Financial Institutions and Financial and Economic Developments

The financial markets have recently experienced a more positive development, but they continue to be affected by the financial crisis. It has had a severe impact on the global economy, and international and Danish macroeconomic conditions have deteriorated significantly. The pace and strength of the economic slowdown have come as a surprise.

The financial crisis had a strong effect on the earnings of the Danish banks in the last six months of 2008, their total earnings only just remaining positive. Increasing write-downs on loans and negative value adjustments more than offset a strong improvement in the banks' core earnings that was attributable to rising lending margins.

The banks' lending growth decreased in 2008 and was negative in the 1st quarter of 2009.

Crisis sentiment in the financial markets

The turmoil in the financial markets culminated in the wake of Lehman Brothers' collapse in September 2008 when it became clear that extraor-

dinary initiatives were needed in order to restore confidence in the financial system. Governments worldwide therefore introduced various measures to support the financial sector and to mitigate the negative impact of the crisis on the real economy.

Equity markets continued to decline in early 2009. When the markets bottomed out at the beginning of March, European and US financial stocks were traded at less than 20 per cent of their worth in early 2007, cf. Chart 2. From the beginning of March to end-May, stock indices in Europe and the USA increased by about 30 per cent.

DEVELOPMENT IN BENCHMARK STOCK INDICES AND BANK INDICES Chart 2
Chart 2
Source: Bloomberg.

The increases by no means offset the total decline over the preceding eight months, however. On several occasions the global equity markets have reacted strongly to both rumours and actual measures to alleviate the financial crisis and its real-economic consequences. Besides, investors have had to consider the fact that governments have acquired substantial shareholdings in an increasing number of banks as a result of the recapitalisation packages launched by many countries, cf. Box 1.

OFFICIAL MEASURES TO STABILISE THE EU FINANCIAL SECTOR Box 1

As the financial crisis has evolved, governments around the globe have implemented various measures ("bank rescue packages") with the primary objective of mitigating the negative consequences of the crisis and preventing a negative spiral in the real economy. The EU has prepared guidelines for the design of government guarantees and recapitalisation to prevent the member states from favouring national interests and introducing measures that distort competition.

The first bank rescue packages, which consisted of temporary government guarantees for the banks' unsecured creditors, were introduced in the autumn of 2008 to stop the panic in the financial markets in the wake of Lehman Brothers' collapse. The mission was accomplished in part as it put a stop to the accelerating deterioration, particularly in the interbank markets.

However, these bank rescue packages did not solve the banks' problem in the form of increasing losses and provisions as a result of the financial crisis and the severe global economic slowdown. Several countries, including Denmark, were therefore compelled to give the banks access to borrow capital from the central government. One of the aims was to prevent the development of a credit crunch, i.e. a situation where creditworthy business enterprises and households are unable to obtain credit because the banks have to reduce their lending gearing (lending/capital).

The common denominator of the government guarantees and the possibility of capital injections has been that the authorities have sought to solve problems by securing the banks' liabilities side.

In a number of countries, it has also been necessary for the authorities to help the banks handle their troubled assets. Generally, the authorities have applied one of the following two models or a combination thereof:

  • ARS (Asset Removal Scheme): The bad assets are removed from the bank's balance sheet through sale or transfer to a separate institution ("bad bank"). Removing the bad assets from a bank's balance sheet releases internal resources, thereby enabling the bank to focus entirely on its sound activities.
  • AIS (Asset Insurance Scheme): The bad assets remain on the bank's balance sheet, but the bank can purchase government insurance against losses exceeding a certain amount. The bank no longer needs to worry about becoming insolvent on account of the bad assets. The advantage in relation to the ARS is that the loan stays where the expertise is. The disadvantage is that the bank does not achieve the psychological effect of getting "a clean slate", as the assets remain on its balance sheet.
The table below provides an overview of the stabilisation measures (temporary government guarantees, capital injections, acquisition/insurance of troubled assets) implemented by individual EU member states as at end-March 2009.
OFFICIAL MEASURES TO STABILISE THE EU FINANCIAL SECTOR
 
Temporary
government
guarantee
Possibility of
capital injections
Acquisition/
insurance of
troubled assets
Belgium    
Bulgaria      
Cyprus      
Denmark  
Estonia      
Finland  
France  
Greece
Netherlands  
Ireland
Italy  
Latvia    
Lithuania      
Luxembourg    
Malta      
Polen      
Portugal  
Rumania      
Slovakia      
Slovenia      
Spain  
UK  
Sweden  
Czech Republic      
Germany
Hungary  
Austria  
Note: "√ "indicates that the member state has implemented general measures in the area concerned. It should be noted that introducing separate measures for individual institutions, e.g. injecting capital into a single bank, does not constitute a general measure, and in such cases the field will be left blank.
Source: National authorities and the ECB.

Uncertainty in the financial markets remains high, but without the same sense of panic as in the autumn of 2008. In 2009, implied volatility indices for equities and interest rates fell back from the extremely high levels at the end of 2008 and are now comparable with previous periods of turmoil, cf. Chart 3.

implied volatility indices for equities and interest rates Chart 3
Chart 3
Note: Volatility in equity prices is the volatility in US equities, CBOE, VIX. Interest-rate volatility is Merrill Lynch Option Volatility Index, MOVE.
Source: Bloomberg.

 

The Danish money market

Conditions on the Danish money market deteriorated significantly during September and early October 2008. Due to the financial crisis, it was practically impossible for many banks to obtain anything other than very short-term financing. This is reflected in the considerable widening of the spread between collateralised and uncollateralised money-market lending that occurred over the summer and up to the adoption of the Financial Stability Act (Bank Rescue Package I, see Box 2), cf. Chart 4.

Costs and their distribution, Bank Rescue Package I Box 2

On 5 October 2008, the Danish Contingency Association concluded an agreement on financial stability (Bank Rescue Package I) with the Danish government. Under the agreement, the government provides an unlimited guarantee to all depositors and other unsecured creditors, exclusive of covered bonds (SDOs).

Overall, payments from the Danish Contingency Association under Bank Rescue Package I may constitute up to kr. 35 billion. This sum comprises a contingency fund of kr. 10 billion (own risk) to cover the losses of the Financial Stability Company (The Winding-Up company), a market-related guarantee commission to the Financial Stability Company of kr. 7.5 billion annually for two years and, if necessary, an increased guarantee commission of kr. 10 billion to cover further losses. The distribution of the banking institutions' payments under Bank Rescue Package I is determined by the Danish Contingency Association. The contribution from each banking institution is proportional to its share of the total base capital required for the activities comprised by the guarantee.

Participation in the government guarantee under Bank Rescue Package I is voluntary, but the great majority of Danish banking institutions have joined the scheme. This is positive, since the default of a Danish banking institution could have widespread consequences for all Danish banking institutions if foreign institutions lose confidence in the sector.

The effect of the government guarantee is evident from the banking institutions' financing costs. A selection of bond issues shows that the banking institutions pay a considerably low er price for issuance within than outside the government guarantee, cf. the Chart below.

Spread between bond and reference rates for selected Danish bonds
Note: The Chart shows secondary prices for bonds. The reference interest rate is CIBOR or EURIBOR.
Source: Danske Markets.

As a consequence of the adoption of Bank Rescue Package II, cf. Box 3, the Danish Act on Financial Stability has been amended. The amendment enables supplementary purchase of an individual government guarantee for non-subordinated unsecured debt and for loans issued for financing top-up collateral for institutions issuing SDOs and SDROs as well as Danish Ship Finance A/S. The individual government guarantee runs for up to three years and comprises loans issued on 31 December 2010 at the latest. Applications for individual government guarantees must be submitted by 31 December 2010.

1 For further details, see Financial stability 2008, 2nd half.

 

Spread between collateralised and uncollateralised 3-month money-market interest rates Chart 4
Chart 4
Source: Bloomberg.

In the autumn of 2008, uncertainty and increasing mistrust among the banks led to a significantly greater spread in very short-term interest rates with the day-to-day rate following Danmarks Nationalbank's official interest rates to a lesser extent than usual, cf. Chart 5.

Short-term money-market interest rates in Denmark,
and daily turnover in the Danish day-to-day money market
Chart 5
Chart 5
Note: The day-to-day interest rate is a turnover-weighted Tomorrow/Next interest rate. Daily turnover is a 5-day moving average.
Source: Danmarks Nationalbank.

Despite substantial fluctuations, the Danish money market has seen a significant reduction of the spread between uncollateralised and collateralised money-market interest rates in 2009 – from around 175 basis points in mid-January to around 100 basis points in late May, cf. Chart 5. Short-term money-market interest rates are again following Danmarks Nationalbank's official interest rates, and several banks are reporting easier access to liquidity. Nervousness in the market has decreased as a result of Bank Rescue Packages I and II, among other reasons, cf. Boxes 2 and 3, but market conditions remain far from normal. This is illustrated by the spread between collateralised and uncollateralised 3-month money-market interest rates in Denmark, which is still considerable despite the fact that uncollateralised loans are covered by the government guarantee until 30 September 2010.

