Consultation responses

Published Download Title
20-11-2017

Consultation response regarding the draft amendment to the executive order on good business practice for mortgage lending

Danmarks Nationalbank

The suggested amendment limits the product supply for homeowners with a total debt-to-income, DTI, of more than four and a loan-to-value, LTV, of more than 60 per cent. Danmarks Nationalbank finds it positive that the rules apply to all homeowners with high debt in proportion to income, regardless of the zip code of the property. On the other hand, Danmarks Nationalbank finds it inappropriate that highly indebted homeowners will still be able to finance housing purchases using deferred amortization loans. Restricting the possibility to obtain deferred amortization financing would reduce the vulnerability of homeowners to negative economic shocks such as declining house prices and unemployment, just like a higher monthly debt service would reduce the risk of short-sightedness due to low interest rates.

06-07-2017

Reply to the Danish Financial Supervisory Authorithy's Discussion Paper on the Fit & Proper Regulations

Danmarks Nationalbank

Danmarks Nationalbank does not specifically address the individual aspects of the Fit & Proper regulations highlighted in the Danish Financial Supervisory Authority's discussion paper. On a more general basis, Danmarks Nationalbank finds it essential to maintain the owners' and management's full responsibility for the sound operation of a credit institution. The EU Fit & Proper regulations give the member states a certain degree of flexibility. In Danmarks Nationalbank's view, no Danish rules or practices generally expanding the Danish Financial Supervisory Authority's Fit & Proper tasks relative to the current regime should be implemented.

15-05-2017

Consultation on amendment of the Supervisory Diamond for banks

Danmarks Nationalbank

The Danish Financial Supervisory Authority has submitted a change in the liquidity benchmark in the Supervisory Diamond for consultation. Danmarks Nationalbank agrees that sound liquidity management in the individual banks is key to ensuring a robust financial system and that the supervisory authorities must have the necessary powers and supervisory tools to follow up and respond to insufficient liquidity management in a bank. But it is important to emphasise that the point of departure must still be that the banks themselves are responsible for managing their liquidity risks. Danmarks Nationalbank notes that the Supervisory Diamond, including the liquidity benchmark, is a supervisory tool which is used as part of the overall supervisory assessment of the risks and risk management of the individual bank.

08-05-2017

Consultation on amendment of the executive order on Financial reports

Danmarks Nationalbank

The Danish Financial Supervisory Authority has submitted a draft amendment of the Executive Order on Financial Reports for Credit Institutions and Investment Firms, etc. (the "Executive Order") for consultation along with guidance notes. A well-founded adjustment of the rules against that background, so that the managements of Danish institutions have the same scope for making accounting estimates as those of other European institutions, could contribute to simplifying financial regulation and strengthening the basis for cross-border competition. In general, Danmarks Nationalbank also finds that such adjustments are sound. However, it is important to emphasise that the core elements of robust regulation of the financial sector must be in place first. In addition to capital requirements and stable funding requirements, it is essential that all credit institutions can be resolved – without major adverse implications for the economy and financial stability.

28-02-2017

Response to the Danish Financial Supervisory Authority's Discussion Paper

Danmarks Nationalbank

Response to the Danish Financial Supervisory Authority's Discussion Paper Danmarks Nationalbank's response to the Danish Financial Supervisory Authority's Discussion Paper Main principles for resolution of small and medium-sized banks and determination of minimum requirements for own funds and eligible liabilities (MREL)

18-01-2017

Response to the Danish Financial Supervisory Authority's consultation of the EU Special Committee for the Financial Sector on the Commission's proposal for a review of the CRR, CRD IV, BRRD and SRMR

Danmarks Nationalbank

Danmarks Nationalbank welcomes the proposals from the European Commission. This package of proposals introduces a number of important and useful new international standards (cf. the Basel Committee) for requirements regarding credit institutions' leverage, liquidity, coverage of market risk and large exposures in EU legislation.