quarter of '19. The number is as stated in the beginning of my presentation affected by high claims within travel insurance of around DKK 10 million, which corresponds to an increase in the claims ratio of 140 basis points. But on the other hand, marginally lower claims ratio on the other insurance claims as activity and accident has been affected by the lockdown. Runoff gains were at a healthy 4.3% and also the expense ratio had a positive development as the effect of the reduced overheads goes through to the numbers. And then please turn to the last slide of Non-life Insurance, Slide 10. For the commercial customers, the claims ratio is significantly up against the first quarter of '19. But when comparing to the previous 2 quarters, then we actually see that the level has stabilized following a return of major and weather-related claims being more in line with normal. I.e., this accounts for close to half of the increase. Further, the runoff result is negative against this quarter, primarily due to the workers' compensation claims. And we are addressing this by imposing the necessary price increases to ensure that pricing and risk is balanced. The expense rate is fairly unchanged and at a satisfactory level. And now please turn to the Life Insurance on Slide 12. Pretax profit for the first quarter of '20 amounted to DKK 32 million, which is both very satisfactory and a bit better than our expectations. The result reflects a fine development in the expense and risk results, which amounted to DKK 20 million against DKK 9 million in Q1 '19, and the technical result then amounted to DKK 36 million. The result on investments allocated to equity amount to minus DKK 4 million following the turmoil in the financial markets and the return on the policyholders' investments as this was a relatively small loss of 2.3%. Consequently, the bonus rate was reduced by 3.3 percentage points to a new level of 12.9%, which in the current economic environment is still seen as a satisfactory level. Now I'll move on to Slide 13. Premiums totaled DKK 425 million (sic) DKK 424 million in the quarter and is made up by DKK 246 million in regular premiums and DKK 178 million in single premiums. The growth in regular premiums was 5.8%, and we believe it could even have been a little higher, if not for the COVID-19 impact and the lower rate on policyholders' savings. And now I'll turn to our last segment, Banking, on Slide 15. Core earnings in the Banking amounted to DKK 16 million in the first quarter of the year compared to DKK 11 million in the first quarter of '19. This is a satisfactory development that reflects both some of the effects from the savings program put in place back in January and the improvement of net interest and fee income following the changes introduced at the end of -- at the start of the year. So we have both an income effect and a cost savings effect. But included in the number is also a drop in trading income following the negative development on the financial markets. It is still quite early to quantify the scale of impact from the COVID-19, but we have made a further write-down of DKK 30 million on our loan portfolio to reflect a worsening in the economy. On the other hand, we have also made a reversal of write-downs, as some of our customers have had an improvement in the economy -- economic situation, primarily in the agricultural sector. Hence, we have more or less balanced the write-downs in the quarter. All in all, we estimate that the total amount of write-downs reflect a prudent estimate on the quality of the loan portfolio, and we are pleased that most of our customers are private households. Total investment portfolio earnings was hit by the market turmoil and came out at a loss of DKK 14 million. In total, the quarter generated a pretax loss of DKK 8 million and without the COVID-19 number, this would have been some DKK 45 million better. And now please turn to Slide 16. Business volume is up 6% compared to the first quarter of '19, but flat against year-end '19. Again, it is very early to read anything out of the numbers regarding the potential COVID-19 impact. So far, we have seen only a relative low number of customers who have applied for additional funding due to COVID-19, but we will, of course, be monitoring this closely over the months to come. Please turn to Slide 17. The negative result in the bank translated into a negative return and negative for the quarter. But again, we see a positive development in the underlying business. Back in February, the bank raised DKK 150 million in an unsecured 6-year senior loan to cover the phased-in NEP supplement. Solvency is now at a robust level at 22%, up from 20% a quarter ago. And then please turn to the last slide, Slide 19. Our guidance for 2020 is still that we expect a consolidated ordinary pretax profit of DKK 550 million to DKK 700 million, excluding any runoff results for the rest of the year. The range that we provide for the guidance is wider than normal as we still see uncertainty on especially how the investment results will be. And as usual, we provide a guidance on each business area. For Non-life, we expect pretax profit of DKK 500 million against the guidance given back in January of DKK 525 million. However, with the losses that we have had on the investment portfolio, profit before tax is expected to be lower. The base assumption is still that we will achieve a combined ratio of approximately 91. For Life, we expect pretax profits of DKK 100 million, no changes to what we have guided before. And again, just underlying that we see a lot of transparency and predictability on this one. For Banking, we expect a pretax profit of DKK 80 million against our previous guidance of DKK 100 million. Improvement in the underlying business gives us some comfort, but the net impact of COVID-19 on write-downs and return on investments makes us lower the number. And Other, i.e. primarily headquarter costs, will be at around DKK 60 million, reflecting no extraordinary items expected here. In total, our guidance reflects a business with all major parts moving as we would like it to, but not forgetting that the situation with COVID-19 is affecting all of us. With this, I conclude my presentation, and I hand over the word to our moderator. Thank you.