THE CREDIT PACKAGE (BANK RESCUE PACKAGE II ) Box 3

On 3 February 2009, a bill on government capital injections into credit institutions was passed by the Folketing (Danish parliament). The purpose of the act is to recapitalise Danish credit institutions and to reduce the risk of a credit crunch.

Credit institutions that observe the statutory solvency requirements can apply to the government for injections of capital. The government injections are given in the form of hybrid core capital. If, on conclusion of the agreement, the hybrid core capital exceeds 35 per cent of the total Tier 1 capital, the Danish Financial Supervisory Authority may require that the capital be converted into share capital if the credit institution is in difficulties. Even if the hybrid core capital does not exceed 35 per cent of the Tier 1 capital on conclusion of the agreement, the central government and a credit institution whose shares have been admitted for trading on a regulated market may agree on an option for conversion on specific terms. This can be done if the hybrid capital exceeds 35 per cent of the Tier 1 capital, e.g. as a result of losses, at a later time.

Credit institutions receiving capital injections must subsequently have a Tier 1 ratio of at least 12 per cent. Individual solutions may be negotiated in special cases, however. The credit institutions pay an interest rate reflecting the central government's risk on the institution concerned. The interest rate is expected to be approximately 10 per cent p.a. on average.

Capital injections are subject to conditions, including requirements regarding lending policy, executives' remunerations and dividend policy.
The scheme is intended to be temporary, and incentives are therefore given for redemption of the government capital, e.g. through rising interest payments in the event of increased disbursement of dividends and more expensive redemption after five years.

The deadline for applications is 30 June 2009, and the majority of large and medium-sized banks have already announced that they want to make use of the possibility to apply to the government for injections of hybrid core capital. If all credit institutions take full advantage of the offer, approximately kr. 100 billion in new hybrid core capital will be provided by the government – approximately kr. 75 billion to banking institutions and approximately kr. 25 billion to mortgage-credit institutes. In addition, kr. 20 billion will be made available under a new export loan scheme in Eksport Kredit Fonden.

It is in the interest of society that the banks accept the capital provided by the government to ensure continued financing of sound projects, thereby supporting growth in the Danish economy. At the same time, the banks have an interest in capitalising themselves to provide extra financial cushioning. A characteristic feature of capital is that it is hardest to obtain when it is needed the most. Consequently, those credit institutions that have not yet announced whether they are going to apply should seriously consider accepting the capital that is made available. In an uncertain world it is an advantage for banks to have extra buffers against any future losses.

The offer of government capital injections and the option of paying guarantee commission in shares under Bank Rescue Package I open up for potential government ownership of credit institutions. Government ownership should be temporary, and the shareholding sold once market conditions normalise and the sale can be effected in good order.

As regards the development in the Danish money market compared with the development in the euro area, the narrowing of the spread between collateralised and uncollateralised money-market interest rates in Denmark has been slower and less smooth than in the euro area, cf. Chart 4. The Danish spread is almost twice as wide as in the euro area.

Apart from a few periods, the banks' daily turnover of uncollateralised day-to-day lending was stable in both 2008 and during 2009 to date and at more or less the same level as in 2007, cf. Chart 5. The banks generally reduced the volume of their money-market transactions, but due to the crisis the money market has seen a shift towards shorter-term loans.

The decline in money-market transactions has been offset by a significant increase in Danmarks Nationalbank's monetary-policy operations (sale of certificates of deposit and granting of monetary-policy loans), cf. Table 7 in the Appendix of Tables.

Nationalbankens kreditgivning

In order to ease the problems in the money market, Danmarks Nationalbank has introduced new temporary credit facilities several times since May 2008. This has led to a significant relaxation of Danmarks Nationalbank's extension of credit to banks and mortgage-credit institutes compared to the framework for credit operations that applied prior to the onset of the crisis, cf. Box 4.

DANMARKS NATIONALBANK'S GENERAL FRAMEWORK FOR CREDIT OPERATIONS Box 4

Danmarks Nationalbank grants 7-day loans and intraday credit in Danish kroner to banking institutions and mortgage-credit institutes against approved securities of high credit quality as collateral. Securities pledged as collateral consist predominantly of Danish government securities, mortgage-credit bonds and covered bonds (SDOs).

The eligible assets must be denominated in Danish kroner or euro. In addition, they must be registered in VP Securities and traded on NASDAQ OMX Copenhagen.

Furthermore, Danmarks Nationalbank also provides access to intraday credit in euro against collateral in largely the same securities. For credit in euro the securities must also meet a rating requirement stipulated by the ECB.
The collateral value of the securities is calculated as their market price less a securities-specific haircut. When euro securities are pledged as collateral for credit in Danish kroner or vice versa, an additional exchange-rate haircut of 3 per cent is added.

On determination of haircuts, the securities are divided into four liquidity categories according to their negotiability. Within each category the haircuts of the securities depend on the type of coupon and remaining life as an indicator of price sensitivity to interest-rate changes.

The value of the securities pledged is calculated on a daily basis as the official price on NASDAQ OMX on the preceding day, including accrued interest. If a security has not been traded within the last five banking days, Danmarks Nationalbank operates with a theoretical price.

A detailed description of Danmarks Nationalbank's framework for credit operations is found at www.nationalbanken.dk under "Rules" and "Pledging of collateral".

The primary purpose of the new credit facilities is to prevent solvent banks from experiencing difficulties due to insufficient liquidity. This has been done by expanding the collateral base with securities that are not normally eligible as collateral for loans from Danmarks Nationalbank, and by offering uncollateralised credit where the credit line depends on the institutions' excess capital adequacy.

The expansion has also made it easier for banks to meet the statutory liquidity requirements.

Temporary credit facilities
Danmarks Nationalbank's framework for credit operations was adjusted for the first time in May 2008 when confidence among the institutions was still relatively high. The institutions had become reluctant to lend to each other, however, as they did not want to tie up liquidity in a money-market loan.

In view of this, Danmarks Nationalbank chose to approve a new type of securities, loan bills, as eligible collateral for loans. Every Friday, these securities, which must meet a number of standard terms, can be pledged as collateral for a 7-day loan from Danmarks Nationalbank. The rate of interest is Danmarks Nationalbank's lending rate plus a premium. The objective was to facilitate lending among the institutions. A banking institution can borrow by issuing a loan bill, and the institution buying the bill can raise liquidity by using it as collateral for a loan from Danmarks Nationalbank. As a result, the latter institution can also include the bill in its liquidity, cf. section 152 of the Danish Financial Business Act.

The loan bill scheme assumes that the banking institutions want to lend to each other. However, confidence among the banking institutions weak ened during the summer of 2008 as the scope of the problems in the financial sector became more apparent, and further measures were needed.

In September 2008, Danmarks Nationalbank introduced a new temporary credit facility. Banking institutions and mortgage-credit institutes were given access to borrow an amount depending on their excess capital adequacy, i.e. the difference between their base capital and capital need. The institutions must apply for this, and the governors of Danmarks Nationalbank decide whether to grant the loan. If an application is approved, the institution is granted a credit line equal to its excess capital adequacy less a margin of 1 per cent, but normally not more than kr. 800 million. Every Friday the institution can then borrow an amount within the credit line for seven days at the lending rate plus a premium. As is the case with the loan bills, the credit line can be included in the institution's liquidity.

Unlike the loan bill scheme, the solvency scheme is meant for loans raised directly from Danmarks Nationalbank. The purpose of the latter scheme is to prevent banking institutions with adequate capital from incurring liquidity problems as a result of insufficient assets that can be pledged as collateral to Danmarks Nationalbank. We have no knowledge of any similar schemes in other central banks.

In addition to the solvency scheme, Danmarks Nationalbank expanded the temporary collateral base with quoted shares, investment fund shares and loans issued for financing top-up collateral for covered bonds (known as SDOs in Denmark) and – on request and based on Danmarks Nationalbank's concrete assessment – unquoted shares.

The expansion to include unquoted shares enabled the banking institutions to pledge shares issued by their jointly owned companies, e.g. PBS Holding A/S and VP Securities A/S as collateral. Furthermore, when calculating their liquidity, the institutions can now include these shares in line with liquid securities.

In June 2009, Danmarks Nationalbank expanded the collateral base with bank bonds and loans issued for financing top-up collateral issued in connection with SDOs that are guaranteed by the Danish government. The expansion included both bonds covered by the general government guarantee introduced with Bank Rescue Package I in October 2008, and bonds with individual government guarantees, cf. the Act to Amend the Act on Financial Stability.

The expansion with government-guaranteed bank bonds was a natural ad just ment of the collateral base. Quoted shares in banking institutions were already eligible for lending. The expansion also aimed to promote interest in these bonds, thereby supporting long-term market-based loan financing.

The temporary credit facilities will run until 30 September 2010. The expansion of the collateral base with government-guaranteed bank bonds and loans issued for financing top-up collateral in connection with SDOs will apply until 31 December 2013, however.

Use of the credit facilities
The temporary credit facilities at Danmarks Nationalbank have been used only to a limited extent. This is mainly attributable to the government guarantee under Bank Rescue Package I which came into force in October 2008. As a result of that package, the banking institutions started lending to each other in the money market again, and the need to borrow from Danmarks Nationalbank has been modest.

