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Finance Denmark

FIDA

Finance Denmark represents Danish banks and financial institutions on regulatory and policy matters.

Lobbying Activity

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Insurance Europe

10 Dec 2025 · Meeting with Danish finance network

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and Confederation of Danish Industry and

8 Dec 2025 · Address to the cleantech MFF roundtable: An EU Budget for a Stronger, Cleaner and More Sovereign Europe – Recommendations from Danish Investors, Business Community & Civil Society

Meeting with Maria Luís Albuquerque (Commissioner) and

18 Nov 2025 · Policy developments in banking and capital markets

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

10 Oct 2025 · Retail investment strategy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

1 Oct 2025 · Meeting with FiDa

Finance Denmark urges swift action on nature credits regulatory framework

30 Sept 2025
Topic — EU roadmap for establishing nature credits to finance biodiversity conservation and restoration.
Message — The organization requests speedy implementation of the proposed timeline and early development of regulatory clarity. They emphasize maintaining profitability in the framework and exploring blended finance mechanisms while avoiding excessive disclosure requirements.1234
Why — This would provide their members clear market rules and profitable investment opportunities.56
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Finance Denmark urges strong creditor protections in EU company law

30 Sept 2025
Topic — EU framework to simplify corporate rules for innovative companies across member states.
Message — Finance Denmark requests adequate creditor protection and minimum capital requirements, especially for cross-border company transfers. They emphasize effective creditor safeguards in insolvency provisions and measures preventing tax avoidance.123
Why — This would protect banks and financial institutions from losses on business loans.4
Impact — Startups face higher barriers through minimum capital and stricter formation requirements.56
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Meeting with Christel Schaldemose (Member of the European Parliament)

30 Sept 2025 · Omnibus

Meeting with Niels Flemming Hansen (Member of the European Parliament)

25 Sept 2025 · Exchange ideas and get together

Meeting with Katri Kulmuni (Member of the European Parliament) and Finanssiala ry - Finance Finland and

24 Sept 2025 · Nordic Finance evening -vastaanotto

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen) and

24 Sept 2025 · Exchange about important digital policy priorities with representatives of Nordic Financial Associations

Meeting with Tomas Tobé (Member of the European Parliament) and Finanssiala ry - Finance Finland and

24 Sept 2025 · Finance Policy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

24 Sept 2025 · EU finance policy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Novo Nordisk A/S and

18 Sept 2025 · Roundtable on sustainability omnibus

Response to European climate resilience and risk management law

4 Sept 2025

Finance Denmarks response to call for evidence for the European Climate Resili-ence and Risk Management Initiative Thank you for the opportunity to provide input for the upcoming initiative. The focus on climate resilience and preparedness, while considering the need for simplification and European competitiveness, is both timely and important. Important for the framework conditions for the financial sector Broadly speaking, the EU Climate regulatory framework is important for the fi-nancial sector as this regulation sets out the framework conditions for the finan-cial sector. The regulatory framework to a large extent determines which green projects will become profitable in the future, and consequently, what the finan-cial sector can support through financing and green investments. It is essential that the adaptation of regulatory and data requirements for climate risk assessments is approached with a clear focus on coherence across existing regulations including financial regulation. Specifically, alignment between re-quirements in CRR, CRD (including Pillar III reporting, climate stress testing etc.), and the CSRD is paramount. Ensuring consistency and compatibility will reduce complexity and administrative burdens both for companies and financial institu-tions, while enhancing the comparability and integrity of data. Concrete recommendations addressing financial barriers and market failures The financial sector's activities are predominantly driven by the allocation of funds to areas where they can most cost-effectively contribute to climate im-provements. For the financial sector to optimally contribute to the green transi-tion, clarity is required regarding the goals and financial instruments intended to achieve these goals. Long-term and stable framework conditions are essential for the financial sector to further enhance its contribution to the green transition. In Denmark, the financial sector is cooperating with the government in the Fi-nancial Climate Partnership. This is a valuable dialogue, where banks, asset managers and pension funds help address the obstacles to unlocking private finance for the green transition both in terms of existing and emerging technol-ogies. In the same vein, we would advocate for close cooperation between the EU Commission and the financial sector to establish the appropriate framework conditions and incentives that will continue to promote financing and invest-ments in the green transition and climate resilient solutions. For further information, we have attached a report prepared on behalf of the Climate Partnership for the Financial Sector that aims to identify and analyze the primary barriers that inhibit private investment and financing in the green transi-tion. Through a number of relevant projects (case studies), the report maps both the concrete challenges for private actors and the mechanisms that can be used to overcome these. Analysis of barriers to increased financing and investment in the green transition In addition, we would point your attention to report from the European Banking Federation which examines the obstacles of scaling up financing in transition and emerging technologies: Increasing Bankability of transition and the clean industrial deal. https://www.ebf.eu/ebf-media-centre/updates/report-to-increase-bankability-of-clean-industrial-deal-and-green-transition/
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Response to Heavy Duty Vehicles CO2 and fuel consumption certification

10 Jul 2025

Finance Denmark appreciates the opportunity to provide feedback regarding the amendments to the prudential treatment of securitisation exposures under the Liquidity Coverage Ratio Delegated Regulation. We support the Commissions initiative to revise the eligibility conditions for securitisations in the liquidity buffer of credit institutions. The proposed amendments are well-targeted, and we believe they will contribute meaningfully to the development of the European securitisation market.
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Finance Denmark urges predictable frameworks to accelerate industrial decarbonisation

7 Jul 2025
Topic — The initiative aims to support energy-intensive industries through streamlined procedures and market creation.
Message — Finance Denmark calls for clear, predictable frameworks and a flexible administrative system to support green financing. They support simplifying permitting procedures and creating lead markets to make decarbonisation investments bankable.12
Why — The sector would benefit from strengthened business models and reduced risk for private capital investments.3
Impact — Environmental groups may lose oversight if faster permitting reduces time for ecological scrutiny.4
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Meeting with Villy Søvndal (Member of the European Parliament)

12 Jun 2025 · Debate on the future of Europe

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and BlackRock and

2 Jun 2025 · Exchange with asset managers on the integration of EU capital market

Finance Denmark urges one-page factsheets to simplify sustainable finance

28 May 2025
Topic — The Commission is reviewing sustainable finance rules to enhance usability and prevent greenwashing.
Message — The group proposes replacing lengthy product annexes with a concise one-page sustainability factsheet. They also call for more flexibility for advisors when asking clients about their investment preferences.12
Why — Simplifying these requirements would reduce administrative burdens and help firms avoid excessive compliance costs.34
Impact — Standardization advocates may lose consistency as firms gain discretion in mapping client preferences.5
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Meeting with Niels Fuglsang (Member of the European Parliament)

13 May 2025 · Finance

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

30 Apr 2025 · AI in Financial Services

Meeting with Maria Luís Albuquerque (Commissioner) and

24 Mar 2025 · Exchange on regulatory developments

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Danske Bank A/S

24 Mar 2025 · Conference on Shaping the Future of European Finance

Finance Denmark urges permanent EU rules for repo liquidity

10 Mar 2025
Topic — The consultation addresses the prudential treatment of reverse repos under banking stability rules.
Message — The organization supports making the current transitory prudential treatment for short-term securities financing transactions permanent. They recommend a legislative proposal before June 2025 to avoid a reversion to Basel standards.12
Why — This would prevent significant increases in funding costs and keep trading activity within the EU.3
Impact — Member States would face higher costs to roll over debt and reduced market capacity.4
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Response to Savings and Investments Union

