Europaudvalget 2015-16
EUU Alm.del Bilag 11
Offentligt
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Commissioner Jonathan Hill
European Commission
DG Financial Stability, Financial Services and Capital Markets Union
Brussels
MINISTER FOR BUSINESS AND
GROWTH
7 October 2015
Dear Jonathan Hill
I would like to thank you for initiating the consultation related to the po-
tential impact of the CRR/CRD IV on bank financing of the economy. As
the Danish minister for business and growth I fully support the rationale
behind this consultation.
The Danish government shares your view that both existing and new leg-
islation should contribute to financial stability, employment and growth in
the EU.
In relation to the CRR/CRD IV-package, the Danish government general-
ly finds the rules balanced and reasonable. We appreciate the constructive
cooperation between Danish authorities and the Commission during the
negotiations of the CRR/CRD IV, including on the level 2 provisions.
The Danish government, however, sees a potential scope for simplifica-
tion when it comes to the reporting requirements for credit institutions in
CRR/CRD IV. We find that it needs to be carefully assessed whether the
administrative burdens associated with these reporting requirements are
commensurate to the added value.
Denmark agrees with the Commission in the benefit of evaluating the
effects of the entire new legislative landscape and this evaluation should
be taken into account if any new legislation is considered. An impressive
amount of new legislation concerning the financial sector has been intro-
duced in recent years. A large part of this legislation is not yet fully im-
plemented or has only been put into force recently. Going forward, it
needs to be carefully assessed whether new legislation is needed.
The Danish government supports the idea behind the Capital Market Un-
ion and believes that many of the actions proposed are important in order
to promote growth and job creation. The Danish government also wel-
comes the Commission consultation on covered bonds and the prerequi-
site that future work in this area should build on and take into account
well-functioning national regimes.
MINISTRY OF
BUSINESS AND GROWTH
Slotsholmsgade 10-12
1015 Copenhagen K
Denmark
Tlf.
+45 33 92 33 50
Fax.
+45 33 12 37 78
CVR-nr. 10092485
EAN nr. 5798000026001
[email protected]
www.evm.dk
 EUU, Alm.del - 2015-16 - Bilag 11: Orienterende notat og høringssvar om Kommissions høring om konsekvenserne af kapitalkravsforordningen og -direktivet
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The Danish government notes that work is currently under way in interna-
tional fora in relation to strengthening and developing the internal ratings
based models, introducing a new standardized approach as well as new
capital floors. We acknowledge the importance of this work but overlap-
ping regulatory regimes should be avoided. Moreover, it of utmost im-
portance that future rules take into account well-functioning national
business models.
From a Danish perspective we generally find it important to ensure that
capital requirements continue to be risk-based. Risk-based capital re-
quirements – when properly regulated and supervised – provide appropri-
ate incentives for credit institutions and they promote efficient capital
allocation to the benefit of our economies. Non-risk-based capital re-
quirements can in our view only be a supplement to risk based capital
requirements.
Special consideration to well-functioning business models should also be
given when it comes to potential new rules on a Net Stable Funding Ratio
and a Leverage Ratio, where rules should be properly calibrated and take
into account the Danish mortgage credit system.
I would once again like to thank you for initiating this consultation and
for your emphasis on financial stability, growth and employment in the
EU. The Ministry of Business and Growth and I stand ready to cooperate
with you and your services on the important issue.
Yours sincerely,
Troels Lund Poulsen