At the end of April 2009, Danish banking institutions had issued loan bills to other institutions amounting to approximately kr. 6 billion. Similarly, credit lines based on excess capital adequacy totalling kr. 14 billion, distributed on 35 banking institutions, had been granted. No institutions have borrowed against loan bills or raised loans under the solvency scheme.

Use of the expanded collateral base has also been limited. At the end of April 2009, 18 Danish banking institutions and mortgage-credit institutes had pledged shares, etc. for approximately kr. 3 billion. While the majority were quoted shares, the institutions had pledged unquoted shares for approximately kr. 1 billion as collateral.

These figures concerning the use of the temporary collateral base should be seen in relation to a total value of assets pledged as collateral to Danmarks Nationalbank at the end of April 2009 of kr. 332 billion. The usual eligible assets thus continue to account for the vast majority of the assets pledged as collateral for loans from Danmarks Nationalbank.

Nevertheless, the temporary credit facilities have been of major importance for the liquidity of several banking institutions. Not least the solvency scheme, which has helped individual banking institutions to meet the liquidity requirements under section 152 of the Danish Financial Business Act.

In addition, the schemes may have contributed to capping the borrowing costs of some banking institutions. A banking institution that wants to borrow from another institution can refer to what it would cost to borrow the amount from Danmarks Nationalbank, e.g. via the solvency scheme. As a result, the institution will not normally borrow from another institution at a higher interest rate.

Use of the normal collateral base
The normal collateral base for loans from Danmarks Nationalbank consists predominately of Danish bonds of high credit quality. When calculating the collateral value, the bonds are divided into four liquidity categories depending on their negotiability. Chart 6 shows the distribution of the securities pledged on those categories.

Breakdown of collateralised bonds by liquidity categories Chart 6
Chart 6
Note:The principles for breakdown of bonds pledged as collateral by liquidity categories can be found at www.nationalbanken.dk under Rules/Pledging of collateral.
Source:
Danmarks Nationalbank.

Banking institutions and mortgage-credit institutes pledge government securities (liquidity category I) as collateral only to a limited extent. At the end of April 2009, the institutions had pledged government securities for only approximately kr. 10 billion as collateral. Instead, the institutions mainly provided mortgage-credit bonds and SDOs as collateral (liquidity categories II and III). This distribution primarily reflects that liquid government securities are more acceptable in the private lending market than mortgage-credit bonds and SDOs. The banking institutions and mortgage-credit institutes therefore prefer to reserve their government securities for the private lending market and to pledge their less liquid mortgage-credit securities as collateral to Danmarks Nationalbank.

The international economy

The global economic recession has intensified over the last year, and the world economy is experiencing its worst post-war setback.

The crisis has had a severe effect. Considerable loss of wealth as a result of falling stock indices and housing prices has reduced consumer and business confidence, leading to a general slowdown in demand. Households and the corporate sector are finding it more difficult to obtain credit, which exacerbates the setback. In addition, unemployment is rising rapidly around the globe.

The global economic slowdown is reflected e.g. in a large decrease in industrial production and international trade in 2008, but in the spring of 2009 there have been certain indications of a stabilisation. The economic development remains a matter of considerable uncertainty, however

The Danish economy

The Danish economy had been slowing down for some time, but even more so in the latter part of 2008. GDP fell by 1.1 per cent in 2008, so that growth was negative for the first time in 15 years. In Denmark, too, there are indications that the economy is stabilising, but the development is not unequivocal and uncertainty remains high.

Both domestic and – as a result of the global economic slowdown – foreign demand for Danish products have declined. Private consumption shows a downward trend although real disposable incomes have risen considerably. The decline in private consumption should be viewed in the light of negative consumer expectations and decreasing wealth, including home equity, due to falling housing prices and stock indices.

An increasing number of enterprises are having difficulties coping with the downturn, resulting in a rise in the number of failures. The last months have seen the highest number of compulsory liquidations since the statistics were published for the first time in 1979, cf. Chart 7. The economic slowdown has also had a severe impact on the labour market with unemployment rising by more than 30,000 person in the first four month of 2009 alone.

Compulsory liquidations in the non-financial sector and enforced sales chart 7
Chart 7
Note: The Chart shows seasonally adjusted monthly data for the number of compulsory liquidations. Enforced sales have not been seasonally adjusted.
Source: Statistics Denmark.

The housing market and enforced sales
House prices fell during 2008 and into 2009. At the national level, cash prices of single-family and terraced houses have declined by 12 per cent since the peak in the 2nd quarter of 2007, cf. Chart 8. Prices in the Copenhagen area have tumbled by approximately 25 per cent during the same period, while the trend has been more moderate for the rest of Denmark overall. The prices of owner-occupied flats have fallen by even more than those of single-family and terraced houses. In general, the areas most severely affected are those where the rate of price increase was most rapid prior to the reversal, and where the price per square metre is highest.

Housing prices and homes for sale chart 8
Chart 8
Sourcee: Association of Danish Mortgage Banks and Danish Association of Chartered Estate Agents, www.boligsiden.dk.

The number of owner-occupied homes for sale remains high, and sales for the 1st quarter of 2009 were at the lowest level since the statistics began in 1995. The total number of homes for sale masks different development trends for different parts of the market. Since mid-2007, the number of owner-occupied flats for sale has fallen by 30 per cent, while the supply of single-family and terraced houses has increased by 36 per cent. This may indicate that the price adjustment process for owner-occupied flats may be complete, while the prices of single-family and terraced houses are likely to decrease further. A major factor behind the housing market situation is expectations of further price drops.

The negative trend in the housing market is also reflected in the increasing number of enforced sales, cf. Chart 7. The level remains low in a long-term perspective, however, which should be viewed in the light of a sustained low rate of unemployment.

The financial institutions

Strong decline in bank earnings in 2008
The financial crisis really impacted on the banks' earnings in 2008, especially in the 4th quarter. The total profits of banks in groups 1 and 2 fell from kr. 31.3 billion in 2007 to kr. 0.4 billion in 2008 (see Box 5 for a description of the groups). The lower earnings in 2008 are mainly attributable to write-downs on loans amounting to kr. 19 billion, corresponding to a weighted write-down ratio of 0.8. Capital losses of kr. 5 billion, the majority on equities, also contributed to the decrease in earnings. On the other hand, net interest income increased by kr. 10 billion due to higher lending margins and increased lending.

Overview of financial institutions in the report Box 5

The Danish financial sector is dominated by a few large groups whose activities and earnings cover various financial business areas. Banking is by far the largest and most important business area in relation to financial stability. Danish banks are sometimes parent companies, sometimes subsidiaries in groups comprising other financial enterprises too.

Ownership and the chosen group structure affect the earnings and risk profiles of the individual banks. Typically, most of a group's excess capital adequacy is held by the parent company, from which it is easiest to channel the funds to any parts of the group that need further capital. Consequently, subsidiaries often have lower capital adequacy in relation to risks. On the other hand, an assessment of a parent company must take into account that its capital adequacy must to some extent also hedge unexpected losses in subsidiaries.

The mortgage-credit institutes provide credit to finance real estate, which makes them the largest bond issuers in Denmark. The development in the mortgage-credit institutes may have a direct impact on the banks via group structures and cooperation agreements or an indirect impact in that the mortgage-credit institutes compete with the banks in the home-financing market.

Life insurance companies manage considerable assets and can thus impact price formation in the financial markets. They, too, can have a direct impact on the banks via group structures.

Mortgage-credit and life insurance activities are undertaken by special institutions and subject to special rules aimed at mitigating risk.

Asset management, including running investment associations, is assessed to be an area with limited risk for the banks and little impact on financial stability. The risk of investment losses as a result of changing market conditions is typically borne by the customer.

The analyses in this report focus on banks in the Danish Financial Supervisory Authority's groups 1 and 2 (banks with working capital of at least kr. 10 billion) that observed the statutory requirements for solvency, liquidity, etc. at end-2008. The analyses thus comprise 14 Danish banks as well as the mortgage-credit institutes and life insurance companies affiliated with the selected
Danish banks, cf. the Table below. FIH Realkredit has however, been omitted as its activities are being phased out.

Danske Bank and Nordea Bank Danmark belong to large groups with activities in most of the Nordic region, the Baltic states and a few other countries. In a group context, they are therefore compared with similar Nordic banking groups.

At end-2008, banks comprised by the report accounted for 93 per cent of the balance-sheet total of the Danish banks and had a market share of 77 per cent of total bank lending in Denmark.
Note that the data in this report concerning bank-specific information such as return on equity, lending growth, etc. is not immediately comparable with the data in Financial stability 2008, since e.g. Roskilde Bank and Fionia Bank are no longer part of the population, cf. Box 6.