[Operator Instructions] Our first question comes from the line of Asbjørn Mørk from Danske Bank.
Couple of questions from my side. First, on Non-life. Your underlying combined ratio deteriorated 140 basis points year-over-year. And you mentioned the reported discounting is largely flat. The impact is nonexisting, so to speak, in year-over-year. And you said that COVID-19 is also very manageable, the impact on your Non-life. So what's actually happening here with the 140 bps underlying deterioration? Could you give us a little bit of a flavor on that?
Yes. Asbjørn, of course. We have real -- of course, we have the impact of the travel insurance. We have some impact from February for the -- with the weather, where the weather also somehow hit the underlying development and then we have some impact from the workers' compensation as well. And when you're adding all this up and then you take positive parts from lower car insurance and these things, then we see this negative impact.
But I guess, your travel insurance that you mentioned as one of the issues. I guess, that would be offset by the motor, et cetera, meaning that is included in the largely neutral impact that you have said, COVID-19 had, correct?
Yes, it's almost neutral. And then is this weather-related part from February, we actually got quite some hit in the -- also in the underlying ratio there of around DKK 10 million.
Okay. Fair enough. The travel insurance claims that you have booked in Q1, does that include people that have filed for claim for Easter, but have done that in March?
No, it is like that, when you file a claim, then you get the -- you can say the claim is only raised 2 days before you leave -- should have left for vacation. So it doesn't do that. It is only what is by covering travels in March. Yes. And it's the same with the summer holidays, you could also already now make a claim for the summer holiday, but we only take it into account 2 days before, as we don't know if the borders are open. And if they do, then we don't have to cover.
Okay. And the DKK 20 million reinsurance loan coverage that you have, does that cover the entire period? Or how does that work?
It covers the period until -- I think it was until -- we have said until somehow end of April. But what we see in the figures until now, it is not really into any gains.
So a lot of other summer travel claims, if the borders remain closed, that will not be covered by the reinsurance?
No. That will be covered by a new reinsurance. So you need to see it in different parts.
And that's also DKK 20 million?
Yes.
Okay. Okay. All right. Then you mentioned motor TPL, you say that the average claim is rising. Could you elaborate a bit on what is it actually that you're seeing here?
What we have seen here is small development, but still we see less cars on the streets. But when they crash, they drive a little bit faster than we have seen else. And then the insurance, we have to pay up is a little bit bigger. It's nothing really significant, but we can see some changes in the way accidents are done, so to say.
Okay. Fair enough. If I then may turn to the bank, the DKK 30 million charge you make on COVID-19, how have you estimated this?
What we did when the crisis started, is we took a value on -- we stressed the whole portfolio we have in the bank with a low stress, middle stress and really high stress level. And of course, we need to take into account what we have, you can say, in our provisions already. And when doing all this, then we ended up with saying that we need a COVID-19, you can say, reservation of around DKK 30 million.
And that is related to the central bank, the scenarios for the Danish economy in 2020.
Yes, I would say, more or less it is. And I think actually, it's very much in line with what you see on the bigger bank. We have a very small portfolio compared to that. So if you add up, it's very much in line with what we see elsewhere.
Sure, sure. And then actually a twofold question, but on the bank's operating side as well. I mean, you -- if I take the pre-provision including the impact from old portfolio, you're still loss making. I know that you say that the trading was impacted negatively in Q1. But let's just say that it's more or less plus minus 0. If you look at the operations before loan losses. How -- I mean, should we expect this to improve in the next couple of quarters? Or are you expecting reversals of loan losses to sort of drive you to the DKK 80 million profit for the full year?
Yes. I would say, yes, so. Just continue, Asbjørn, you had...