28 Feb 2025

European competitiveness is facing significant challenges. At the same time, Europe needs to invest in defence and a clean industrial base. Many reports have described the challenges, we are facing, including investment gap of 800-1,000 billion Euros per year. Public spending is not sufficient. Several member states and central banks have already pointed to the fact that we need to also address the competitiveness of the financial sector in order to unlock the private capital needed to bridge the gap. A competitiveness plan for the financial sector, including the addressing the banking sectors important and strategic role should be developed. Even if efforts must be broader, a Savings and Investment Union is a crucial element to addressing key barriers to deeper liquidity and more well-functioning capital markets to the benefit of European companies and investors. Within the SIU, Finance Denmark points to the following key and concrete proposals that can contribute to leveraging the necessary private capital: Increasing retail investor participation - Tax incentives can increase retail investments. At the EU level, the development of a blueprint for investment savings accounts (based on good practices from member states that already have ISAs) in place could encourage use of ISAs at national level - The EC should systematically gather and communicate about good practices to increase retail participation and conduct monitoring and scoreboarding of retail participation on national markets as well as member states use of good practices. - Introduce a suitability light investment advice regime for all retail investors to facilitate simpler and easy investment advice for simple retail products. Such a regime can be linked to non-complex UCITS - Simplify information disclosures to retail participants Securitisation review - Reducing compliance and reporting cost while maintaining overall financial stability as a key objective. - Minimizing regulatory uncertainty: Supervisory approval as SRT (Significant Risk Transfer) should be available earlier in the issuing process and there should be less discretions for the supervisor to reject SRT or to demand capital add-ons. - Supporting risk-weights reflecting actual underlying risk in terms of capital cost by adjusting the risk-weight formula and lower the p-factor. Review of macroprudential rules for banks - Simplification and better use of capital buffers for banks - Harmonize the use of macroprudential tools with the aim to create a level playing field for financial institutions buffer - Simplify frameworks and improve coordination between national and EU authorities. - Increase flexibility of capital buffers Capital markets infrastructure - Conduct a detailed and holistic examination of capital market infrastructure and data providers inefficiencies and identify areas and services across European capital markets, which are not subject to genuine competition and where the costs and complexity of the services provided are unreasonable. It is imperative to include the user perspectives in the examination - Through targeted measures Address rent-seeking behavior in infrastructure companies, which is the core issue behind the fragmented, costly and inefficient markets to the detriment of issuers and investors and prevent the development of deep and liquid capital markets in EU. Supervision - To enhance supervisory practices, it is essential to achieve regulatory convergence. - Mandates for European supervisors must be adjusted to tackle the present divergence in national implementation of rules. - For capital market infrastructure, a single EU supervisory authority with a competition mandate is needed. Simplification - Competitiveness check and fitness checks of of all financial regulation with regard to reduce burdens and align rules
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

6 Feb 2025 · Stratégie d'investissement de détail

Meeting with Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

21 Jan 2025 · Exchange with Finance Denmark

Meeting with Sigrid Friis (Member of the European Parliament)

10 Dec 2024 · Priorities of Finance Denmark for the upcoming mandate

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

5 Dec 2024 · Financial regulation

Meeting with Morten Løkkegaard (Member of the European Parliament)

20 Nov 2024 · Finance market

Meeting with Morten Løkkegaard (Member of the European Parliament)

22 Oct 2024 · Upcoming Legislative Agenda of the ITRE Committee

Meeting with Morten Løkkegaard (Member of the European Parliament)

11 Oct 2024 · European Economy

Meeting with Morten Løkkegaard (Member of the European Parliament)

2 Oct 2024 · Framework for financial data access

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Finanssiala ry - Finance Finland and Finance Norway

25 Sept 2024 · Pohjoismaisten finanssialajärjestöjen tilaisuus

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

25 Sept 2024 · Nordic Finance reception

Meeting with Morten Løkkegaard (Member of the European Parliament)

16 Sept 2024 · General status on ECON-files

Meeting with Kristoffer Storm (Member of the European Parliament)

24 Jul 2024 · Financial Services

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finance Sweden and Finance Norway

9 Apr 2024 · Priorities for next EU term; Future EU agenda in financial services.

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

11 Jan 2024 · Retail investor strategy

Response to Payment services – revision of EU rules (new Regulation)

1 Nov 2023

Finance Denmark welcomes the Commissions Proposal for a Regulation on payment services in the internal market (PSR). We have the following comments to the proposal: Open banking The Commission proposes to continue PSD2's principle that; account servicing payment service providers should allow access by providers of open banking services to payment account data and that this should take place in a non-contractual basis without the possibility of charging for access. This contrasts with the Commission's proposal for a Regulation on a framework for financial data access (FIDA). Also, the Data Act allows for compensation for par-ties sharing data. In the FIDA-proposal it is proposed that there should be a possibility for contractual relationship and the possibility of charging for access to data as reasonable compensation. Finance Denmark believes that it is crucial that the same principles for data sharing apply to all services and sectors. APIs will need to be continuously maintained, updated and further developed, i.e. for reasons of cyber security and operational robustness. It should therefore be possible for account servicing payment services providers to enter into contracts with payments institutions and they should be given the possibility of charging for access. It will support high-quality APIs and ensure continued development of the open banking market to the benefit of all players and customers. IBAN-name check The Commission proposes an obligation on payment service providers to make a verification solution (IBAN-name check), where discrepancies between the name and unique identifier of a payee alert the payer of possible mistakes or fraud, before a payment is initiated. A similar solution is proposed in the regula-tion on instant credit transfers in euros, which currently is being negotiated. The provisions in PSR should therefore be fully aligned with the future Instant pay-ments Regulation to avoid any discrepancies in the legal obligations. Payment service providers liability for spoofing fraud The Commission proposes that the payer's payment service provider is liable for authorized payments, when a payer has been manipulated into authorizing a transaction by a third party pretending to be an employee of the consumers payment services provider. The so-called "spoofing" cases. Scams originate outside the payments chain (online platforms, telcos etc.) and the payer is manipulated into duly authorizing a payment, which is impossible for a payment service provider to detect. Payment service providers should not be made liable for scams they cannot prevent, and the legislation should instead focus on measures to prevent and mitigate fraud. The most important aspect would be to ensure that parties that can take action electronic communications service providers have clear legal obligations to take all prevention measures possible, in the absence of which they should be liable for the financial loss of the payer. It is also important that the authorities ensure that providers of electronic communication services and other providers, e.g., of technical services, are actually cooperating to ensure that the proposal will work. Transaction monitoring and sharing of fraud data It is very positive that a legal basis is being provided for sharing of fraud-related data among payment service providers. It would however be important to clarify that all fraud-relevant data can be shared - not only IBANs and that such sharing is allowed from the first notification of fraud suspicion (currently the text requires two notifications from users). Furthermore, additional measures currently not included in the proposal are needed to combat fraud more effectively. Such measures should include the possibility of blocking and recovering funds for which payment service providers have legitimate grounds to suspect fraud.
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Finance Denmark Calls for 48-Month Open Finance Implementation Delay

1 Nov 2023
Topic — A proposal expanding financial data sharing to products like savings, investments, and insurance.
Message — The group requests extending the implementation timeline to 48 months and excluding derived data from the scope. They also advocate for a market-driven compensation model for data holders.12
Why — Narrowing the data scope would reduce technical complexity and the resource burden on financial institutions.3
Impact — Customers not using online banking may lose access to new data management tools and protections.4
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Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur)

10 Oct 2023 · EMIR

Meeting with Pia Ahrenkilde Hansen (Director-General Communication) and Sydbank A/S

11 Sept 2023 · communication priorities and upcoming State of the Union speech

Response to Establishing the digital euro

6 Sept 2023

It is imperative for the stability and resilience of the European financial system that careful analysis and consideration is made before any decision is taken to issue a digital euro. A digital euro must benefit the society as a whole, adding value to both individuals and businesses. An issuance requires therefore a strong business case. It needs to remedy a deficiency or meet demands that are not already covered by private payment solutions. The European payments market is overall well-functioning and effective with a wide range of means to make payments. The last building block adding to efficiency is the new instant payments regulation that already broadly achieves what the digital euro is trying to cover. Financial inclusion is not a widespread problem within the eurozone, but digital inclusion might be, as a wide range of individuals in certain regions lack digital skills. A digital euro cannot remedy that. Citizens in non-euro countries who visit a euro-country can gain access to the digital euro for use in the euro area (tourists etc.). The regulation contains no further provisions for, when visitors from non-euro countries can access the digital euro, as well as under what conditions the option to use or store the digital euro is available. We recommend that the upcoming work ensures that the regulation clarifies visitors access to and possession of digital euros and ensures that the regulation only enables visitors use of the digital euro in the euro area. The use of the digital euro in non-euro countries could potentially affect countries' financial and monetary stability. We therefore welcome that such use presupposes an active request from the Member State in question as well as an agreement between the Member State's central bank and ECB.
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Finance Denmark urges ESG rating and credit rating alignment

1 Sept 2023
Topic — This consultation aims to improve the transparency and reliability of ESG rating providers.
Message — The regulation of ESG ratings must be symmetrical with the regulation of traditional credit rating agencies. Providers of ESG data should also be covered by the proposal to improve transparency. Rating providers should be required to have a physical presence within the EU.123
Why — Financial institutions would benefit from more predictable, high-quality data for investment decisions.45
Impact — Non-EU providers would lose their current exemption from strict transparency and disclosure requirements.67
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

30 Aug 2023

The attached comments have been prepared by Finance Denmark as a reaction to the European Commissions proposal to review the EU crisis management and deposit insurance (CMDI) framework.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

30 Aug 2023

The attached comments have been prepared by Finance Denmark as a reaction to the European Commissions proposal to review the EU crisis management and deposit insurance (CMDI) framework.
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Finance Denmark urges mandatory reporting for financial sector data

6 Jul 2023
Topic — The European Commission is establishing standards for corporate sustainability reporting within the European Union.
Message — Finance Denmark recommends reintroducing mandatory disclosure requirements for data needed by the financial sector. They also request limiting quantitative metrics to own operations until value chain guidance is established.12
Why — This ensures banks have the reliable data needed to comply with their own reporting rules.3
Impact — Companies would lose administrative relief by having to report data they consider irrelevant for banks.4
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Meeting with Mairead McGuinness (Commissioner) and