Banks in the Danish Financial Supervisory Authority's groups 1 and 2, affiliated mortgage-credit institutes and life insurance companies, and Nordic groups
aktivities in denmark
 
Banking
Mortgage credit
Lif Insurance
Group 1
Danske Bank
Danske Bank
Realkredit Danmark
Danica
FIH Erhvervsbank
FIH Erhvervsbank
FIH Realkredit
Jyske Bank
Jyske Bank
Nordea
Nordea Bank Danmark
Nordea Kredit
Nordea Liv & Pension
Sydbank
Sydbank
 
Group 2
Alm. Brand
Alm. Brand Bank
Alm. Brand Liv og Pension
Amagerbank
Amagerbanken
Arb.Landsbank
Arb.Landsbank
Nykredit
Nykredit Bank
Nykredit
 
Forstædernes Bank
Totalkredit
Ringkjøbing Landbobank
Ringkjøbing Landbobank
Roskilde Bank
Roskilde Bank
Spar Nord Bank
Spar Nord Bank
Vestjysk Bank
Vestjysk Bank
Antal Number of institutions
14
5
3
Nordic groups
Danske Bank
DnBNOR
Nordea
SEB
Svenske Handelsbanken
Swebank
Note: Nordea Liv & Pension is part of the Nordea Bank AB group. FIH Realkredit has been omitted as its activities are being phased out. Roskilde Bank and Fionia Bank are no longer part of the population, cf. the above and Box 6.
Source: Financial statements.

Write-downs on loans accelerated throughout 2008. In the 4th quarter alone, write-downs on loans amounted to kr. 14 billion, equivalent to a weighted write-down ratio of 0.6 in that quarter for the banks in groups 1 and 2 overall. In group 2 alone, the average weighted write-down ratio was 1.2 in the 4th quarter of 2008. Several banks reported that the write-downs primarily concerned loans to financial institutions and corporate customers, while the write-downs on private customers remained limited. The write-down ratio was reduced for both groups in the 1st quarter of 2009, cf. Chart 9.

Quarterly Write-downs Chart 9
Chart 9
Note: Group-level data is exclusive of Nordea Bank Danmark and Arbejdernes Landsbank.
Source: Danish Financial Supervisory Authority and annual and quarterly financial statements.

In 2008, the return on equity before tax for the banks in groups 1 and 2 fell to 2.2 per cent and -11.9 per cent, respectively, against 18.3 per cent and 18.0 per cent in 2007, cf. Chart 10. Increased write-downs on loans were the major reason for this. The average return on equity after tax at the end of 2008 was 1.9 per cent for group 1 and 8.8 per cent for group 2.

Return on equity before tax chart 10
Chart 10
Note: Return is calculated on the basis of an average of equity and the beginning and end of the year.
Source: Financial statements.

The financial statements published for the 1st quarter of 2009 show improved earnings capacity compared with the 4th quarter of 2008. The improvement is mainly attributable to fewer write-downs and positive value adjustments.

The recent decline in earnings, tight liquidity conditions, etc. have contributed to a growing number of banks being subject to winding-up, mergers or acquisitions, cf. Box 6. Strong lending growth and considerable exposure to the property sector are among the characteristics of the banks that experience difficulties.

Changes in the Danish banking sector in 2008 and early 2009 Box 6

In 2008 and the first few months of 2009, the number of independent banking institutions in Denmark was reduced by 18. This is the result of mergers, acquisitions and winding-up, to some extent as a direct consequence of the financial crisis. A chronological review of events during the last 17 months is provided below.

Banking institutions under the Financial Stability Company or acquired by the Danish Contingency Association
In 2008 and early 2009, five banks have concluded agreements with or been acquired by the Danish Contingency Association or the Financial Stability Company (The winding-up company).

August 2008: On 24 August 2008, Danmarks Nationalbank and Danish Contingency Association acquire the assets and liabilities of Roskilde Bank (balance sheet kr. 37 billion), except its subordinated loan capital and hybrid core capital. At end-September most of Roskilde Bank's branch network is sold to Nordea (9 branches), Spar Nord Bank (7 branches) and Arbejdernes Landsbank (5 branches). The remainder of Roskilde Bank, primarily corporate customers, is still being wound up.

November 2008:
On 13 November 2008, ebh Bank (balance sheet kr. 10 billion) announces that it no longer observes the statutory solvency requirement. The bank is acquired by the Financial Stability Company and is still being wound up. Most branches of ebh Bank were sold to other small banking institutions during the spring of 2009.

February 2009:
In February, Fionia Bank (balance sheet kr. 33 billion) has to acknowledge that its solvency ratio is below its individual capital need. On 23 February, Fionia Bank concludes a framework agreement with the Financial Stability Company concerning financial support. Under the agreement, Fionia Bank establishes a new bank to which all assets and liabilities of the old bank are transferred, with the exception of share capital and subordinated capital. The Financial Stability Company owns one share in the new bank, while the old bank owns the rest. The old bank pledges its shares and the attached voting rights to the Financial Stability Company, which thus controls the new bank and continues its activities. The Financial Stability Company undertakes an obligation to strengthen the capital base of the new bank by injecting subordinated capital of approximately kr. 1 billion, after which the solvency ratio of the new bank is approximately 13 per cent. The Board and Management and shareholders of the old bank continue in the new bank.

March 2009:
Following a series of write-downs in 2008, mainly on large property exposures, Løkken Sparekasse (balance sheet kr. 2 billion) no longer meets the solvency requirement. After having sought in vain for a partner to merge with, Løkken Sparekasse on 2 March 2009 enters into a framework agreement with the Financial Stability Company. The bank transfers all assets and liabilities to the Financial Stability Company, except the guarantee capital of kr. 170 million. The Financial Stability Company has subsequently concluded an agreement with Nordjyske Bank on sale of the core activities of Løkken Sparekasse – the bank's green part – as of 1 April 2009.

April 2009:
On 16 April 2009, Gudme Raashcou Bank (balance sheet kr. 6 billion) enters into a framework agreement with the Financial Stability Company, after having sought in vain to strengthen its capital base for some time. The bank's non-observance of the solvency requirement is attributable to considerable write-downs on its property exposures. Under the agreement, all the bank's assets and liabilities, except share capital and subordinated capital, are transferred to the Financial Stability Company.


The transfer sum is kr. 0 with the option to adjust it at a later date. As of 1 June 2009, Lån og Spar Bank has acquired all of Gudme Raaschou Bank's asset and portfolio management activities, as well as a small lending and deposit portfolio. At the same time, Lån og Spar Bank acquires the goodwill and the intangible rights related to the activities acquired, including the name of Gudme Raaschou Bank. The bank's activities within mortgage deeds are transferred to a newly established subsidiary of the Financial Stability Company.

Mergers and acquisitions in the Danish banking sector in 2008 and early 2009

January 2008:
Financial problems in bankTrelleborg (balance sheet kr. 8 billion) lead to merger with Sydbank (kr. 132 billion).

February 2008:
Sparekassen Himmerland (balance sheet kr. 10 billion) merges with St. Brøndum Sparekasse (balance sheet kr. 0.1 billion) as of 1 January 2008.

February 2008
: Folkesparekassen acquires JAK Andelskasse Rødding. Total balance sheet after the merger: kr. 0.4 billion.

March 2008
: Sparekassen Sjælland (balance sheet kr. 11 mia.kr.) acquires Haarslev Sparekasse (balance sheet kr. 0.2 billion).

September 2008:
Vestjysk Bank (balance sheet kr. 20 billion) acquires Bonusbanken (balance sheet kr. 2 billion) on 29 September 2008. On the same day, the forthcoming merger of Vestjysk Bank and Ringkjøbing Bank (kr. 10 billion) is announced. The merger is effected as of 3 December 2008, making the new Vestjysk Bank the 9th largest banking institution in Denmark.

September 2008: Sparekassen Vendsyssel (balance sheet kr. 7.4 billion) acquires Ulsted Sparekasse (balance sheet kr. 0.4 billion) as of 1 January 2008.

October 2008
: Nykredit Realkredit (balance sheet kr. 1,104 billion) acquires Forstædernes Bank (balance sheet kr. 32 billion), which continues as an independent brand and company in the Nykredit group under the existing management.

October 2008
: Handelsbanken i Danmark, a branch of Svenska Handelsbanken AB (consolidated balance sheet kr. 1,494 billion), acquires Lokalbanken i Nordsjælland (balance sheet kr. 6 billion).

October 2008
: Frøslev-Mollerup Sparekasse acquires Sparekassen Nordmors with accounting effect from 1 January 2008. Balance sheet after the merger: kr. 0.4 billion.

November 2008
: Morsø Bank (balance sheet kr. 4 billion) acquires the activities of Sparekassen Spar Mors (balance sheet kr. 0.7 billion), except its guarantee capital.

December 2008
: Sparekassen Hobro (balance sheet kr. 4.5 billion) acquires Den Lille Sparekasse (balance sheet kr. 0.5 billion) as of 1 January 2009.

February 2009:
Den Jyske Sparekasse (balance sheet kr. 10 billion) acquires Sparekassen Løgumkloster (kr. 1 billion).

Note: Figures in brackets indicate the balance-sheet total at the time of the merger/winding-up or the latest data available.
Source: Financial statements, stock-exchange announcements and press releases.

