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
www.em.dk