28 Mar 2023 · Round-Table on Digital Euro (with EVP Dombrovskis and DG FISMA)

Response to Facilitating small and medium sized enterprises’ access to capital

24 Mar 2023

Feedback from Finance Denmark to consultation on Listing Act.
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Response to Facilitating small and medium sized enterprises’ access to capital

24 Mar 2023

Please see attached file for Finance Denmark's response to the EC consultation regarding CMU Listing Act - MiFID II.
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Response to Facilitating small and medium sized enterprises’ access to capital

24 Mar 2023

Please see attached file for Finance Denmark's response to the EC consultation regarding the CMU Listing Act - prospectus regulation and market abuse regulation.
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Finance Denmark calls for aligned EU sustainable finance rules

13 Mar 2023
Topic — The 2023 Strategic Foresight Report focuses on achieving EU sustainability and economic autonomy.
Message — The organization wants to consolidate existing rules to address horizontal challenges like data quality. They suggest exempting financial firms from standard corporate due diligence requirements.12
Why — Aligned rules would lower compliance costs and simplify the process of raising capital.3
Impact — National authorities lose power to set local rules as industry seeks uniform implementation.4
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

1 Feb 2023 · General economic outlook for EU and Denmark

Response to Instant Payments

22 Dec 2022

Se attached file.
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Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and AMUNDI AM and Deutsche Pfandbriefbank AG

28 Oct 2022 · CRR3 (staff)

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and European Banking Federation and

21 Oct 2022 · digital euro

Response to Open finance framework

1 Aug 2022

On behalf of Finance Denmark we welcomes the European Commission initiative to enable data sharing and third-party access in the financial sector. Please find our comments attached
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Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur) and Schneider Electric and European Building Automation and Controls Association

22 Jun 2022 · Energy Performance of Buildings Directive

Meeting with Emil Radev (Member of the European Parliament, Rapporteur) and Finanssiala ry - Finance Finland

18 May 2022 · AML

Meeting with Othmar Karas (Member of the European Parliament, Shadow rapporteur) and Finanssiala ry - Finance Finland and Finance Sweden

18 May 2022 · Reform der EU-Bankenregulierung (CRR3/CRD6)

Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur) and Finanssiala ry - Finance Finland and

22 Apr 2022 · AMLR

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

5 Apr 2022 · EU Banking Package 2021

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Improvements in energy efficiency of the building stock play an important role in the green transition and decarbonisation in the EU. There is a need to promote energy improvements of existing homes and ensure that new homes are suffi-ciently energy efficient. We generally support measures and initiatives that con-tribute to cost-effective energy efficiency and reduce emissions from buildings. With the proposal for the revision of the Building Directive member states must ensure that all residential properties in 2030 have at least an energy perfor-mance certificate (EPC) classified as F and in 2033 at least an EPC classified as E. This means that all properties with energy label G – that according to the pro-posal must amount to the 15 percent least energy efficient homes – must be en-ergy renovated or demolished by 2030, and correspondingly for properties with an EPC label F in 2033. The proposal has far-reaching consequences that raises several issues. Not least how the national authorities will ensure that all properties live up to the minimum standards, and who is responsible for this. The proposal can potentially have sig-nificant financial consequences for many homeowners. The proposal´s effect on other areas must also be analysed e.g. the financial legislation requires that the financial capacity of borrowers is taken into account when loans are granted, and the proposed recast of the directive can have large impact on the econo-my of borrowers. Hence it should already before a home is purchased be as-sessed if the potential homeowner is able to finance the energy renovations re-quired in the future. The need for both renovation work and/or demolition work for a large share of the homes and buildings in the EU can potentially cost billions of euros, and there is a risk that the cost is imposed on homeowners. It is important to support vul-nerable customers and households when energy efficiency requirements are tightened. For many homes the costs of energy renovations are higher than the value of the home, and hence the energy renovations are not economically profitable - e.g., if the building parts to be replaced are not yet worn out. There-fore, it could be the case that some homes become unsellable, and homeown-ers can become insolvent if they are forced to carry out renovations that are not economically profitable. Homeowners in areas where there is a large proportion of homes with a low EPC and where renovations are not automatically matched by price increases can be affected by the proposal. There may also be many homes where the eco-nomically profitable is the demolition and reconstruction of new buildings, but this may have negative climate consequences due to the significant green-house gas emissions that follows with the construction of buildings. The consequences will most likely impact the market early, e.g., before a pro-posal is even adopted, and it will be reflected in price formation, property valua-tions, etc. Thus, the proposal can have immediate and significant financial con-sequences for homeowners with the relevant EPC’s (F and G). Also, in Denmark, mortgage loans typically have up to 30 year credit commitments. If the value of loans in the credit book to homes with the lowest EPC’s decline it can have a considerable effect on the mortgage credit industry as well as investors holding the underlying bonds. In the Danish mortgage system loans must remain in the cover pool, they cannot be removed as is typically the case in universal bank models. Care must be taken that the high quality of covered bonds is not im-pacted by the proposal. The recast of the Energy Performance of Buildings Directive has an impact on the Taxonomy Regulation, including the technical screening criteria for economic activities that are in line with the environmental objectives. It should be ensured that there is compliance between the Directive and the EU-Taxonomy's criteria for “green” property renovations.
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Response to Amendments to certain Directives regulating public financial and non-financial disclosure in order to establish the ESAP

29 Mar 2022

General position Finance Denmark sees an advantage in gathering information that EU companies already today are required to disclose publicly into one single access point allowing investors, lenders etc. easy access to standardized, digital, machine-readable data. Against this backdrop, we are overall positive towards the proposal, provided and as anticipated by the EU Commission, that the administrative tasks concerning collection, validation, and submission of data to ESAP will rest solely with the EU- and national collection bodies. Furthermore, the costs incurred, and resources consumed by the authorities must neither directly nor indirectly be passed on to the reporting companies. If this crucial precondition is not met and the reporting EU companies face additional significant burdens and costs, we can no longer support establishing the proposed broad-scoped ESAP. In this case, we call instead for a narrow-scoped ESG database/access point giving investors, lenders etc. the urgently needed sustainability/ESG data from the companies. Attention points We would like to point out below further attention points which are important for our support to the ESAP proposal: • ESG-/sustainability information shall have highest priority and be accessible on ESAP as soon as they are reported by the companies. • Further phasing of directives and regulations to include into ESAP on basis of need for users. We call for a “start small, think big approach”. • Not all disclosures are suitable for incorporation into ESAP. For instance, reporting not based on common EU templates but rather on different national templates taking local specificities into account should not be included in ESAP. Please see example below. • ESAP must not lead to new reporting obligations for companies in scope for the mandatory reporting. • Existing national and European reporting channels and collection bodies shall be used as far as possible. • Application of a file only once principle for the companies shall apply – duplication of reporting tasks must be avoided. • Strong focus on minimizing the burden on reporting companies through-out the ESAP development process must be kept, not least regarding ESMA’s development of formats, technical requirements and licensing costs. • Access to data should be made free regardless of the volume, especially when needed for regulatory compliance. Example of disclosures based on national templates As regards the covered bond directive (EU/2019/2162) we do not support including the required cover pool reports into ESAP. They are not based on EU templates rather on different national templates taking local specificities into account and therefore not suitable for a standardised EU ESAP solution. This type of issue will most likely also be relevant for other directives and regulations where local rather than EU templates apply.
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Response to Amendments to certain Regulations regulating public financial & non-financial disclosure in order to establish the ESA

29 Mar 2022

General position Finance Denmark sees an advantage in gathering information that EU companies already today are required to disclose publicly into one single access point allowing investors, lenders etc. easy access to standardized, digital, machine-readable data. Against this backdrop, we are overall positive towards the proposal, provided and as anticipated by the EU Commission, that the administrative tasks concerning collection, validation, and submission of data to ESAP will rest solely with the EU- and national collection bodies. Furthermore, the costs incurred, and resources consumed by the authorities must neither directly nor indirectly be passed on to the reporting companies. If this crucial precondition is not met and the reporting EU companies face additional significant burdens and costs, we can no longer support establishing the proposed broad-scoped ESAP. In this case, we call instead for a narrow-scoped ESG database/access point giving investors, lenders etc. the urgently needed sustainability/ESG data from the companies. Attention points We would like to point out below further attention points which are important for our support to the ESAP proposal: • ESG-/sustainability information shall have highest priority and be accessible on ESAP as soon as they are reported by the companies. • Further phasing of directives and regulations to include into ESAP on basis of need for users. We call for a “start small, think big approach”. • Not all disclosures are suitable for incorporation into ESAP. For instance, reporting not based on common EU templates but rather on different national templates taking local specificities into account should not be included in ESAP. Please see example below. • ESAP must not lead to new reporting obligations for companies in scope for the mandatory reporting. • Existing national and European reporting channels and collection bodies shall be used as far as possible. • Application of a file only once principle for the companies shall apply – duplication of reporting tasks must be avoided. • Strong focus on minimizing the burden on reporting companies through-out the ESAP development process must be kept, not least regarding ESMA’s development of formats, technical requirements and licensing costs. • Access to data should be made free regardless of the volume, especially when needed for regulatory compliance. Example of disclosures based on national templates As regards the covered bond directive (EU/2019/2162) we do not support including the required cover pool reports into ESAP. They are not based on EU templates rather on different national templates taking local specificities into account and therefore not suitable for a standardised EU ESAP solution. This type of issue will most likely also be relevant for other directives and regulations where local rather than EU templates apply.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

