ING Reported a 160% Liquidity Ratio. APRA Says the Real One Dipped Below 100%. It Writes More Than 95% of Its Book Through You

ING had been reporting a Liquidity Coverage Ratio of approximately 160 per cent. According to APRA, the actual figure was substantially lower and, at times, fell below the 100 per cent minimum required under Prudential Standard APS 210 Liquidity.

For most of the market that is a governance story about one bank. For the mortgage broking channel it is more specific than that. ING originates more than 95 per cent of its home loans through brokers. There is no substantial proprietary channel absorbing the other half. Whatever this remediation does to ING’s cost base, appetite or service levels over the next 12 to 24 months arrives in the third-party channel undiluted — through pricing sheets, credit policy notes and assessment queues.

This piece covers what APRA did, what it explicitly did not say, and the small number of things genuinely worth checking on your own desk this week. It is not a reason to move clients. It is a reason to know your numbers.

1. What APRA actually imposed

APRA’s response has four components, and they are worth separating because they do different things:

• Licence conditions on ING’s banking authority — the enforceable wrapper that makes everything else binding.
• Independent reviews, both into the cause of the liquidity reporting failures and into ING’s broader risk management and governance practices.
• A comprehensive remediation plan, with independent assurance that it is actually implemented rather than merely written.
• A $50 million operational risk capital add-on and increased minimum liquidity requirements, both of which remain in force until APRA is satisfied the work is complete.

APRA Deputy Chair Therese McCarthy Hockey framed the seriousness in terms of measurement rather than outcome: “When a bank cannot accurately measure one of its most important financial safeguards, it raises fundamental questions about the effectiveness of its risk management and controls.”

She also pre-empted the obvious misreading. “Although the bank remains well capitalised, and benefits from the financial strength of the broader ING group,” she said, “these breaches are not simply a reporting error.”

2. Reporting and controls — not credit

The distinction matters commercially, and it is the part most likely to get mangled in a hallway conversation.

Nothing in APRA’s action concerns ING’s loan book, its arrears performance, its serviceability settings or its credit standards. The Liquidity Coverage Ratio is a funding measure — broadly, whether a bank holds enough high-quality liquid assets to survive a defined short-term stress scenario. The failure APRA identified was that ING could not measure that ratio correctly, for years, and that its governance did not catch it.

It is also worth stating plainly what a supervisory action of this kind is not. Licence conditions and a capital add-on are prudential tools applied to an institution. They are not a finding of misconduct against any named individual, and they are not a court outcome.

ING self-reported. Chief Executive Melanie Evans said the bank regretted “that these deficiencies existed in our operations” and was “committed to meeting APRA’s expectations when it comes to standards of risk management, governance and regulatory reporting.”

3. Why the broker channel is uniquely exposed here

ING’s National Sales Manager, Sergio Delvescovo, told Mortgage Professional Australia in late August that brokers continue to originate more than 95 per cent of the bank’s home loans. That is not a marketing line; it is the operating model. ING built its Australian mortgage business through brokers rather than branches.

The scale is meaningful. On the most recent public figures available — reported by MPA from APRA data as at June 2025 — ING held a mortgage book of roughly $66.47 billion, making it the sixth-largest mortgage lender in the country behind the major banks and Macquarie. Those figures are more than a year old and should be treated as indicative of position rather than current size, but the ranking has been stable.

That cuts both ways, and brokers should hold both halves. A lender that depends entirely on brokers has every commercial reason to protect broker relationships through a remediation period, not to damage them. The exposure is not that ING abandons the channel. It is that a lender with a narrower set of levers has fewer places to make up ground.

4. The mechanism to watch — and the one not to over-read

Two of APRA’s four measures carry an ongoing cost rather than a one-off compliance exercise. Increased minimum liquidity requirements mean holding a larger buffer of high-quality liquid assets, which by design yield less than lending. A $50 million operational risk capital add-on ties up capital that would otherwise sit behind loan growth. Independent reviews and assurance work also consume senior management attention, which is a real constraint even when it does not appear in a margin line.

None of that tells you ING will reprice, tighten policy or slow down. Banks of this size absorb costs of this order regularly, and the parent group’s strength is part of APRA’s own framing. Predicting a repricing from an enforcement action would be exactly the kind of inference this article is arguing against.

