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Maria Luís Albuquerque
Commissioner of Financial Services and the Savings and Investments Union
European Commission
MINISTER FOR INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
06 December 2024
Dear Maria Luís Albuquerque,
Thank you for the opportunity to respond to the Commission’s public con-
sultation on assessing the adequacy of macroprudential policies for the non-
bank financial intermediary (NBFI) sector.
Denmark acknowledges the Commission's assessment of the potential risks
and vulnerabilities that the NBFI sector may pose to both the EU as a whole
and its Member States. We recognize the importance of gaining a deeper
understanding of these potential risks, while noting that the NBFI sector is
highly diverse, and, in many respects, should not be viewed as a single,
unified sector.
We have a shared responsibility of ensuring that regulation is focused at
correcting specific problems or identified gaps in the current framework.
In this regard, we would like to emphasize the importance of basing any
proposal on thorough assessments of risks and impacts. It is essential that
any regulatory changes mitigate risks effectively while ensuring that the
measures remain proportionate and avoid imposing unnecessary burdens
on businesses and national supervisory authorities.
As a first step, significant risk could be addressed through gradual and tar-
geted adjustments to existing rules, rather than by imposing new legisla-
tion.
Finally, we generally find the existing supervisory set-up to be well-func-
tioning. However, should a thorough assessment of pros and cons indicate
shortcomings and potential substantial added value through new regulation,
we remain open to further discussions whilst bearing in mind that any extra
regulation has to be assessed both with respect to the benefits it creates and
the cost in terms of administrative burdens. Moreover, it is important to
MINISTRY OF INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
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