Real Estate Finance (REF) is part of the Real Estate department at ING. The Finance department is responsible for financing the activities of the ING real estate department. Among other things, this includes issuing mortgages to real estate customers, entering into large-scale and other syndicate loans with other financial institutions, and consulting on and issuing 'special product' financing.

Proposition
Given that ING is a listed company in the United States, it must also comply with United States legislation. The Sarbanes Oxley (SOx) Act was created to stop the large-scale stock market scandals of the past from recurring in the future. The SOx Act requires all directors of listed companies to personally guarantee the correctness and completeness of the company’s annual figures to the NYSE.

Our role
The SPRING UNITED consultant was charged with the task of producing a detailed description of all processes, and publishing it at a central location (the process portal). SPRING UNITED also used its expertise to produce an overview of the risks and control measures of the most important processes. Work commenced with a thorough analysis of the processes described, in which the key risks were defined. For each key risk, one or more key controls were defined which purpose was to mitigate the key risk.
All processes, risks and controls were then set out in a Risk Framework. As part of the ‘In Control’ framework, periodic (monthly) ‘tests of effectiveness’ are carried out. These tests are the mechanism designed to monitor and ultimately prove that the controls have been effective, and that the company is ‘in control’.

Our added value
The process-based approach allowed Real Estate Finance to set up a comprehensive Risk Framework, easy to understand because it takes the processes themselves as the starting point. The managers of ING REF are up-to-date on the content of the controls, and can carry them out independently. The first test of effectiveness proved that the controls were effective, and allowed ING REF to issue its first SOx statement – In Control.