Reclassification of financial assets
With the European Commission's adoption of amendments to the International Financial Reporting Standards on 15 October 2008, banking institutions are now able to reclassify financial assets in rare cases. Reclassification entails that unrealised value adjustments on the assets in question will no longer affect the income statement. Depending on the category to which the asset is reclassified, the unrealised value adjustments will be entered as equity capital or just appear from the notes to the financial statement. For a further description of the various categories, see Box 4 "Reclassification of assets" in Financial Stability 2008, 2nd half.

A few Danish banking institutions chose to make use of this opportunity, thus considerably improving their earnings in 2008.

The argument for reclassification has been to remove part of the financial asset volatility from the income statement. It is worth noting, however, that the quality of the banking institutions' financial assets and thus the risk on individual assets did not change as a result of the reclassification. The reclassification option made it more difficult to compare the banking institutions' profits and return on equity as not all institutions have chosen to make use of it. Moreover, the institutions that did, chose to reclassify the financial assets to different categories with varying effects on their equity capital.

Reduced growth in lending
The decline in the banks' growth in lending in 2007 continued in 2008. Compared to the peak in 2005, the growth in lending for banks in both group 1 and group 2 decreased by more than 20 percentage points up to 2008, cf. Chart 11.

Growth in lending chart 11
Chart 11
Note: Adjusted for the effect of the recognition of Danske Bank's banking activities in the Baltic states as branches, Sydbank's acquisition of Bank Trelleborg, Nordea Bank Danmark's, Spar Nord Bank's and Arbejdernes Landsbank's acquisition of branches of Roskilde Bank, Nykredit Bank's acquisition of SEB's Hellerup branch and the merger of Vestjysk Bank and Ringkjøbing Bank. Growth in lending is calculated at year-end, i.e. growth in lending in 2008 is calculated as lending as at 31. December 2008 divided by lending as at 31 December 2007.
Source: Financial statements.

Adjusted for large acquisitions and take-overs, almost half of the banks saw negative lending growth in 2008. Only three banks experienced lending growth of more than 10 per cent, in one case primarily caused by growth in repo transactions.

The banks' financial statements showed negative lending growth for banks in groups 1 and 2 in the 1st quarter of 2009 compared with end-2008. The development in lending also reflects the banks' deposit deficits, which decreased in the 1st quarter, cf. Chart 12.

Deposit surplus (deposits less lending) chart 12
Chart 12
Source: Danmarks Nationalbank.

The weaker lending growth is in line with the credit managers' reports in connection with Danmarks Nationalbank's new lending survey, cf. Box 7. According to the survey, the banks will tighten their credit policies even further in the current quarter.

DANMARKS NATIONALBANK'S LENDING SURVEY Box 7

In January 2009, Danmarks Nationalbank published the results of the first Danish lending survey. The survey was inspired by similar foreign surveys conducted by the Federal Reserve, the Bank of Japan, the ECB, the Bank of England and Norges Bank, among others.

General information about the survey
The survey is conducted on a quarterly basis. The credit managers of a number of banking institutions and mortgage-credit institutes are asked to assess changes in the supply of and demand for loans in the current quarter, as well as expected changes in the coming quarter. Against that background, the survey illustrates changes in the institution's credit policies, i.e. whether it has become easier or more difficult for customers to obtain loans. At the same time it discloses the rationale for changing credit policies and the credit institutions' expectations for future developments in the credit market. The survey also deals with changes in the demand for loans on the part of current and new customers, the purpose being to distinguish whether changes in overall lending are governed by supply or demand. Finally, the survey reviews changes in write-downs and losses on outstanding loans. The survey may also include questions relating to topical issues.

The banking institutions in the Danish Financial Supervisory Authority's groups 1 and 2 and the five largest mortgage-credit institutes participate in the survey. In April 2009, this population covered 74 per cent lending to households and 84 per cent of corporate lending.

Most recent results
In the most recent survey from April 2009, the banking institutions and mortgage-credit institutes stated that they had tightened their credit policies further in the 1st quarter of 2009. The measures were less pronounced for households than for corporate customers. This development is in line with expectations in the previous quarter. The institutions mainly cite deterioration of the risk outlook as the underlying reason. The banking institutions and mortgage-credit institutes state that the risk assessment and the risk appetite contribute substantially to the tightening of their credit policies. Overall, they expect to tighten their policies further in the current quarter, albeit not as much as in the 1st quarter of 2009.

Most institutions report tightening credit policies in the form of higher margins and fees as well as increased collateral requirements. The mortgage-credit institutes did not change the credit conditions noticeably for households. The institutions expect increased prices and stricter collateral requirements in the coming quarter, especially for corporate customers.

The demand for loans is declining for both households and corporate customers, and a moderate increase in write-downs and losses on corporate exposures is expected in the current quarter compared to the 1st quarter of 2009.

Box 8 compares the development in a number of key parameters for the banking sector as a whole in 2008 with the period up to the onset of the crisis and with the period from 1991 to 2008. The comparison shows that the banks' lending growth was significantly higher up to the onset of the crisis than in the period from 1991 to 2008. In 2008, lending growth fell to below the average for 1991-2008.

DEvelopment in selected key parameters for the Danish banking sector Box 8

The Chart below shows selected key parameters for the Danish banking sector in the period 1991-2008 and 2005-07 and in 2008.

Prior to the financial crisis, the Danish banking sector was characterised by a rising ratio of lending to deposits and increasing lending gearing, measured as the ratio of lending to equity capital, cf. the Chart below. Compared with the average for the growth years 2005-07, the banks reduced their lending growth considerably in 2008. However, the sector average masks considerable differences between the banks in the population. Lending growth has also been reduced when compared with the average for the period 1991-2008.
The exposure to the property market, measured as lending to the property market as a percentage to total loans and guarantees was reduced in 2008 and is now in line with the average for the period 1991-2008.

Total large exposures as a percentage of base capital was reduced in 2008 compared with the average for the other two periods; this indicates a declining concentration risk.

Excess capital adequacy, measured as the difference between the base capital and the minimum capital requirement as a percentage of loans and guarantees, rose slightly in 2008 compared with the average for the other two periods. This calculation does not take into account the individual capital need, which exceeds 8 per cent for a number of banks, cf. the section on the banks' solvency.

In summary, the Chart shows that in 2008 several key parameters for the banks were brought more in line with the average for the period 1991-2008.

Development in selected key ratios for the Danish banking sector

Note: The population is 47 banks from the Danish Financial Supervisory Authority's groups 1-3. Lending gearing is lending as a ratio of equity capital. Large exposures correspond to the Danish Financial Supervisory Authority's key ratio by the same name. The sector average for large exposures is for the period 2003-08 rather than 1991-2008. Lending growth is the average annual growth rate. Property loans are defined as loans and guarantees to the building and construction sector and property administration, etc. The excess capital adequacy is the excess cover as a percentage of loans and guarantees, and the sector average is for 1993-2008 rather than 1991-2008.
Source: Financial statements and own calculations.

In addition to deposits, the banks in group 1 primarily rely on issuance of debt securities with maturities of more than one year for financing, cf. Chart 13. The share of debt securities issued with maturities of less than one year has increased since September 2008, while debt to other credit institutions has fallen.

Net debt to other credit institutions, and debt securities issued chart 13
Chart 13
Note: Exclusive of foreign branches and subsidiaries.
Source: Danmarks Nationalbank, MFI statistics.

The source of financing for group 2 banks has changed over the last year to the effect that they are now relying more on issuance of debt securities and less on debt to credit institutions. Nevertheless, short-term debt to other credit institutions still remains the primary source of financing in group 2.

Amended rules drive the increase in the banks' solvency ratio
For most Danish banks, the transition to the new capital-adequacy rules (Basel II) in early 2008 meant reduced capital requirements in Danish kroner due. This is because Danish banks are primarily exposed to retail customers and small and medium-sized enterprises, which are given lower risk weights in the new risk calculation. Institutions using the IRB (Internal Ratings-Based) approach to calculating credit risks, of which most are found in group 1, experienced the largest reduction in risk-weighted items.1 This explains the strong increase in the solvency and Tier 1 ratios of the group 1 banks in 2008, cf. Chart 14. The fact that the solvency and Tier 1 ratios are higher in 2008 than in previous years thus reflects primarily the decrease in the risk-weighted assets due to a changed calculation method and not that the banks have obtained more capital. The lower solvency and Tier 1 ratios in 2008 for medium-sized banks in group 2 are mainly attributable to a single institution with a very strong increase in repo lending and thus risk-weighted assets.

solvency and tier 1 ratios chart 14
Chart 14
Note: The estimated capital injections are based on preliminary announcements in the banks' financial statements and in the press, i.e. only banks that have explicitly stated that they will apply for capital have been included. Capital injections cover banks only, not affiliated mortgage-credit institutes. Capital will be injected in 2009, but is shown in the Chart for 2008.
Source: Financial statements.

A further reduction of risk-weighted items for the IRB institutions occurred at the turn of the year 2008/09 when the transitional arrangement, under which these institutions are subject to a higher capital requirement for a transition period, was reduced.2 The new capital-adequacy rules will not be fully implemented until 2010. The purpose of the transitional arrangement has been to prevent a large one-off decrease in the banks' capital requirements.