Yes. I mean, it was just because then your guidance -- you lowered your guidance by DKK 20 million for the full year, but you said that the impact from the bank from COVID-19 was DKK 45 million. So I guess, inclusively something is doing better?
Yes. No, what we have lowered our guidance is DKK 80 million, and that is with, you can say, a 0 development on the loan losses. So the guidance is lowered in '20, mostly due to the impact of the trading activities and the loss on the investment portfolio. So the underlying business should add on to the DKK 80 million. We expect them to do that.
So you -- the DKK 80 million is assuming 0 loan losses for the full year?
Yes.
So we should expect -- okay, okay, fair enough. Okay. So when you gave -- had the guidance of DKK 100 million before, was that then implicitly assuming reversals? Or was it also 0 losses?
It was assuming 0 loss also.
Okay. So it's really the trading effects.
Yes. It is the trading take, and I hope you also noticed that we have increased the top line somehow.
Sure. That was, I guess, in your plans also...
Yes, exactly.
Okay. Fair enough. Fair enough. Okay. And then my final question on a capital model, excess capital, how should we look at that?
Yes, Asbjørn. This is Lars Holm here. And are you on a group level now or specifically in the bank?
On a group level?
Yes. Well, we are -- well, we have -- basically we have sufficient capital. And if you're referring to the dividend, we have said that we now are going to postpone -- we have postponed the decision to the autumn. Whether or not we pay out our dividend in 2019. General view is that we are very robust when it comes to capital.
Yes, but the capital model...
Yes, okay, we'll not disclose any longer. We've changed that. So now we have a dividend policy that we're going to pay out at least 70% of our annual result, and that's still the case.
So you're not going to be as loyal or whatever you are going to call to the excess capital model any more. So if there's excess capital that will not necessarily be paid out to shareholders in the short term.
We're not ruling that out. What we are saying, at least 70% of our earnings is going to be paid out. And as you remember, the intention for 2019 was actually to pay out a bit more than 70%. We actually paid out -- even though we changed that along with the Q4 results. So we are definitely going to be very -- sorry, very strict when it comes to our capital management. That's not going to change. But our policy is that we now have a dividend policy instead of having this capital modeling for each quarter basically.
But why are you not disclosing capital model anymore?
Yes. Because we changed that. So we want to have a more, so to say, steady capital management linked to the payout ratio instead of cost cuts because you have this fluctuation in capital models that we sort of want to get out and communicate on a more steady basis with our dividend rate.
Okay. But then I guess my question is really. So the general view on how you look at your capital and your requirement. That will still be the same more or less? Or you're going to look at the regulatory requirement? Or I mean, it's going to be your own requirement at the levels of some...
Yes. Yes. True.
So it's a minimum of 70% and the last 30% is used for increase in premiums and all that.
Yes. And if that's not the case, then we're definitely going to look into to help dispute that as dividend as well.
And the next question comes from the line of Per Grønborg from SEB.
First of all, not so much a question, more a question whether we can get some information. Yes, you are finally dividing in the bank, the NII and commissions out on 2 lines, thanks for that. Any chances that we can get the split for 2019 will come in the financial figures that I can see hasn't been uploaded to your home base yet?
Yes, I will. I should make sure -- we knew that you were going to ask that, Per. so we definitely got to say to you. But the intention is that it's going to be included in the figures on our website.
When will those figures be uploaded?
Today. But I'll send it to you guys.
Remortgaging activity this quarter, how large was the positive impact?
It was minor, only a couple of million in the bank.
A couple of million. Perfect. When I look at your P&C cost, you are targeting a 16% full year cost ratio. We see -- we saw quite limited impact of the lower cost burden in the first quarter. If you should reach that, that implies that your underlying run rate will be more like 15.5% for the remaining part of the year. Is that a fair assumption?
Well, Per, the 60% is our goal for 2022 after 2020. And that's going to be a gradual decrease in the cost ratio towards 2020 -- towards 2022.
Okay. I read that a bit too far.
But, Per, just to be clear, but of course, we expect the cost side is exactly in line and a little bit lower than we have in our budget. So it's clearly following the path we have estimated for the year. And it will -- the percentage will, of course, decline throughout the year as normal.
I guess it would be fair to assume that we will see a visible decline in the second quarter where you have the first clean quarter after the cost cutting program?
Yes.