29 Mar 2022

General position Finance Denmark sees an advantage in gathering information that EU companies already today are required to disclose publicly into one single access point allowing investors, lenders etc. easy access to standardized, digital, machine-readable data. Against this backdrop, we are overall positive towards the proposal, provided and as anticipated by the EU Commission, that the administrative tasks concerning collection, validation, and submission of data to ESAP will rest solely with the EU- and national collection bodies. Furthermore, the costs incurred, and resources consumed by the authorities must neither directly nor indirectly be passed on to the reporting companies. If this crucial precondition is not met and the reporting EU companies face additional significant burdens and costs, we can no longer support establishing the proposed broad-scoped ESAP. In this case, we call instead for a narrow-scoped ESG database/access point giving investors, lenders etc. the urgently needed sustainability/ESG data from the companies. Attention points We would like to point out below further attention points which are important for our support to the ESAP proposal: • ESG-/sustainability information shall have highest priority and be accessible on ESAP as soon as they are reported by the companies. • Further phasing of directives and regulations to include into ESAP on basis of need for users. We call for a “start small, think big approach”. • Not all disclosures are suitable for incorporation into ESAP. For instance, reporting not based on common EU templates but rather on different national templates taking local specificities into account should not be included in ESAP. Please see example below. • ESAP must not lead to new reporting obligations for companies in scope for the mandatory reporting. • Existing national and European reporting channels and collection bodies shall be used as far as possible. • Application of a file only once principle for the companies shall apply – duplication of reporting tasks must be avoided. • Strong focus on minimizing the burden on reporting companies through-out the ESAP development process must be kept, not least regarding ESMA’s development of formats, technical requirements and licensing costs. • Access to data should be made free regardless of the volume, especially when needed for regulatory compliance. Example of disclosures based on national templates As regards the covered bond directive (EU/2019/2162) we do not support including the required cover pool reports into ESAP. They are not based on EU templates rather on different national templates taking local specificities into account and therefore not suitable for a standardised EU ESAP solution. This type of issue will most likely also be relevant for other directives and regulations where local rather than EU templates apply.
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Response to Review of the regulatory framework for investment firms and market operators (MiFID 2.1)

22 Mar 2022

To European Commission Please see attached file. Kind Regards Helle Søby Thygesen
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Meeting with Luis Garicano (Member of the European Parliament, Rapporteur) and Finanssiala ry - Finance Finland and Finance Sweden

3 Mar 2022 · Meeting with stakeholders

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and Deutsche Pfandbriefbank AG

2 Mar 2022 · CRR (staff)

Response to Mortgage credit – review of EU rules

25 Feb 2022

Taking up a mortgage to finance a home is a major decision for households, and the Mortgage Credit Directive (MCD) has played an important role in harmonizing the framework for consumers’ protection in the EU in this field. Despite the efforts of MCD to create a cross-border supply of mortgages, the market in the EU is still very national-based. This is overall due to legal and infrastructural differences as well as different product ranges, and not least to consumers’ preferences. The fact that there is little cross-border supply of mortgage loans does not imply that the mortgage markets are not competitive or do not serve consumers well on the national level. In Denmark, mortgage loans are funded by covered bonds, and match funding ensures market driven and low prices for the consumers. The Danish mortgage rates are among the lowest in the EU. It is crucial that the MCD, while ensuring that a high level of consumer protection is applied across the EU, can still accommodate well-functioning national mortgage markets that are to the advantage of consumers. We find that the review of the MCD should be targeted and focus on areas with significant developments since the adoption of the directive – in particular the digital agenda. The process of mortgage lending involves human intervention due to the complex nature of the product and consumer preferences. But digital innovation is also transforming the mortgage market, just as consumer expectations and preferences for digital solutions are changing. Several years will pass before the MCD review process has been concluded and potential new provisions have entered into force. Further digital transformation of the mortgage market will by then have taken place. It is essential that the directive does not hinder digital developments that can benefit consumers and industry alike. MCD introduced standardized information in the form of ESIS (European Standardised Information Sheet) for all consumers across the EU. While the intention to ensure comprehensive as well as comparable information was right, it is our view that ESIS has not worked as well as it could have. The amount of information provided and the prescriptive way in which it is presented and explained has resulted in information overload, which has made the document less relevant for the consumer. We would suggest simplifying ESIS to create a more meaningful tool for the consumer and allow for a digital format. This would make it better suited as a comparison tool across the European market. In Denmark, a one-pager was introduced in October 2021, but it is worth noting that this document has been specifically tailored for the Danish mortgage market. Creating a one-pager both relevant and meaningful for consumers across the EU with different national mortgage products could prove exceedingly difficult. We are concerned that the shortcomings of ESIS could be repeated and lead to information overload. We will instead argue that the information requirements in the MCD need to be streamlined to alleviate the information burden on consumers and improve the way in which information can be provided digitally. The financial sector plays a huge role in funding the green transition and contributing to sustainable growth. Several Danish mortgage banks are offering green mortgages and green bonds, matching consumers demand for green financial products. We support the support the uptake of green mortgages and find that new initiatives in this area must be coherent with existing legislative framework and market-based standards, as well as individual bank actions, that aims to promote and develop sustainable financing solutions. Considering the major advancements already going on, we do not see a need for prescriptive provisions in the MCD on green mortgages.
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Response to Alignment of EU rules on capital requirements to international standards (review processes)

16 Feb 2022

Finance Denmark welcomes the opportunity to comment on the Commission’s proposal for amending to the CRD. Governance issues: The proposal to make it mandatory for institutions to establish individual statements setting out the roles and duties of each member of the management body could have far reaching implications and would not be aligned with most jurisdictions in the EU where the management body is seen as a collective body. The introduction of this requirement should therefore be reconsidered. While ex ante fit & proper assessments entail the possibility for some advantages, including the avoidance of reputational risk for the candidates that are not approved, it also holds the risk of creating bottlenecks at the supervisory authorities hereby delaying the recruitment of new candidates for management and key functions. We would therefor prefer that ex post assessments are maintained with an opportunity for institutions to approach the authorities for a de facto ex ante assessment in high profiled cases. If a requirement of ex ante assessments should be introduced several issues should be considered, including the need for swift and effective case handling at the authority level. ESG risks: It is natural that there should be an increased focus on sustainability risks, and Finance Denmark supports the greater focus to managing ESG risks in the proposal. The financial sector is in the process of incorporating climate risks into risk management, etc. However, the wording of certain provisions especially the stated possibility of risks of misalignment “with the relevant Union policy objectives or broader transition trends towards a sustainable economy” leaves a very wide room for interpretation which should be avoided. Finance Denmark notes that the EBA, EIOPI and ESMA must develop guidelines ensuring consistency and common standards for stress tests of ESG, cf. CRD6 Article 100. However, it is also very important that the EBA and the ECB cooperate primarily to ensure uniform access to data for institutions in the euro area and outside the euro area. As ESG risks are very much risks materialized in the medium and long term, annual reporting for all institutions would be sufficient. It is positive that the EBA should take proportionality into account in determining the format for reporting. The EBA makes an assessment of any differences in risks on "green" and "significant harmful" activities before deciding on changing risk weights in pillar I. When advancing the analysis to mid-2023, it is important that sufficient resources in the EBA are allocated to the work. In addition, Finance Denmark notes that the preamble to CRD6 states that the systemic risk buffer can be used to manage climate risks if the authorities consider it an effective and proportionate instrument and the authorities are given the opportunity, by means of amendments to the Directive, to impose institutions an additional capital requirement in Pillar 2. The authorities thus have powers in this area before the EBA's evaluation is carried out. This should be taken into account when considering changing risk weights in Pillar 1. Pillar 2 and buffer requirements: We welcome the proposed amendments to the provisions on Pillar 2 capital requirements and capital buffers that specify that they should be reviewed to ensure that the calibration remains appropriate when an institution becomes bound by the output floor. These provisions should also apply for subsidiary institutions that are not (formally) bound by the output floor as the output floor only applies at top consolidated level in the banking group.
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Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