The injections of hybrid core capital via Bank Rescue Package II will strengthen the banks' capital position. In the financial statements from the 1st quarter of 2009 and subsequent press releases, most banks in the population have indicated the capital injection they will apply for. If the capital had been injected at the end of 2008, the solvency and Tier 1 ratios would be 2.2 percentage points higher for group 1 banks and 3.6 percentage points higher for group 2 banks, corresponding to a total capital injection of just over kr. 40 billion.3 The deadline for applications is 30 June 2009.

The banks' buffers
The difference between a bank's actual capital and its capital requirement constitutes the excess capital adequacy or buffer available to cover negative earnings, including losses on loans. A bank's actual capital is reflected in the solvency ratio, while the capital requirement is expressed by the individual capital need (minimum 8 per cent of the risk-weighted items). The capital need reflects the bank's assessment of the capital required to cover its total risks. Among other factors, this individually calculated capital need should take into account any deterioration in the credit quality of exposures that are not included in the write-downs. Consequently, as it is based on a number of estimates and assessments made by the management of the institution, the calculation cannot be made unequivocally.

In the 2008 financial statements very few banks published their individual capital needs. The adoption of Bank Rescue Package II empowered the Danish Financial Supervisory Authority to lay down more detailed rules on disclosure of the banking institutions' and mortgage-credit institutes' individual capital needs and any higher solvency requirement stipulated by the Danish Financial Supervisory Authority. The institutions will therefore be required to disclose information about their individual capital need.

The development in the banks' excess capital adequacy/buffer depends on the size of the individual capital need and the effect of the transitional arrangement, cf. Chart 15. According to the Danish Financial Supervisory Authority, the excess capital adequacy of the banking institutions is 3 per cent of loans and guarantees.4 This means, cf. Chart 15, that the average individual capital need is close to 10 per cent, and that the banking sector has become more vulnerable to losses over the past year. These aggregate figures mask considerable dispersion across the sector.

Development in bank buffers chart 15
Chart 15
Note: Up to and including 2004, provisions were split into 'A' and 'B' provisions, the former being assumed to have a certain buffer effect. This buffer effect does not exist in write-downs under IFRS. The Chart is based on all banks in the Danish Financial Supervisory Authority's groups 1-3.
Source: Danish Financial Supervisory Authority and financial statements.

If the banks' excess capital adequacy at a 10-per-cent capital need were to be increased to 4.3 per cent of loans and guarantees, which is the level at a capital need of 8 per cent, the banks, other things being equal, would have to reduce their total loans and guarantees by just under one third.

It should be noted that the above calculations do not take into account the fact that the supplementary capital must not be included at more than 100 per cent of the Tier 1 capital, and the buffer at a low level of Tier 1 compared to the capital base may consequently be eroded more quickly than in the calculation, cf. Box 16 in the chapter on the banks' resilience.

In 2008, accumulated write-downs rose to 1.6 per cent of loans and guarantees, which is the highest level since the introduction of the new accounting rules.

The existing capital-adequacy rules have been criticised for being procyclical. During an upswing, when the risk is considered to be limited, the capital requirement will tend to fall. This allows the banks to increase their lending. On the other hand, lending will decrease and the capital requirement increase during economic downturns, when the risk is considered to be high. This means that the new capital-adequacy rules (Basel II) reinforce cyclical developments and have a negative impact on financial stability.

Limiting procyclicality is one of the central aims of a number of initiatives launched in response to the crisis (for a review of international initiatives as a result of the crisis, see Box 9).

REGULATORY AND SUPERVISORY INITIATIVES AS A RESULT OF THE crisis Box 9

In the wake of the financial crisis, the authorities, international collaborative organisations and the financial sector have launched proposals and initiatives to address problems in the financial sector and to prevent a repetition of the crisis. The Ecofin road map was adopted within the EU in the autumn of 2007, and in April 2008, the Financial Stability Forum (FSF) presented its 67 recommendations.1 In February 2009, the EU published the de Larosière Report2 with a number of new proposals, and in April 2009, the G20 countries followed up on the action plan announced in November 2008.

This box describes the principal initiatives. The points of departure are the relatively new G20 initiatives and the European Commission's proposal for strengthened oversight and macroprudential supervision within the EU. Denmark is not a member of the G20, but takes part in the formulation of the common EU position. Eventually, discussions in the various international forums are presumed to lead to consensus on the necessary measures. The details of this consensus will lead to amendments to EU law that must be implemented in Danish law.

Capital requirements, etc. The crisis has shown that the banks' capital is inadequate in relation to the risks they incur. Building up capital in good times is necessary in order to have a buffer that can be used in economic downturns. The crisis has also demonstrated the import ance of the capital structure, cf. Box 16. As a consequence, it is internationally agreed that there is a need for more and better capital as well as measures to counter procyclicality. There is also agreement that the international standards for the minimum capital require ment should not be changed until the crisis is over. Stricter requirements at present would only increase the risk of unwanted deleveraging and reduction of the banks' lending.

Looking ahead, it is also necessary to limit strong growth in the banks' balance sheets during upswings, e.g. by supplementing the Basel II capital requirements with a simpler target for gearing.

According to its communication of 4 March 2009, the European Commission will present its proposals regarding capital adequacy in the autumn of 2009.

Liquidity.
One of the weaknesses of the current regulation, which has become apparent since the onset of the crisis, is insufficient requirements in the liquidity area.

The Basel Committee on Banking Supervision, BCBS, and the Committee of European Banking Supervisors, CEBS, issued new recommendations in this area already in June 2008. The amendments to the EU Capital Requirements Directive 3 adopted in May 2009 are based on those recommendations. The amendments to the Directive include requirements for the credit institutions' strategies and systems to manage and measure liquidity risks over various time horizons, including intraday. In addition, the boards are required to define a tolerance level for liquidity risks. At the same time the requirements regarding the regulatory supervision of liquidity risks and management have been extended.

In April, the G-20 countries agreed on the need to strengthen the liquidity buffers of financial institutions, and further measures are expected in this area.

Accounting rules, including rules concerning provisions and fair value
. In 2005, it became mandatory for European groups to present their financial statements in accordance with the International Financial Reporting Standards, IFRS. This implies that in connection with pricing of assets and liabilities, the banks should primarily apply fair value rather than historical cost prices.4 Under the "fair value" principle, the values of assets and liabilities are stated at current market prices when they are available, whereas model calculations are used when no current market prices are available. The approach to provisions was also changed from making provisions for probable losses to a principle of objective indication of a loss.

Since the onset of the crisis, both the new approach to provisions and the valuation methods have been criticised. The approach to provisions has been criticised for contributing to the banks facing a economic downturn with inadequate provisions. The fair value method has been criticised for forcing the banks to recognise losses on shares and bonds which critics attributed to an overreaction in the financial markets. According to critics, this forced banks to hold fire sales of assets to reduce their capital requirements. This has exacerbated the price falls, thereby leading to further losses.

There is broad international consensus that the crisis gives rise to a review of existing accounting rules with a view to improving the accounting standards, including rules concerning write-downs, reducing their complexity, etc. At the same time it G20 leaders reaffirmed the framework of the fair value accounting.
Extending regulation to all systemically important financial institutions, markets and products.
At their meeting in April, the G20 countries agreed to extend regulation to all systemically important institutions, including hedge funds. In this process it is important to focus on addressing weaknesses in the current regulation identified during the crisis.

In April 2009, the European Commission presented a proposal regarding regulation and supervision of alternative investment funds (proposal for a Directive on Alternative Investment Fund Managers). Alternative investment funds include hedge funds and private equity funds, among others. The proposed directive calls for minimum limits, to the effect that it will not apply to the administration of small alternative investment units.

Regulation, registration and supervision of credit rating agencies.
Credit rating agencies have been widely criticised, especially for their involvement in tailoring credit products that only just make it into the desired rating class. The agencies have had a strong financial interest in the development of the market for structured products – a major source of income – which has given rise to conflicts of interest.

The EU regulation on credit rating agencies, which was adopted in April 2009, contains requirements to apply for registration in the EU. The authorities should also supervise credit rating agencies, and a number of requirements are stipulated with regard to the agencies' handling of conflicts of interest, improvement of credit assessment quality and increased transparency.
In this connection the use of ratings for financial regulation is something that should be given thorough consideration. The Basel II rules gave the credit rating agencies ample opportunity to influence the capital to be held by a bank.

Corporate governance.
One of the areas highlighted by the crisis is remuneration in the financial sector and whether inappropriate remuneration structures have contributed to the sector's excessive risk appetite prior to the outbreak of the crisis. Consequently, there is international agreement on the importance of establishing principles/rules in this area.

In April 2009, the Financial Stability Forum, FSF, published "Principles for Sound Compensation Practices", and the European Commission issued a recommendation on remuneration policies in the financial services sector. In overall terms, it is important that remuneration in financial institutions is linked to long-term earnings adjusted for risks.

Oversight and macroprudential supervision. On 27 May 2009, the European Commission presented a proposal for a reform of micro-prudential supervision in the EU and a proposal for macroprudential supervision. The Commission's reform is based on recommendations from the report published by the de Larosière group on 25 February 2009.

