Erhvervsudvalget 2024-25
ERU Alm.del Bilag 82
Offentligt
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Maria Luís Albuquerque
Commissioner for Financial Services and the Savings and In-
vestments Union
European Commission
Response from the Danish Government to the Commission’s targeted con-
sultation on the EU securitisation framework
Dear Commissioner Albuquerque,
Thank you for the opportunity to respond to the Commission’s public consultation
on the functioning of the EU securitisation framework.
Well-functioning and diverse funding markets are important for underpinning
growth, employment, and innovation in Europe. To ensure this, financial regula-
tion must be effective and efficient while at the same time safeguarding financial
stability. Thus, we welcome initiatives aiming at simplifying and improving the
regulatory framework.
Therefore, Denmark is ready to consider simplifications and adjustments to cer-
tain requirements relating to the EU securitisation framework. We would like to
emphasize the following points.
A proposal should be based on thorough assessments of risks and impacts
An important guiding principle should be that the regulation should continue to
contain and mitigate the risks for issuers of and investors in securitisations. It is a
fundamental principle that the regulation and capital requirements need to be risk-
based and reflect actual risk-levels. Any changes to the prudential requirements
should be based on thorough analyses and assessments of the impact on potential
risks to avoid unintended consequences in terms of reduced robustness and resil-
ience of the markets.
We have a shared responsibility to make sure that any substantial change is based
on specific problems or identified gaps in the regulation. The work should be
supported by impact assessments to underpin that any changes have the intended
impact and implications both for the private and public sector.
An appropriate role as part of the wider European funding landscape
Another guiding principle should be to avoid negative impact on well-functioning
markets, in particular the covered bonds markets, which already play an important
and stabilising role in the European funding landscape. An increased role for se-
curitisations should not come at the expense of already well-functioning funding
instruments such as covered bonds, as little real value would be added in terms of
an increase in total funding supply.
MINISTER FOR INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
MINISTRY OF INDUSTRY, BUSI-
NESS AND FINANCIAL AFFAIRS
Slotsholmsgade 10-12
DK-1216 Copenhagen K
Tlf.
Fax
+45 33 92 33 50
+45 33 12 37 78
CVR-nr. 10 09 24 85
EAN nr. 5798000026001
[email protected]
www.em.dk
 ERU, Alm.del - 2024-25 - Bilag 82: Orientering om dansk høringssvar vedr. Kommisionens offentlige høring om rammerne for securitisering i EU, fra erhvervsministeren
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Any changes to the securitisation framework should continue to reflect that secu-
ritisations are different instruments to covered bonds and that they distribute risks
differently. We need to keep in mind the history of securitisations. We have prac-
tical and hard-learned lessons from the past and we must ensure that changes to
the regulation do not risk jeopardising financial stability or investor protection.
Continuation of a market- and principle-based approach
Although standardisation and platforms could be relevant to explore – especially
identification of barriers that cannot be mitigated by private market participants
themselves – we do not see a role for state guarantees or other public financial
support for securitisations. Selective public support for securitisations would pro-
mote securitisations at the expense of well-functioning funding sources operating
on market-based conditions and competing on their own merits. This would dis-
tort the effective allocation of resources in a harmful way and could increase risks
in the funding markets, while using scarce public resources that could have oth-
erwise contributed more effectively to public policy goals.
Information sharing and cooperation between competent authorities
Finally, we consider the existing supervisory setup on securitisation broadly suit-
able. If evidence points to shortcomings and possible improvements, we are open
to explore this. We would favour proportionate adjustments to the existing setup
rather than fundamental changes. Possible shortcomings could likely be effec-
tively remedied through increased information sharing and strengthening mutual
dialogue and cooperation between competent authorities rather than establishing
new structures.
We are at your disposal for any questions or comments that you and your services
might have. We look forward to a fruitful dialogue on these important issues.
Yours sincerely,
Morten Bødskov
Minister for Industry, Business, and Financial Affairs
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