11 Feb 2022

Finance Denmark has submitted a joint response to the Commission’s consultation together with the Swedish Bankers’ Association and Finance Finland. In the proposal, the Commission has chosen an approach for the output floor that applies the floor also on capital requirements beyond the capital requirements agreed upon at international level. This can significantly increase the cost of bank financing for homeowners and businesses in Europe and especially the Nordic countries. The European Commission’s impact assessments estimate an overall average increase in the minimum capital requirements for European banks between 6,5 and 8 per cent. However, the increases are very unevenly distributed among regions. In general, lower-risk Nordic banks are much more affected than the EU average. These increases are not justified by risk concerns, and they can have significant unintended consequences, such as increased financing costs for institutions and a decline in lending to customers to the detriment of homeowners and business investment. The output floor is the main driver for these increases. The temporary adjustment of the output floor calculation for loans to unrated corporates and loans secured residential real estate to mitigate the effect of the output floor, as proposed by the Commission, will only have a limited value. The focus of regulators, rating agencies, investors and the management of institutions will be on the long-term situation of the institution, assuming the toughest regulatory scenario. A permanent more risk sensitive implementation of the output floor is therefore essential. In order to retain significant risk sensitivity a permanent adjustment to the output floor calculation should be extended to include loans secured by commercial real estate where very low loss rates can be documented. It is necessary to recognise the regulatory measures which have taken place in the EU while the Final Basel III standards were still negotiated and during the four years after its publication. The output floor in the Final Basel III standards was drafted to address undue variability and lack of comparability of risk weight between banks. These weaknesses have, however, been addressed and mitigated already with several European regulatory measures. We specifically refer to the ECB’s targeted Review of Internal models from 2016 to 2020 and the corresponding IRB Roadmap with new guidelines from the European Banking Authority, as well as new regulatory initiatives to address problems arising from a buildup of non-performing loans. While the proposed implementation of the output floor without permanent long-term adjustments is the most important issue to address, there are other elements in the Commission’s proposal where we see a need for adjustments. We have more detailed comments to the proposed legislation from the Commission in the following areas: • The output floor • Unrated corporates in the output floor calculation • Loans secured by real estate in the output floor calculation • Loans secured by real estate under the standardised approach for credit risk • Covered bond pools and unrated institutions • Trade finance • Commitments • Market risk • CVA risk • Equity– transitional arrangements and exposures to jointly owned service providers
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Finanssiala ry - Finance Finland and

9 Dec 2021 · Basel III

Response to EU Anti-money laundering supervisor

29 Nov 2021

Finance Denmark supports the Commission’s Anti-Money Laundering and Coun-tering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe and, as an important part of the new initiatives, the establishment of a new EU AML Authority (AMLA). We find harmonisation of the cross-border area crucial. However, we believe that it is important that it is clarified in advance which entities are to be covered by AMLA's supervision and in doing so concentrating its direct supervision on the riskiest institutions with cross-border activities in multiple member states as well as on the member states and areas where national supervision is insufficient or in-appropriate while respecting the specificities of national systems and enforcement set-ups. The identification of financial institutions under direct supervision should be based on harmonised, predefined and objective risk-based criteria. Such criteria should be in accordance with the European Supervisory Authority’s Risk-Based Supervi-sion Guidelines. The AMLA should complement and not undermine national ML/FT supervisors, and it is crucial that the division of powers and tasks between the AMLA and the national supervisor is very clear. Obliged entities must not be caught between opposing views from the different levels of supervisors. Obliged entities should also not face significant increases in additional workloads and costs because of the establishing of an EU AML supervisor (e.g., dual reporting must be avoided). To ensure and support a level playing field and in continuance of the risk-based approach, the scope of the AMLA should be extended to include the non-financial sector. Furthermore, as a general remark, we find that the specified supervisory re-sponses in the AMLA regulation should not exceed the supervisory responses that national supervisors may apply under art. 40 and 41 of the AML Directive. Moreover, the supervisory powers must be clearly defined including the reach and scope of the powers and whether these supervisory powers in any case - under art. 30 - can be applied on non-selected obliged entities. Similarly, it should be clearly defined in which significant cases the AMLA can take the place of a national authority on the supervision of a non-selected obliged entity, and how the Commission's approval procedure will work in the event of such a query. We also find a need to clarify the mandate of AMLA regarding supervision of sanctions compliance. Sanctions are mentioned in both the proposed AML Regulation and the AML directive but is not included in the mandate of AMLA. Moreover, an impact assessment as well as risk factors and risk variables as regards sanctions are lacking from the proposals. Regarding the proposed cost allocation for AMLA, according to which a quarter of the costs of AMLA are covered by the EU’s general budget and three quarters are covered by companies under supervision, we propose an adjustment, so that the EU's general budget covers a higher fraction of the costs corresponding to the general tasks that AMLA must perform, while only costs for direct and in-direct supervision must be borne by companies subject to these. At the same time, it should be considered nationally that a number of tasks in connection with supervision and regulation would be handled at the EU level, hence, there should be a corresponding reduction in the payment to the national supervision. Finally, it is important to emphasise that better supervision by itself will not stop financial crime. We need both European and national supervision to properly enforce the AML legislation, but without stronger public-private cooperation and enhanced possibilities for information sharing, financial criminals will continue to exploit the European financial system. Please find our specific remarks on the proposal attached.
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Response to Revision of EU rules on Anti-Money Laundering (recast of a former instrument)

29 Nov 2021

Finance Denmark supports the Commission’s Anti-Money Laundering and Coun-tering the Financing of Terrorism Package which aims to strengthening the financial system against money laundering and terrorist financing in the EU. It is very important with a level playing field between all covered sectors and whilst the travel rule and subsequently proposed updates to the Regulation might prove difficult and could take some time to implement within the cryptocurrency market, this is welcome change bringing cryptocurrencies up to the standard of the wire transfer regulations and stepping up the AML/CTF compliance. In addition, Finance Denmark believes that extending the rules on information accompanying wire transfers to virtual asset service providers and crypto-to-crypto transactions has the potential to improve the traceability of transactions and strengthen the prevention of financial crime. However, difficulties may arise in applying all rules on wire transfers to crypto transfers. This is due to some of the specificities inherent to virtual assets such as the fundamentally decentralised nature of the DLT technology they are based on, which also excludes the need for intermediaries
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Response to Revision of EU rules on Anti-Money Laundering (recast)

18 Nov 2021

Finance Denmark thanks the Commission for the opportunity to provide feedback on the proposal. Finance Denmark supports the EU Commission’s Anti-money laundering and countering the financing of terrorism legislative package. We acknowledge and support the importance of establishing an effective and cooperative AML/CFT environment within the EU which requires the combined efforts of obliged entities, competent authorities, FIUs, law enforcement and the new AMLA. The new AML/CFT Directive (AMLD6) should provide the appropriate institutional framework for enhancing and improving the efforts of all parties in-volved. Finance Denmark supports the strengthening of the registers of beneficial owner-ship. We believe that the registers serve an important purpose, which is why we also believe that the registers should be given a status - through a verification of the information - so that they can be used to a greater extent and obliged enti-ties should be allowed to rely on the data collected from the registers.
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Response to Revision of EU rules on Anti-Money Laundering (new instrument)

18 Nov 2021

Finance Denmark thanks the Commission on the opportunity to provide feedback on the Commission's proposal for a regulation on preventing money laundering and terrorist financing. Finance Denmark supports the Commission’s Anti-money laundering and coun-tering the financing of terrorism legislative package and a new and revised reg-ulatory framework and supervision in the EU, and we strongly agree that in-creased harmonisation both in the regulation and in the supervision will strength-en the joint efforts in the area. Furthermore, we value the increased coordination between authorities and the focus on generally ensuring a level playing field in in the AML-framework. Finance Denmark finds it very positive that the majority of the directive will be transferred to a directly applicable regulation to ensure the harmonisation of the rules across the EU. A higher degree of detail and clarity i.e., in the rules on cus-tomer due diligence (CDD) and beneficial ownership, will ensure a more uniform approach in the EU, which will benefit both the obliged entities and the custom-ers. However, it is important to supplement this with an operational guidance for the rules and maintaining the risk-based approach. In this context Finance Den-mark would like to highlight that the creation of a true single rulebooks precludes additional national rules and that the possibility to uphold such rules should be limited to the furthest extend possible. A high priority area for Finance Danmark is the opportunity for increased infor-mation sharing and public-private cooperation. The ability to share data is an important tool in fighting money laundering and financing of terrorism as combined data sources give a better basis to detect more criminals – and networks of criminal transactions - as well as detecting criminals at an earlier stage, more sound and substantiated reports to the author-ities on suspected money laundering and financing of terrorism and better se-curement of evidence. However, the Commission's proposal does neither provide a clear basis for in-formation sharing and increased sectoral cooperation – nor a basis for public private partnerships. We believe that it is crucial and necessary to establish a clear legal basis for information sharing to strengthen the financial system against money laundering and terrorist financing. Another important focus for Finance Denmark is the rules on governance and the compliance functions. We see great value in harmonising the rules in this ar-ea – especially for banks’ operation cross border – however, it is important that provisions on governance in the AML-area can be implemented within different member state’s national company law and organisational structures. Additional-ly, we see a need for the rules on the compliance functions to be clarified in re-lation to tasks and responsibilities. Finally, Finance Denmark would like to highlight the importance of not only main-taining but also strengthening a level playing field between the relevant sectors and technologies not only for competitive reasons but also to avoid that crimi-nals are able to circumvent anti-money laundering and terrorist financing de-fences of obliged entities by routing their activities to less regulated sectors and technologies. Finance Denmark has attached a PDF-file with additional specific remarks.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Finanssiala ry - Finance Finland and