The European Commission proposes a new supervisory architecture in the EU to strengthen the oversight of individual financial institutions. Three existing supervisory committees (CEBS, CESR and CEIOPS) will be replaced by the European Banking Authority, EBA, the European Insurance and Occupational Pensions Authority, EIOPA, and the European Securities and Markets Authority, ESMA. These agencies will take over the tasks of the existing supervisory committees and be assigned increased responsibilities and powers. They will be required to contribute to the development of harmonised rules, develop a common supervisory approach to institutions with cross-border activities and help settle any disagreements/disputes between national supervisory authorities. Further strengthening and coordination of the supervision of financial markets and enterprises is important. It should, however, be based on careful consideration of the distribution of competences between the national and European level.

The current crisis has demonstrated the need to strengthen macroprudential supervision. Several risks that have had major consequences for the development of the crisis were insufficiently identified by central banks and international organisations alike. In addition, neither the authorities nor the financial institutions responded to the risks identified before the outbreak of the crisis. The European Commission has therefore proposed the establishment of the European Systemic Risk Council, ESRC, which is to monitor and assess any threats to financial stability arising from macroeconomic developments and developments in the financial system in general. The ECRC will be charged with identifying risks, issuing warnings and recommendations and following up on the recommendations. ESRC membership will consist of central bank governors from the 27 EU countries and the ECB, the chairman of the Committee of European Banking Supervisors, cf. above, and a member of the European Commission. National supervisory authorities will have observer status.

1 See also Box 1, Danmarks Nationalbank, Monetary Review, 2nd Quarter 2008, page 6.
2
Report from the High-level Group on Financial Supervision in the EU. The Group's chairman is Jacques de Larosière.
3
Amendments to the EU Capital Requirements Directive also include rules on large exposures, hybrid capital, supervision of banking institutions with cross-border activities, and risk management of securitised products.
4
Under the "fair value" principle, the values of assets and liabilities are stated at current market prices, and model calculations are used when such prices are unavailable.

Sensitivity analysis – reduced resilience in 2008
A static sensitivity analysis, based on the banks' earnings and capital structure, shows that their resilience was reduced from 2007 to 2008, cf. Chart 16. At the baseline – the banks' actual financial result before sensitivity analysis – 7 out of 14 banks had deficits in 2008, whereas all banks posted profits in 2007.

Sensitivity analysis chart 16
Chart 16
Note: The banks have been listed in random order. Losses on lending in the sector have been distributed on the individual banks in proportion to their credit-risk measures.
Source:Financial statements and own calculations.

It appears that, other things being equal, only one bank's earnings in 2008 would have been sufficient to cover rising financing costs on loans of 1.5 percentage points. In 2007, 10 banks would have been able to cope with a similar scenario.

A loss corresponding to 10 per cent of the sum of large exposures would have resulted in deficits in 10 banks in 2008 (against six in 2007), and in two cases the base capital would have fallen below the capital requirement. A similar trend is seen in relation to losses on loans in general. None of the banks' earnings in 2008 were sufficient to cover a general increase in losses on loans of 1 percentage point in the sector, and three banks would have had solvency problems, compared with one in 2007.

Mortgage-credit institutes – increased write-downs and increasing arrears ratios

The mortgage-credit institutes' total earnings in 2008 amounted to kr. 2.2 billion before tax, corresponding to a return on equity of 2 per cent p.a. Compared with 2007, profits decreased by 76 per cent. The development was driven by one institution with a significantly poorer result in 2008 than in 2007. The results of the remaining mortgage-credit institutes improved by approximately 10 per cent in 2008. Net income from interest increased by almost 10 per cent in 2008. This includes both increasing contributions and rising interest income from mortgage-credit loans.

In total, the four mortgage-credit institutes had to write down kr. 841 million on loans in 2008. In comparison, they reversed losses and write-downs of kr. 65 million in 2007. Individual mortgage-credit institutes' write-down ratios were between 0.01 per cent and 0.06 per cent of their total mortgage-credit lending in 2008. The four institutions analysed all reported increasing arrears ratios in 2008, but this was from a very low level compared to previous years.

Portfolio earnings affected the mortgage-credit institutes' results in different ways. Two of them had positive portfolio earnings, while the other two recorded losses on that item in 2008.

On the balance-sheet side, the total amount of outstanding mortgage-credit loans in the four institutions increased by 8 per cent compared with 2007, to kr. 1,832 billion.

Chart 17 shows the development in the mortgage-credit institutes' buffers against losses. Like the banks, cf. page 33, a limit has also been imposed on the mortgage-credit institutes as regards the decrease in their capital requirement in connection with the transition to Basel II, the so-called transitional arrangement. Chart 17 illustrates the effect of the transitional arrangement, using the Danish Financial Supervisory Authority's calculations.5The transitional arrangement accounts for more than half of the credit institutions' buffer in 2008, which indicates that they became more vulnerable to losses from 2007 to 2008.

mortgage-credit institutes' buffers against losses chart 17
Chart 17
Note: Maximum losses are calculated including actual losses and write-downs. The population changes from 2004 onwards. From 2004, the population comprises Nordea Kredit, Nykredit Realkredit, Realkredit Danmark and Totalkredit. Previously it also included BRFkredit, DLR Kredit, LR Realkredit and FIH Realkredit. The shaded area has been estimated on the basis of data from the Danish Financial Supervisory Authority, covering all eight mortgage-credit institutes.
Source:Financial statements and Danish Financial Supervisory Authority.
Life insurance companies' reserves heavily reduced

The financial groups' life insurance companies (hereafter called the life insurance companies) have had low or negative returns in 2008, cf. Chart 18. This was the third consecutive year that the return on investments was lower than the interest-rate guarantees associated with a large part of the companies' commitments and the rate of interest on policyholders' savings announced by the companies at the beginning of 2008.6 Consequently, the life insurance companies have not been able to recognise risk compensation as revenue, and the amount has therefore been transferred to shadow accounts, see Box 10. According to the Danish Executive Order on the Contribution Principle, subsequent disbursements from such shadow accounts are conditional on the re-establishment of the companies' "bonus potential in respect of paid-up policies".

Return after pension-yield tax in the financial groups' life insurance companies chart 18
Chart 18
Source: Financial statements.

life insurance companies' shadow accounts Box 10

Under the Danish Financial Business Act, life insurance companies must report risk compensation accruing to equity. If in a particular year there is a shortfall in a life insurance company's realised results in relation to the announced level of risk compensation accruing to equity, the company may transfer the amount to a "shadow account". If in subsequent years the life insurance company obtains sufficient realised results, amounts from this shadow account can be added to the equity capital in addition to the reported annual risk compensation. The life insurance company may choose that the amount on the shadow account should carry interest.

However, section 8(1) of the Danish Executive Order on the Contribution Principle states that if a life insurance company has used bonus potential of paid-up policies to cover a loss, they must be re-established before a subsequent profit may be used to reduce (write down) the shadow account.

1 Bonus potential of paid-up policies means the duty to pay bonus on paid-up premiums.

The negative development in the financial markets and the resulting low returns on investment led to a considerable reduction of the life insurance companies' reserves. The life insurance companies have had to make inroads into their collective bonus reserves and bonus potential in respect of paid-up policies in order to honour the announced rates of interest on policyholders' savings. The life insurance companies' collective bonus reserves are more or less gone, cf. Table 1, and one company has received a capital injection from the parent company to ensure its continued capital strength and flexibility.

Bonus ratio in selected pension companies Table 1
Per cent, year-end
2008
2007
2006
Danica
0.9
8.5
8.8
Nordea Liv & Pension
1.2
12.3
14.0
Alm. Brand Liv og Pension
0.0
4.0
4.7
Note: The bonus ratio is the collective bonus potential measured in relation to the sum of retrospective provisions.
Source: Financial statements.

On 31 October 2008, the Danish Insurance Association entered into a stability agreement with the Ministry of Economic and Business Affairs, entailing, among other things, a new method of calculating the yield curve used to discount provisions. This led to a reduction of the current value of about 0.5 per cent of the life insurance companies' provisions. In principle, this is not a major change. It should be noted, however, that no matter how the current value of future liabilities is calculated technically, this does not change the fact that the pension companies' current income over a number of years must be sufficient to enable the companies to fulfil the promises they have made to their customers.

The life insurance companies have generally reduced their equity portfolios in 2008, and highly-rated bonds constitute the largest share of the investment assets, cf. Chart 19. Nonetheless, exposure of the base capital to share price risk7increased from end-2007 to end-2008 in all three companies. Generally, the companies' reserves have been reduced, thereby increasing base capital-related risks. This means that owning a life insurance company has become more of a risk for the financial institutions. The probability of the financial groups having to inject new capital into the life insurance companies is assessed to have increased.

Breakdown of investment assets chart 19
Chart 19
Source: Financial statements.

All three companies have reduced their rate of interest on policyholders' savings for 2009. This is the first step towards restoring the companies' reserves. This is a precondition if the financial groups are once again to obtain a return on the capital invested in the life insurance companies and reduce the owners' risks.

