Consultation responses

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Consultation response regarding the bill to amend the Act on Measures to Prevent Money Laundering

Danmarks Nationalbank

The political anti-money laundering agreement gives the authorities more scope to crack down on illegal activities. That is important in relation to the Danish financial sector's reputation at home and internationally. Danmarks Nationalbank supports an increased level of fines and a general strengthening of the anti-money laundering effort.


Consultation response concerning the bill to amend the Danish Financial Business Act, Anti-Money Laundering Act, Act on Alternative Investment Fund Managers, etc. and various other acts

Danmarks Nationalbank

A key lesson learned from the financial crisis is that it must be possible to address the problems of banks and mortgage banks without the use of government funds. The large, systemically important institutions perform functions that are critical to society and essential to financial stability. It must be possible to continue these functions if problems arise. This means that there must be sufficient funds contributed by owners and creditors, i.e. own funds and eligible liabilities.


Comments on the draft delegated act amending the commission delegated regulation on the Liquidity Coverage Ratio (LCR)

Danmarks Nationalbank

The European Commission has asked for comments on the proposed amendments to the short-term liquidity rules for EU banks known as Liquidity Coverage Ratio, LCR. Danmarks Nationalbank supports the amendments which solve the unwind problem for repos with central banks in a systemic crisis. Danmarks Nationalbank is still concerned about the framework for secured transactions, which can have some unintended consequences. Danmarks Nationalbank encourages the Commission to continue the work towards a general solution of the unwind problem for secured transactions.


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.