5 Nov 2021 · MiFID/MiFIR

Response to Quick fix to the PRIIPs Regulation

9 Sept 2021

A 12-MONTH IMPLEMENTATION PERIOD IS NECESSARY TO IMPLEMENT THE JUST PUB-LISHED PROPOSAL BY THE EUROPEAN COMMISSION FOR A REVISED RTS We welcome the European Commission’s initiative to extend the “transitional arrangement” for UCITS and for the AIFs offered to retail investors, when the members state applies rules on the format and content of the key information document as laid down in Articles 78 to 81 of the UCITS IV Directive. The revised Regulatory Technical Standards (RTS) was finally published by the Eu-ropean Commission two days before the deadline of this consultation. Assuming that none of the co-legislators object to the revised RTS within their three months right of doing so from the publication date and that the revised RTS are finalized and published in the EU Official Journal sometime during December 2022 – at the very latest, the industry will only be left with only six months to implement the new rules. We would therefor like to urge the Commission to ensure that the in-dustry has sufficient time to implement the revised RTS by allowing a reasonable twelve months to implement the new rules by 31 December 2022. A six-month extension is not enough time as the revised RTS has just been published by the Commission two days ago and are yet not finalized as the co-legislators still have three months to object to the revised RTS, which happened with RTS in 2016. The European Commission proposed its amendments to the Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation and the Undertakings for Collective Investment in Transferable Securities (UCITS) Directive in July. However, in contrast to earlier plans, the adoption of the revised RTS amending Commission Delegated Regulation (EU) 2017/653 was postponed. The delayed adoption of the revised RTS limits the implementation period for the industry, leaving both PRIIPs manufacturers and distributors with a short period of time to implement the revised RTS, when it is finally published in the EU Official Journal. A 12-month implementation period is the bare minimum required for a number of reasons: • The number of KIDs for UCITS and AIFs that need to be produced: A PRIIP KID must be produced for each fund’s share class that is available to retail investors. This typically means producing thousands of KIDs for a medium-sized asset manager. • Data sources: Producing the PRIIP KID requires a huge amount of data sources (some of which are very expensive) and the revised RTS make changes to the underlying calculation and presentation models. New data requirements must be identified, properly sourced and back tested to ensure flawless disclosures. • Education of advisors: Distributors need time to educate their advisors, so they are familiar with the differences between the UICTS KIID and PRIIPs KID for UCITS. They must be able to inform and explain to retail investors the difference and how to read and understand a PRIIPs KID for UCITS. We would also like to use the opportunity to draw the Commission’s attention to the issues concerning the proposed amendments to Article 78 I in the UCITS Directive, when the transitional arrangement for the UCITS ends. We find it very unfortunate that the European Commission’s proposal does not repeal the obligation to provide a UCITS KIID completely, when the transitional arrangement for UCITS ends as professional investors has no need for a UCITS KIID.
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Response to Quick Fix to the UCITS Directive

9 Sept 2021

We welcome the European Commission’s initiative to solve the issues that will arise when the UCITS exemption in the PRIIPs regulation ends. However, an amendment to the UCITS directive considering PRIIPs KID as satisfying the re-quirements applicable to the key information document required by UCITS di-rective is insufficient and administrative burdensome for the industry. The obliga-tion to provide a UCITS KIID needs to be repealed completely when the transi-tional arrangement for UCITS ends. We agree with the statement in the proposed preamble 6 that the “key infor-mation” required by article 78 of directive 2009/65/EU and the “key information documents” required by Regulation (EU) No 1286/2014 cover essentially the same information requirements. Both documents are intended to provide retail investors with the necessary information. Professional investors are excluded from the scope of the PRIIPs regulation as they have different needs than retail investors. Professional investors receive much more detailed information, more frequently and tailored to their needs. For that reason alone, we see no need for a UCITS KIID, when the temporarily exemption ends. It seems unnecessary burdensome to ask the fund industry to produce both a UCITS KIID and PRIIPs KID for different investor types – especially bearing in mind that professional investors are unlikely to read the UCITS KIID. To maintain the UCITS KIID means that manufacturers must keep both systems and produce two different types of documents. The suggested wording of preamble 6 states that it should be avoided that retail investors in PRIIPs interested in acquiring units of UCITS would receive both a UCITS KIID and PRIIPs KID, which we fully support. A PRIIPs KID or UCITS KIID must be provided for each share class and not at the level of the sub fund. Meaning that there will be a PRIIPs KID produced for the share class marketed to retail inves-tors and a UCITS KIID produced for the share class marketed to professional in-vestors in the same sub fund. It should be noted that from a practical point of view there is the risk that retail investors will come across a UCITS KIID produced for the professional investors for a sub fund, that they wish to invest in. The result being a confused retail investor as the risk indicator and cost calculations are very different in the two documents. The PRIIPs Regulation clearly states that a KID must be produced when a PRIIP is made available to “retail investors” which excludes professional investors. If UCITS managers chose to switch to PRIIP KIDs for professional investors, the cur-rent wording of the UCITS Directive may require ongoing updates of the UCITS KIID throughout the lifetime of the UCITS even if it is not being used as a pre-disclosure document. We find it very unfortunate that the Commission’s proposal does not repeal the obligation to provide an UCITS KIID, when the transitional arrangement for UCITS ends. We therefor urge the Commission to repeal to obligation completely in-stead of the proposed amendments to reduce the obligation to produce a UCITS KIID when a PRIIPs KID is not produced. As a closing note, we would also like to draw the Commission’s attention to the challenges following the delay of the revised Regulatory Technical Standards (RTS) leaving the industry with a short time to implement the RTS, when it finally has been adopted and published in the EU Official Journal.
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Response to European Digital Identity (EUid)

1 Sept 2021

Extract of the full document in Annex: We welcome the intention to develop an EU digital ID scheme with an ambition to ensure a much greater use of digital authentication across the member states. Particularly, we note that this is supported by broadening the scope of the eIDAS regulation to also cover services offered by private companies. However, we wish to emphasise the importance of ensuring that the investment, which will be required to develop a digital ID scheme is balanced against the expected acceptance and usage of the solution by the European citizens, and investments made in existing national eID solutions. In addition to this, we strongly recommend that the general benefits for the individual member states, as well as individuals and businesses across the EU, are considered. To require private corporates to accept digital identity wallets for authentication purposes will require significant investment on behalf of financial institutions. Therefore, we prefer a solution based on ID switching which means that the eID is the identification tool for online onboarding, while authentication for financial services would be based on a digital identity in a format which the individual bank supports. Based on experience from our national solutions, we also hold the opinion that public-private collaboration will provide the best result for citizens. Purely public, centralised solutions might not fully satisfy the needs for businesses and consum-ers and could lead to a fragmented market with public solutions and separately developed private sector solutions.
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Response to Consumer Credit Agreement – review of EU rules