For all three companies green light applied at end-2008, as defined by the Danish Financial Supervisory Authority's risk scenarios. The yellow risk scenario was abolished by the Danish Financial Supervisory Authority in connection with the agreement of 31 October 20088. However, according to the three life insurance companies' financial statements they all observed the yellow scenario throughout 2008. The yellow scenario is tougher than the red as it implies providing earlier warnings about problems than the red scenario.

Nordic groups

Danske Bank and Nordea are the largest banking groups in the Nordic region in terms of balance-sheet assets, cf. Chart 20. The total assets of Nordea and DnB NOR increased by more than 20 per cent in 2008, while Danske Bank and SEB experienced the lowest growth at 6 and 7 per cent, respectively. In terms of the market value of outstanding shares at end-2008, Nordea is the largest group, with a value of kr. 97 billion, compared to 36 billion for Danske Bank.

Balance-sheet totals, Nordic banking groups chart 20
Chart 20
Note: On translation into Danish kroner, the exchange rate at end-2008 has been applied for all years.
Source: Financial statements.

Earnings in the Nordic groups in 2008 were in line with the global development. Profit for the year and return on equity fell significantly compared to 2007, cf. Chart 21. Net interest income generally increased due to higher lending margins and sustained growth in lending, whereas net fee income was reduced due to lower investment activity and a weak stock market. Reduced valuation adjustments further contributed to the decline in earnings. Write-downs on loans increased significantly, and several groups had to make extraordinarily large write-downs on goodwill relating to activities in countries that are particularly severely affected by the economic slowdown. Cases in point are Danske Bank's activities in Ireland and Swedbank's activities in Ukraine.

Return on equity before tax, Nordic groups chart 21
Chart 21
Note: Return on equity is calculated in the local currency on the basis of an average of equity, beginning of period, and equity, end of period. The return on equity for the 1st quarter of 2009 has been annualised.
Source: Annual and quarterly financial statements.

The financial statements for the 1st quarter of 2009 indicate that the development continues, with increasing net interest income, but also substantial write-downs on loans and further write-downs of goodwill in Swedbank and SEB on activities in Ukraine.

The development in return on equity in all six groups was adversely affected by the decline in earnings in 2008. The return on equity in 2008 and in the 1st half of 2009 is positively affected by the groups' reclassification of financial assets in accordance with the new accounting rules that were implemented in the autumn of 2008.

Write-downs on loans in Danske Bank increased significantly in the 4th quarter of 2008 while the other Nordic groups were still at a relatively modest level, cf. Chart 22. Write-downs in the Nordic groups in the 4th quarter of 2008 were primarily related to financial institutions and corporate customers. In the 1st quarter of 2009, write-downs on loans increased further, and the spread in the groups' write-down ratios became more apparent. Swedbank's write-down ratio amounted to more than 2 per cent p.a., mainly related to the Baltic States.

Write-downs for the year chart 22
Chart 22
Note: Write-down ratios calculated as write-downs for the year as a percentage of loans and guarantees before write-downs. The write-down ratios for the 1st quarter of 2009 have been annualised.
Source: Annual and quarterly financial statements.

The accumulated write-down ratio (the corrective account) also varies greatly among the Nordic groups, cf. Chart 23. In the period from 2005 to 2007, Danske Bank was among the groups with the lowest sum of accumulated write-downs. Following substantial write-downs in 2008 and in the 1st quarter of 2009, Danske Bank had the highest write-down ratio on its loans. Handelsbanken's write-downs remain at a very low level. Factors such as the loan distribution on sectors and the value of assets pledged as collateral determine the credit quality of the lending portfolio, and certain geographical areas are more severely affected by the economic downturn than others.

Accumulated write-downs chart 23
Chart 23
Note: Calculated as the sum of accumulated write-downs on loans and provisions for losses on guarantees as a percentage of loans and guarantees without write-downs and provisions.
Source: Annual and quarterly financial statements.

More than 10 per cent of Danske Bank's lending activities are in Ireland and the UK, cf. Chart 24. In both these countries, the economic setback was particularly severe in the early stages of the international downturn. Denmark was also affected by the economic decline earlier than the other Nordic countries. Several of the other Nordic groups have a higher exposure to countries that were affected later by the setback. SEB and particularly Swedbank have relatively large exposures to the Baltic States, however.

Geographical distribution of credit exposures, end-2008 chart 24
Chart 24
Note: SEB's share of lending to Ukraine is not specified in the financial statements.
Source: Financial statements.

The global financial crisis has made it extremely difficult for many banks to gain access to new capital, and in anticipation of increased losses in the banks, the focus of the market, including rating agencies, is now on the banks' capital adequacy and the quality thereof. The Nordic groups, with the exception of DnB NOR, have all raised or had injections of new Tier 1 capital since the 4th quarter of 2008, and the Tier 1 capital of the groups concerned has increased significantly, cf. Chart 25.

Development in solvency ratio broken down by Tier 1, hybrid core and supplementary capital chart 25
Chart 25
Note: Capital adequacy at the end of the 1st quarter of 2009 includes the financial result for the period. For DnB Nor only half of the financial result is included. The "new capital" bar comprises capital adequacy at end-March 2009 plus new capital injections announced but not included in the quarterly financial statements. Calculated on the basis of risk-weighted items in accordance with Basel II, i.e. excluding the transitional arrangement.
Source: Annual and quarterly financial statements.

In May 2009, the Danske Bank group received capital injections of kr. 26 billion from the Danish government under Bank Rescue Package II (kr. 24 billion to Danske Bank and kr. 2 billion to Realkredit Danmark). The capital injections were in the form of hybrid core capital and improved the group's Tier 1 ratio from 9.0 to 11.7 per cent. Danske Bank can convert part of the hybrid capital to share capital if its hybrid core capital exceeds 35 per cent of its total Tier 1 capital. If the hybrid core capital exceeds 50 per cent of its total Tier 1 capital, Danske Bank is obliged to convert part of the capital injections to share capital.9

In April 2009, Nordea launched a share issue providing net proceeds of 2.5 billion euro and bringing the group's Tier 1 ratio to 12.4 per cent.

SEB also issued new shares in the 1st quarter of 2009, the proceeds of which amounted to 14.9 billion Swedish kronor within the accounting period and another 212 million after closing of the quarterly accounts. SEB's Tier 1 ratio then amounted to 12 per cent.

Handelsbanken issued new hybrid core capital in both the 4th quarter of 2008 and the 1st quarter of 2009 of 2.6 and 2.7 billion Swedish kronor, respectively, bringing the group's Tier 1 ratio to 11.6 per cent at the end of the 1st quarter of 2009.

Swedbank launched preference share issues in December 2008 and January 2009, the proceeds of which amounted to 12 billion Swedish kronor. The group's Tier 1 ratio at the end of the 1st quarter of 2009 amounted to 10.8 per cent.

DnB NOR differs from the other Nordic groups in that its Tier 1 ratio was 7.0 per cent at the end of the 1st quarter of 2009. Despite having the lowest capital requirement as a ratio of the risk-weighted items, the group's excess capital adequacy is still the lowest. The Nordic groups have not published their individual capital needs, and the capital requirement is therefore calculated as minimum 8 per cent of the risk-weighted items with the addition of any capital requirement in relation to the transitional arrangement for IRB implementation under Basel II.


1 The IRB approach is currently used by Danske Bank, Nordea, Jyske Bank, Sydbank, Nykredit Bank and Lån & Spar Bank. Alm. Brand Bank applied to the Danish Financial Supervisory Authority for authorisation as an IRB institution at the end of 2008, and Spar Nord Bank is preparing the process, but has not applied yet. FIH Erhvervsbank has suspended the process for the time being.

2 While the base capital was to constitute at least 90 per cent of the solvency requirement under the previous rules (Basel I) in 2008, the requirement is reduced to 80 per cent in 2009.

3
The capital injection covers banks only, not affiliated mortgage-credit institutes.

4
The Danish Financial Supervisory Authority's 2008 report on the market development for banking institutions, May 2009 (in Danish only).

5
The Danish Financial Supervisory Authority's 2008 report on the market development for banking institutions, May 2009 (in Danish only).

6
From 1982 up to mid-1994 the life insurance companies were allowed to use a maximum guaranteed interest rate of 5 per cent. This was reduced to 3 per cent in 1994 and further reduced to 2 per cent in 1999.

7
Share price risk indicates the loss to be covered by the base capital if share prices fall.

8
In the yellow risk scenario the life insurance companies were required to sustain an interest-rate adjustment of 1.0 percentage point in the most detrimental direction, a fall in equity prices of 30 per cent, a fall in real-estate prices of 12 per cent, and losses in connection with credit, counterparty and exchange-rate risk. The red risk scenario, which is retained, provides for an interest-rate adjustment of 0.7 percentage point in the most detrimental direction, a fall in equity prices of 12 per cent, a fall in real-estate prices of 8 per cent, and losses in connection with credit, counterparty and exchange-rate risk.

9
See "Agreement on state-funded capital injection" and "Terms and conditions of the notes" at www.danskebank.com.

 

 

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