EUU, Alm.del - 2016-17 - Bilag 132: Notat og dansk høringssvar til Kommissionens høringsdokument om review af makroprudentielle værktøjer

Europaudvalget 2016-17
EUU Alm.del Bilag 132
Offentligt

European Commission

DG FISMA

Rue de Spa 2

1000 Brussels

Belgium

MINISTER FOR BUSINESS AND

GROWTH

MINISTRY OF

BUSINESS AND GROWTH

Thank you for the opportunity to comment on the review of the EU

mac-

ro-prudential policy framework for the banking sector.

We broadly support the review. I have

three main points.

First, we find it very important to preserve the balance between further har-

monisation and national flexibility in the use of macro-prudential instru-

ments. On the one hand, harmonisation across sectors and between Member

States could be appropriate, if and where it adds value. On the other hand, it

is important to ensure sufficient flexibility to Member States, taking into

account national specificities e.g. in the real estate market and differences

between Member States and sectors (banking, the insurance and pensions

sector etc.)

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

Secondly, in the current framework, the calibration of the capital buffers

is inappropriate for smaller member states with large financial institutions

like Denmark. Therefore, we suggest that the framework is recalibrated.

For more details on this matter please confer to the attached annex.

Thirdly, at this point in time, we do not see a need to broaden the scope for

macro-prudential instruments to non-banking. Risks to financial stability

may originate in other areas of the financial system than banking, and there-

fore it is relevant to consider which tools would be effective in mitigating

such risks. However, we would like to emphasize that in Denmark we have

not seen financial risks originating from other areas of the financial system

than banking. Moreover, the macro-prudential risks stemming from non-

banking areas are of a different nature than those of banking, and the instru-

ments to address these risks will most likely be of a different nature. In any

case, before introducing new instrument to other areas, thorough impact stud-

ies should be carried out, including an assessment of the added value to the

financial system, as well as an in depth impact assessment of the economic

consequences for businesses, including the non-banking sector.

EUU, Alm.del - 2016-17 - Bilag 132: Notat og dansk høringssvar til Kommissionens høringsdokument om review af makroprudentielle værktøjer

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Yours sincerely,

Troels Lund Poulsen

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Annex

In order to secure an effective macro-prudential framework there is a need to

revise the current cap on the O-SII buffer (Other Systemically Important

Institutions). Specifically, we find the current cap of the O-SII buffer too low

and find it appropriate to recalibrate it. The floors and caps between the G-

SII buffer (Global Systemically Important Institutions), the O-SII buffer and

the SRB (Systemic Risk Buffer) restricts smaller member states like Den-

mark to fully benefit from the advantages and purpose of the O-SII, as the 2

percent cap on the O-SII buffer is not appropriate for the systemically im-

portant institutions in Denmark.