23 Aug 2021

Finans Danmark støtter en revision af forbrugerkreditdirektivet. Forbrugerne efterspørger i dag digitale løsninger, hvor lånetilbud skal kunne fremsendes og underskrives digitalt. Ønsker forbrugerne at indhente information eller sammenligne forskellige tilbud, foregår dette ofte på nettet fremfor på papir. Lovgiv-ningen bør naturligvis afspejle denne udvikling. De fleste forbrugere og pengein-stitutterne ønsker, at hele låneprocessen kan foretages digitalt. Dette bør det nye direktiv sikre Vi er enige i ønsket om en høj grad af forbrugerbeskyttelse. Kun herved sikrer vi tilfredse kunder. Selv om forbrugerne er blevet langt mere digitale, efterspørger de også rådgivning, både i forbindelse med låneoptag men også i de situationer, hvor det går mindre godt med deres privatøkonomi. Her står pengeinstitut-terne selvfølgelig til rådighed såvel digitalt som fysisk. Også i forhold til kreditværdighedsvurderinger skal vi sikre et højt fagligt niveau. Vi har noteret, at EU-Kommissionen har anført, at vurderingen skal foretages på baggrund af nød-vendige og proportionale informationer, hvilket vi er enige i. Hverken pengeinstituttet eller forbrugeren er tjent med, at en forbruger bliver overgældsat. Direktivteksten er dog meget vagt formuleret, så en præcisering ønskes således, at det bliver præciseret, hvilke oplysninger pengeinstituttet skal indhente, at der er et proportionalitetshensyn, og omfanget af de oplysninger forbrugerne selv leverer. I forhold til information til forbrugerne er vi enige i, at forbrugerne skal sikres til-strækkelig information til at kunne træffe valg på et oplyst grundlag. Derfor anerkender vi også, at EU-Kommissionen foreslår et forklæde – Standardiseret Europæisk Forbrugerkredit Oversigt, der nemt kan læses på en mobiltelefon eller anden bærbar enhed. Vi finder dog, at informationskravene bør genbesøges for at få afklaret, om der ikke kan laves en bedre lagdeling af de informationer, der skal gives. Som direktivforslaget er udformet nu, skal en kreditudbyder stille en række generelle oplysninger til rådighed på papirer eller varigt medium (det kan f.eks. være en hjemmeside). Herefter skal en forbruger, der optager en forbrugslån, have udleveret prækontraktuelle oplysninger i form af et skema – ESIS, der skal muliggøre en sammenligning. Dertil kommer et nyt ”forklæde” – Standardiserede Europæisk Forbrugerkredit Oversigt. Til sidst kommer selve låneaftalen. Finans Danmark opfordrer til, at der foretages en grundig analyse af, om det er hensigtsmæssigt med så meget forbrugerinformation. Det er vigtigt at undgå overinformation. Mange af de nye elementer i direktivforslaget kender vi allerede i Danmark. Vi har for eksempel allerede indført et loft over ÅOP og et omkostningsloft. Der er tale om et totalharmoniseringsdirektiv. Derfor finder vi, at det er stærkt konkurrenceforvridende, at det overlades til medlemslandene selv at beslutte, hvorle-des et loft over renter, ÅOP og omkostninger skal implementeres. Hermed opnår vi i værste fald 27 forskellige løsninger. Det sikrer ikke en ensartet forbrugerbeskyttelse eller letter forbrugernes sammenligningsmuligheder. For pengeinstitutter vil det betyde, at hvis de ønsker at tilbyde grænseoverskridende produkter, skal pengeinstituttet sætte sig ind i det enkelte medlemslands specifikke lovgivning. Det sikrer ikke et indre marked. Ligeledes vil det heller ikke være fremmende for det grundlæggende ønske om mobilitet. Vi skal derfor opfordre til, at man søger en højere grad af harmonisering/lige konkurrencevilkår. I forhold til forbrugernes mulighed for førtidig indfrielse af en kredit er Finans Danmark enig i, at dette altid skal være muligt for forbrugerne. Selvfølgelig skal forbrugerne ikke betale renter for den periode lånet ikke løber. Men det er af væsentlig betydning for sektoren, at der ikke i forbindelse med en førtidig indfrielse skal ske afkortning i allerede erlagte etableringsomkostninger. Det er sektorens honorar.
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Response to Preventing money laundering and terrorist financing – EU rules on public-private partnerships (PPPs)

20 Aug 2021

Preventing money laundering and terrorist financing – EU rules on public-private partnerships (PPPs) Finance Denmark supports the Commission anti-money laundering and countering the financing of terrorism legislative package. A high level of confidence in the financial system is vital not just for the financial sector, but for society too. Banks, together with the authorities, have a wide responsibility for mitigating the risk of money laundering and financing of terrorism. In our view, establishing a more effective AML/CTF framework in Europe will rely on especially: 1. increased information sharing and public-private cooperation on both a national and on a EU-level; 2. A single rulebook for AML/CFT compliance requirements; and 3. a strong and consistent supervision throughout EU. Sectoral cooperation and data sharing As it has become harder for the criminals to escape notice within the individual banks, they have evolved and taken advantage of the banks’ limited possibilities to share information and thereby use several bank accounts in several different banks, which make it easier for them to go undetected. More effective cooperation between the obliged entities is key to a stronger prevention of and fight against money laundering and financing of terrorism. In the current regulation, banks are - as the general rule – in most cases cut off from seeing where funds are distributed to besides information on the account number and the receiving bank. The ability to share data is an important tool in fighting money laundering and financing of terrorism as combined data sources give a better basis to detect more criminals as well as detecting criminals at an earlier stage, more sound and substantiated reports to the authorities on suspected money laundering and fi-nancing of terrorism and better securement of evidence. A clear legal basis for such information sharing should be established by a new article in the directive/regulation, which allows the establishment of joint agreements on data sharing as well as amendment to the existing Article 39 on prohibition of disclosure of information that will allow exchange of information within the purpose of the specific joint agreement on sharing data to better fight money laundering af terrorist financing. Public Private Partnerships We believe that the fight against money laundering and terrorist financing is best and most effectively achieved by working together, as the task lies both with the banks as the gatekeepers and with the authorities as the regulators and enforcements. Some Member States have already with good results established public-private partnerships (PPPs), where information on concrete cases of financial crime with respect of GDPR rules are shared between authorities and the private sector – e.g., The Netherland’s Transaction Monitoring Netherlands (TMNL) to jointly monitor collective transactions for more effective detection of criminal money flows and networks in addition to the banks’ individual monitoring and Sweden has launched an anti-money laundering initiative, SAMLIT, to join forces in the fight against money laundering and terrorist financing by collectively sharing information on methods, suspicious transaction patterns and new types of crime. In Denmark a proposal to establish a collaboration between the authorities and where obliged entities, including the banks, can participate is in consultation at the moment. In order to promote these partnerships, a way forward could be to incorporate a clear legal basis for such public-private information sharing in the AML regulatory framework.
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Response to Requirements for Artificial Intelligence

13 Jul 2021

Finance Denmark supports regulation of AI. It is important to provide a regulation that protects the customer, through which trust in AI can be build. Much of what the financial sector does, is fundamentally based on trust. Therefore, it is important that AI-solution now and in the future can be trusted through a sound and appropriate regulatory framework on AI. The proposal from the European Commission distinguishes between high and low risk. Finance Denmark recommends that a risk-based approach with several lev-els will be used instead. We support that the future supervision of the financial sectors use of artificial in-telligence is placed with the regulatory authorities that currently has the supervi-sory oversight of the financial sector Finance Denmark proposes that it will be possible to apply the same regulatory risk-based approach for artificial intelligence as the approach used in connec-tion to fintech.
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Response to Revision of Non-Financial Reporting Directive

22 Jun 2021

We are overall supportive of the ambitious proposal. It is now important to stay ambitious in the forthcoming political and standard development process. In particular this applies to the following areas: • consistency to requirements to the financial sector • expansion of scope to all large undertakings and all listed undertakings • mandatory standards for large undertakings • proportionate simplified standards for SMEs - mandatory for listed SMEs and optional for non-listed SMEs • standardization • digitization • assurance • time schedule. CONSISTENCY In our view the most crucial aspect of CSRD and the coming EFRAG-standards is to secure consistency with other EU requirements for the financial sector - both for investment and financing activities and not only in terms of content, but also in terms of timing and scope. The financial sector cannot make sustainable investment and finance decisions and subsequently report on the indirect effect of its activities without the necessary sustainability data from the non-financial undertakings. Thus, when it is not mandatory for a non-financial undertaking to give sustainability data, the financial sector shall not either be obliged to report on the investing in – and financing to this non-financial undertaking. Against this backdrop, we are concerned about the significant gaps illustrated in the attached time schedule based on the current draft regulations to the financial sector and the proposed CSRD. We call for a full alignment on content, scope, application data, reporting frequency, transition periods etc. allowing credit institutions and other financial institutions the necessary time to access, assess and make use of the sustainability data from the non-financial undertakings. FURTHER PHASED APPROACH If the political and/or standard development process seems to be delayed, we encourage the Commission to consider a further phased standard development process covering the urgent information needs of the financial sector first – i.e., information needs directly linked to the requirements in the disclosure-, taxonomy and capital requirement regulations etc. MATERIALITY AND PROPORTIONALITY PRINCIPLES ACROSS SECTORS We agree materiality and proportionality principles shall apply to small and me-dium-sized undertakings. These principles shall, however, apply across sectors, including to small and medium-sized credit institutions. Thus, article 40 of the current Accounting Directive, stating that all public interest entities (including all credit institutions) shall be considered large undertakings, shall not apply. Furthermore, two of three thresholds (balance sheet total and turnover) in the Accounting Directive for determining whether an undertaking is large, are not relevant for credit institutions due to their deposit and lending activities. On this basis, we propose using the threshold based on average number of employees of 250 in the Accounting Directive only – i.e., the thresholds based on balance sheet total and turnover shall not be applicable for credit institutions. The threshold based on number of employees corresponds to the threshold for non-financial companies and will in practice bring symmetry between the financial and non-financial sector. RETAIN PRESENTATION FLEXIBILITY We agree as well that sustainability information does not belong to a category of less relevant information and management shall focus on sustainability matters but find it important to retain the undertakings’ flexibility to tailor the reporting to their user groups to avoid information overload. In addition, a requirement to give the complete sustainability reporting in the management report will make it difficult/impossible to apply different assurance levels for different types of sustainability information. Against this background, we propose retaining the current Member State option. Please see attached time schedule and full comment letter.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