On travel insurance, you mentioned reinsurance program of DKK 20 million. Is that mentioned anyway in the reinsurance? Or I don't know where that information is coming from?
Yes. Again, the figure didn't get the figure, Per.
The DKK 20 million for own account on travel insurance, don't see that...
That's the reinsurance program. Sorry, that's the reinsurance program. So whenever they are getting EUR 22 million, we're going to -- the rest will be captured by reinsurance. But for this quarter, we have expenses of DKK 10 million due to travel.
And you said that this is not a program that covers an event that covers by time, meaning if we don't see any changes to the current lockdown, that you will still have to pay for a new reinsurance program running into the summer holidays.
Yes. And it's like a first event, was the mid-March when the prime minister said, now we close down. And then she expanded it by 2 weeks, and we said that's how we see it as one event. And then as of now, we see the next thing coming as a second event. But of course, it has to be discussed with the reinsurance company. It's not really stated in the policy how to cope with this thing.
But I guess, up until now, there haven't been a second event. The second event would be if they open the borders again? And then people would be allowed to travel.
Yes.
Okay. On Life, I assume the very strong risk result that is unlucky quarter. Is that fair?
You can say in the health part, it is a little bit -- it's a little bit up and down. I would say it was up with DKK 10 million in this quarter.
That's what I'm addressing. That was basically not this quarter.
Yes. But that's also why we don't increase the expectation for 2020.
Fair enough. On the buffer that it looks very, very strong. Can you share with us what was the trough level of your buffers when we had the trough of the market?
Yes. But I think you should see it in a different way. When we were -- in August last year when we experienced also the big depreciation in share prices and all that, then we took some measures and we made some, you can say, some activities within the portfolio in order to ensure that we will not see such a big decline another time. And of course, it cost a little bit on the upside, but then recovered it more on the downside. So we have not seen a real worsening in the situation. We have been around the level where we are now. So from -- yes, during -- there has not been any worsening in the last 2 weeks of March around this level, yes.
Okay, okay, okay. Interesting. On the prior year gains, you said that you would take measures to fix the losses on your one-off on your workers compensation? That seems like you will hike current year's prices. But I guess that will not remove the losses on the OTS. It's not simply a question of that you have basically reversed 2 last claims previously, and now you have basically maybe even slightly under-reserved on this business line?
No. No. I understand your question. One, in terms of pricing, then we were just about to pull the button when COVID-19 started, and then we said, we cannot do this to our customers, increase prices right now. So we have to wait a little bit until market gets back a little bit more to normal. And then definitely, we will increase prices on workers compensation. In terms of our reservations, there was a small hit. I think this end of March when this motor insurance thing, I think, they came back with that they have fixed more of these claims. And then we said, okay, we take them now, and we don't use what we have on the shelf, so to say, from this reservation. We are not -- we still have things. Otherwise, we should have made a one-off when we got into this new situation with higher claims. And we haven't done that. So we are somehow well reserved there still. It goes a little bit -- we need to expect that now, and then it goes a little bit up, it goes a little bit down on workers compensation. Yes, that's how it is.
Okay. Finally, on the payout, assuming you end up having 2 strong pressure from EIOPA and Danish FSA not to pay out anything for 2019. Should we expect that you're basically entering your excess capital at the [ AGM ] in 2021 as you done historically?
Yes.
[Operator Instructions] The next question comes from the line of Martin Gregers Birk from Carnegie.
My first question goes on premium growth, you reported 3.7% in the quarter. What is the targeted rate for full year '20?
I think we have -- we don't have special target, Birk, but we internally, we think about 3%. And even though we had a good start-up. I think it will be very tough under these circumstances to reach 3%. But I would say we have made a good start of the year, and we are very happy with that.
Okay. Okay. And then my second question comes on -- with respect to reinsurance. You say DKK 20 million and assume there is still some DKK 10 million to go until you reach the DKK 20 million threshold. But -- and then you can refer those claims back to the lockdown date. But what if there aren't any -- what if the borders are open, but there aren't any flights? Why wouldn't that be the same? Why wouldn't that go back to the same lockdown date?
No, Birk. But yes, that we have to see, but then it's about who's sitting with the problem at end of the day. If I understand that. If the government changes the ruling that now everything is green instead of red. Then as such, we are not covering. Of course, there is the -- it is a matter of what does the -- you could say, airplane companies do at that level. And that we have to think about when we reach into that. So it's a matter of what is happening within the last 48 hours before actually have to take off to what you have to do.
