ERU, Alm.del - 2017-18 - Bilag 137: Notat og høringssvar om EU-Kommissionens høring om tilsynsmæssig finansiel rapportering

Erhvervs-, Vækst- og Eksportudvalget 2017-18
ERU Alm.del Bilag 137
Offentligt

Valdis Dombrovskis

Commissioner for Financial Stability,

Financial Services and Capital Markets Union

European Commission

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

March 16 2018

Dear Vice-President Valdis Dombrovskis,

Thank you for the opportunity to respond to the public consultation on

fitness check on supervisory reporting.

Supervisory reporting is essential for competent authorities to perform

their tasks, thereby ensuring financial stability, orderly market conditions

and investor protection.

Following the financial crisis, important reforms were agreed in the field

of financial services. This included supervisory reporting requirements

which had proven insufficient in detecting weaknesses in the financial

system. Denmark has been and continues to be a strong supporter of these

reforms which ensure that we have a more resilient financial sector in the

EU.

In general, the supervisory requirements introduced at EU level have im-

proved the prudential supervision and thereby helped safeguarding the

stability of the financial system.

That being said, the amount of new reporting requirements has also in-

creased the administrative burden imposed on financial institutions. Im-

plementing new reporting requirements is costly due to the need to adopt

new IT system, training personnel etc. Therefore, we strongly believe that

supervisory reporting should be limited to need-to-have requirements.

Also, it is important to take into account principles of proportionality in

terms of the size, complexity and solidity of the institutions. A propor-

tionate approach to supervisory reporting allows competent authorities to

obtain the required information without enforcing a disproportionate cost

on institutions.

Since implementation often comes with large one off costs to cover adap-

tation of reporting and IT systems, we believe that the frequency of

changes should be kept to a minimum. Furthermore, it is important that

there is always sufficient time for the financial institutions to implement

new systems etc. when changes are introduced.

MINISTRY OF INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Slotsholmsgade 10-12

1216 Copenhagen K

Denmark

Tlf.

+45 33 92 33 50

Fax.

+45 33 12 37 78

CVR-nr. 10092485

EAN nr. 5798000026001

[email protected]

www.em.dk

ERU, Alm.del - 2017-18 - Bilag 137: Notat og høringssvar om EU-Kommissionens høring om tilsynsmæssig finansiel rapportering - fitness check, fra erhvervsministeren

2/2

Many of the new requirements have been introduced only recently and it

is too early to assess the added value of all the requirements. We have,

however, together with the Danish Financial Supervisory Authority

(FSA), identified some areas where requirements seem to be excessive

and disproportional. This includes the AMML reporting (Additional Mon-

itoring Metrics on Liquidity) and the Asset Encumbrance reporting. We

find this reporting to be both complex and comprehensive and therefore

burdensome for credit institutions as well as supervisory authorities com-

pared to the relatively limited information it brings. The Danish FSA is

submitting a separate response to the consultation which will elaborate

further on these examples.

We are looking forward to discussing the outcomes of the consultation in

the form of concrete proposals to reduce identified overlaps, inconsisten-

cies and unnecessary burdens in order to optimise supervisory reporting

in the EU.

My services and I stand at your disposal for any questions or comments

you might have.

Yours sincerely,

Brian Mikkelsen