The International Monetary Fund has assessed financial supervision in the Netherlands against international standards of supervision. The IMF has found that the Twin Peaks model, dividing Dutch supervision of the financial markets between DNB and the AFM, has remained an effective supervisory model during the crisis. However, the IMF does suggest a number of essential changes to improve supervision.
An important suggestion is to enable supervisors to intervene at an earlier stage in the product development process. In addition, the IMF recommends providing supervisory authorities with wider powers in areas such as financial reporting.
With regard to the housing market and mortgage practice, the IMF notes that the loan-to-value ratio should be limited.
Finally, the IMF suggests further limiting the liability of financial supervisors to wilful misconduct and gross negligence.
These preliminary conclusions of the IMF have been endorsed by the AFM.