Okay. But just to help me clarify here because I -- so let's say I book a ticket with Norwegian and Norwegian doesn't fly, and -- but they're not able to refund me the money. Then you guys still cover it, right?
As such? Yes, yes, you're right. Then we will cover. And then we'll have a claim on Norwegian.
Yes, but they're never going to pay that, right? So...
I don't know...
So you guys are going to be on the hook...
I don't know. I think if we insist, then they have to cover. You have to have that kind of [ data ] yesterday and the European Parliament saying that the airplane companies have to cover if we want to continue to exist.
Okay. Okay. And then my final question on combined ratio going into Q2, in particular, where you have seen -- well, you get the full effect of the lockdown in April, what should we expect? What are the moving parts between travel, motor, accident, et cetera?
Yes, that is a good question, Mark. I can, of course, not answer that exactly. But in April, we have seen less cars on the streets and all that, as you have seen yourself, and there will, and there are some positive effects. Then the question and the same in the -- of course, in the investment part as well is also positive. But I would say that I'm a little bit more curious to see what is happening in May now when people are getting back to work and all that, that I think things will stabilize quite quickly. At least we see a tendency to -- that is actually only the travel things that are really down, but the other ones are coming back to not a normalized level, but getting closer to a normalized level. In May, I would expect.
Okay. Okay. So when you -- by year-end '20 report your segment business line breakdown on your different parts in your Non-life Insurance, and you see that there is -- there could be potential supernormal profit in certain business lines. Is that something that you are afraid of? Or do you fear that there's going to be any sentiment for insurers to either pay back premiums to reduce 2021 premiums? Or how should we think about that?
No, not at the moment, Mark, not at the moment. I think we'll -- except for the travel insurance, I think we'll get back to a normalized level quite quickly. And we haven't had any customers really asking for what you're talking about. There could be -- I think there could be some competition and maybe also a little bit more investigations for some of the public companies on what they pay in premiums, but as we are covering the lower part of the segment, I think it's mostly the real big companies that will have to spend the time and effort to get into this.
Okay. Okay. And then just finally, on following up on Per's question on the dividend. If -- in order to pay out the 2019 dividend later in the year, do you need anything from -- do you need a letter from EIOPA or Danish FSA? Or if this is stabilized, are you willing to do it without any -- without seeking any approval or seeking any indications from regulators?
No. I would say that I think we need to see how the market develops. And then we will follow that. But again, as Lars said, we have the funding. I also think as you see in the accounts -- our accounts that we have enough capital at the moment to provide a dividend. So we are leaning a little bit back and then waiting what is happening in the market.
Okay. So you will need a thumbs up or a positive nod from the regulator in order to go...
But I'm on weekly calls with Danish FSA and -- yes I think, if they continue, then I will discuss with them.
And we have a follow-up question from the line of Per Grønborg from SEB.
Yes, rightly turned it from one into being two. Just to be clear on Martin's last question. Do you need to seek formal approval from the FSA on your capital planning before make an extraordinary dividend or announcing a buyback?
The short answer, Per, is no. We don't do that. They have not -- it has been -- you can say, how do you say in English, it's been a recommendation, it's not been an order.
The reason I'm asking is because the banks, they need to ask to get a formal approval, but that's the difference between the banking orders and then...
Exactly. And here, we are discussing the group. And for sure, we have stated that in 2020, the bank will not provide any dividend for '19. But we will do it. We still keep the same dividend level on group level.
Yes. Okay, perfect. Then just on the travel claims. To what extent should we expect that the company clearing the card payments will be held liable? We have any experience how many have paid with a bank card with no card risk and how many have paid with international credit card, where basically, you can go back to the credit card company and get the money from them on that?
Now we don't have the figures for that, Per, to be honest.
What's you guess, 1/3, 25% or no clues?
To be honest, your guess is as good as ours. But it's not something we -- it's not an issue we have had to deal with. So maybe that answers your question.
On the other hand, that could be a pretty good second line of defense.
Yes.
You're right about that.
As there are no further questions, I'll hand it back to the speakers.
Okay. Thank you for listening, and thank you for all the good questions. Look forward to see you maybe later, some of you at least. But have a good day. Thank you.