What it does mean is that the lever set has narrowed slightly, and there are observable signals worth watching rather than guessing at:

• Deposit pricing. This is the most useful and most public tell. A bank rebuilding liquidity headroom typically competes harder for stable retail deposits. ING’s savings and term deposit rates are published, and a sustained move relative to peers says more about funding posture than any announcement will.
• The gap between new-business and back-book pricing. Widening discretion for new loans while existing customers drift is the classic signature of a lender buying volume; narrowing it is the signature of a lender protecting margin.
• Credit policy at the margins. Changes to maximum LVR, acceptable income types, or postcode and security restrictions usually arrive as quiet policy notes, not press releases.
• Turnaround times. Remediation programs pull operational resource. If assessment SLAs move materially, that is a service issue you can measure from your own pipeline before any lender tells you.
• Cashback and discretionary pricing authority. The first thing to soften when margin tightens is usually what a BDM can approve without escalation.

Watching those five things costs nothing. Acting on speculation about them costs clients.

5. The client conversation you should not freelance

Some clients will see a headline containing the words “bank”, “regulator” and “$50 million” and reach a conclusion. A smaller number will call you, because you are the finance professional whose number they have.

The accurate answer is short, and it belongs to APRA rather than to you: the regulator has stated that ING remains well capitalised and benefits from the financial strength of the broader ING group, and the action concerns the accuracy of the bank’s liquidity reporting and its risk controls. That is the whole of what has been established publicly.

Resist the temptation to go further in either direction. Speculating about a bank’s prudential health is not something a credit representative is licensed, resourced or insured to do, and reassurance you invent is a liability you keep. Point clients to APRA’s published statement and to ING directly for questions about their own accounts, and escalate anything unusual to your licensee. If a client wants to discuss their deposit arrangements specifically, that is a banking question for their bank, not a credit assistance question for you.

6. Where best interests duty actually sits in this

This is where a good instinct can produce a bad file.

The best interests duty under Part 3-5A of the National Consumer Credit Protection Act, and ASIC’s guidance in RG 273, governs the credit assistance you provide to a consumer. Brokers are not prudential analysts, and no part of this action changes ING’s standing as a lender on your panel or as an option you can recommend. Treating a supervisory action as a reason to stop recommending an otherwise suitable product would be a decision you would then need to justify on the file — not a safe default.

The genuinely BID-relevant moment is the ordinary one. If ING’s pricing or policy does move, and your recommendation consequently moves away from what would otherwise be the strongest option for that client, the file needs to show the reasoning at the time you gave it. That is the same discipline that applies every week; the only difference is that this is a period where the reasons may change faster than usual.

It is worth noting that ASIC’s targeted review of best interests duty compliance — the first since the duty commenced — has been underway since 2025, with findings expected later this year, according to MFAA reporting of ASIC’s update to the industry. File documentation is under more scrutiny than usual, which is an argument for consistency rather than for anything dramatic.

7. What to review on your desk this week

Most brokers have never actually calculated their lender concentration. It takes about twenty minutes and it is the only number in this article that is about your business rather than someone else’s.

On the concentration number itself, a working heuristic — an editorial rule of thumb, not a regulatory threshold or an aggregator standard:

8. What to watch next

• The scope and appointment of the independent reviews, and whether their findings are made public.
• Any variation, tightening or eventual removal of the licence conditions — APRA has said they stay until it is satisfied, with no published end date.
• ING’s deposit pricing relative to peers over the next two quarters.
• ING’s housing book growth in APRA’s monthly authorised deposit-taking institution statistics, which will show whether appetite has actually changed.
• Whether APRA broadens its supervisory attention to liquidity reporting accuracy across other authorised deposit-taking institutions.

Common questions

The bottom line

A bank misreported one of its core prudential measures for years and did not catch it. The regulator has responded with enforceable conditions, an ongoing capital cost and independent scrutiny, while stating plainly that the institution remains well capitalised. Those two facts sit together, and brokers should be able to hold both without flattening them into either alarm or indifference.

The reason this one lands differently in the broker channel is structural. When more than 95 per cent of a lender’s home loans arrive through brokers, brokers are not a segment of that lender’s exposure to change — they are effectively all of it.

Which makes the right response an unglamorous one. Find out what share of your settlements actually sit with one lender. Know who your second option is before you need them. Watch five public signals instead of speculating about one private balance sheet. And keep telling clients only what has actually been established. None of that is dramatic, and all of it is the difference between running a business that reacts to headlines and one that reacts to evidence.