20 May 2021 · Basel 4 implementation

Response to Retail Investment Strategy

18 May 2021

Finance Denmark support the initiative of an EU Strategy for Retail Investors and suggest that the well-being of the investor is put at the center of the strategy. Consumer protection in the context of the CMU is about generating trust and transparency, whilst promoting a better investment and saving culture. Retail investors should be able to trust that the institutions handling their investments or advising them, do so in a cost-effective and professional manner so that all in-vestment considerations are best served. We find that the investor protection regulation is on the key elements fostering the long-term success of the CMU. Today investors are faced with three overall challenges: • A lack of comparability in similar products or services for investors • Very complex regulatory-driven advisory processes • Information overload, especially for simple retail investors The ultimate consequence of these challenges being that retail investors with-draw from capital markets countering the objective of the regulation and the CMU. In order to turn this around, investor protection must be at the center of policy efforts. This essential means that the distributors, such as banks, must be able to better match the consumer’s investor-preference with the right invest-ments and services. We find that in order to increase investor protection three main principles should guide the review of the existing legislation such as MiFID II, PRIIPs, UCITS, AIFMD and IDD: • Tailering information towards investor types and simplifying disclosures where relevant • Horisontal alignment between legislation to ensure transparency and comparability • Base future regulatory action on consumer testing Differences in EU legislations cause different information obligations, making it difficult for investors to make the right investment decisions. This is best ad-dressed by a horizontal approach to aligning relevant pieces of legislation. Retail investors are increasingly offered a wide range of different types of prod-ucts and through an increasing number of investment platforms and distribution channels. Different products and distribution channels are regulated by different legislative acts. As there is a lack of alignment between these legislative acts, investors are presented with different kinds of information, when considering sub-stitutable investment products. This makes it difficult and time-consuming for the investor to factually compare and understand different products. We strongly support a high level of investor protection. However, we see a strong need for a European effort to rethink how it is achieved. The main objective of investor protection should be to contribute to the financial well-being of the in-dividual investor.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

19 Mar 2021 · Basel III

Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Jan 2021

Finance Denmark welcomes the Commission's inception impact assessment regarding the establishment of a European Single Access Point (ESAP). Finance Denmark has three key messages for the proposed ESAP 1. Finance Denmark welcomes the establishment of a European Single Access Point. The first step and top priority should be to ensure access to ESG data. Therefore, the creation of an ESAP must in no way cause delay in the establishment of a single access point for ESG data. 2. To ensure real added value, establishing a single access point must go hand in hand with ensuring the availability of sustainability-related data, especially through reporting requirements that are fully aligned with the taxonomy’s technical screening criteria and the disclosure obligations and standards under the Regulation on sustainability-related disclosure. 3. The European Single Access Point for users must be supported by a single reporting channel for the issuing companies. Please find attached Finance Denmark's consultation response.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (SRMR review)

8 Dec 2020

General remarks to be added The number of Options and National Discretions (ONDs) included in the BRRD (including the BRRD2) implies significant uneven playing field for institutions in certain jurisdictions which also constitute barriers to the function of the internal EU single market. A significant reduction in the numbers of ONDs would contribute to a harmonized application of the BRRD across the EU and complete the idea of a common European crisis management regime without major national differences. Specific BRRD ONDs Art 45 b The option for Resolution Authorities (RA) to increase the subordination requirement for G-SIIs and top tier banks is applied with very significant differences across the EU, resulting in substantive uneven playing field and negative implications for the functioning of the internal single market. This significant issue could be solved by ensuring that the option for setting a higher subordination requirement will be applied only in instances where an institution has been either unwilling or incapable in removing substantial impediments for resolution as also outlined in the SRB MREL Policy and in particular the approach to the NCWO principle. Doing so would also be in line with the SRB interpretation and application of the SRMR as outlined in the MREL Policy 2020. This would significantly increase level playing field and entail positive implications for the function of the internal single market. Likewise, the option to reduce the subordination requirement for G-SIIs and top tier banks could also be further harmonised by specifically and explicitly referring to the NCWO principle as the primary reason/justification for reducing the subordination requirement. This would also follow the interpretation of SRB as outlined in the MREL Policy, and thus result in a more level playing field across the EU. Art 45 c The current application of the option for RAs to include a market confidence buffer in the recapitalisation amount across the EU implies that otherwise comparable institutions are imposed to significantly different MREL requirements with clear implications for level playing field. In order to enhance the level playing field and improve the functioning of the internal single market, the conditions allowing RAs to set a market confidence buffer should be further outlined with a view to significantly reduce the current substantive level of discretion. Correspondingly, these conditions for considering post-resolution balance sheet depletion when setting the recapitalisation amount could also be further harmonised. Otherwise, the option will be applied differently across the EU which would imply that otherwise comparable institutions risk facing significantly different requirements. This issue could be solved by amending the BRRD along the lines of the SRB interpretation and application of considering post-resolution balance sheet depletion, cf. the SRB MREL Policy 2020. Art 55 The current wording of the article requires that the party to the agreement or instrument creating the liability recognises that the liability may be subject to bail in etc. The BRRD, however, does not stipulate which agreements or instruments creating a liability are within the scope, thus leaving doubt as to whether it is necessary to include such a clause in all agreements meeting the requirements in article 55 (1, a-d), regardless of whether the bail-in of the agreement could in fact be used to absorb losses or recapitalize the institution. Art 71 a Currently, the article requires that a clause recognising the stay power of the resolution authorities should be included in all financial contracts. The term financial contracts are defined in the BRRD. However, we find that it would be more beneficial to state that this obligation should apply to critical financial contracts which are essential for the continuation of the institution in a resolution scenario.
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Response to Amendment to the LCR Delegated Regulation

24 Nov 2020

To the European Commission Response to the European Commission’s Consultation on amending the LCR Delegated Regulation Finance Denmark - representing the Danish issuers of covered bonds – one of the largest covered bonds jurisdictions globally – would like to thank the European Commission for the opportunity to respond to the consultation on amending the LCR Delegated Regulation to cater for covered bonds. The proposal from the European Commission contains amendments to the LCR Delegated Act to:  remove the overlap/double counting between the liquidity buffer in the Covered Bonds Directive (CBD) and the liquidity coverage requirement in the LCR Delegated Regulation and  align with Article 129 of the CRR and CBD. The proposal includes a significant narrowing by only letting CRR-compliant cov-ered bonds being eligible as Level 1, Level 2A and Level 2B assets. This should be avoided. The reference in the existing LCR to covered bonds meeting the re-quirements set out in UCITS 52,4 should in Finance Denmark’s opinion be replaced by reference to the CBD - however this seems not to be the case. The narrowing of eligible covered bonds is neither justified nor a prudent approach and will undermine the intention and the initial motivation of creating a European wide, harmonized Covered Bond definition for regulatory purposes. In the proposal the European Commission recognises it as prudentially sound that liquidity risks related to net outflows in a covered bond program can be fully covered by HQLA encumbered in the cover pool when solving the double counting issue. Finance Denmark appreciates and supports a solution along this line provided that: • It is ensured that in general encumbered HQLA in a cover pool can be deemed to be unencumbered in the LCR requirement up to the amount of net liquidity outflows (the LCR requirement) from the associated covered bond programmes – irrespective of the HQLA being part of the cover pool liquidity buffer or due to other regulatory coverage requirements. This means that deeming HQLA as unencumbered is not contingent on and capped by a cover pool liquidity buffer requirement. • It is explicitly stated that HQLA fulfilling other regulatory coverage require-ments can also be included when deeming HQLA unencumbered up to the amount of net liquidity outflows stemming from the associated covered bond programme. If the LCR net liquidity outflows stemming from the associated covered bond programme is larger than the CBD liquidity buffer requirement – and the access to deeming HQLA as unencumbered is contingent on the CBD liquidity buffer requirement - issuers will have an incentive to keep the HQLA covering cover pool liquidity risk outside the cover pool. We find this to be conflicting with the prudentially sound prospect of having the HQLA needed available in the cover pool. Furthermore, it should be clarified that all ‘non-mandatory overcollateralisation’ in covered bond programmes (according to article 411 (1)(6) in CRR2) is considered unencumbered. Finance Denmark has elaborated in detail in the attached annex and would be pleased to explain and discuss the details at an on-line meeting with the European Commission. Kind regards, Peter Jayaswal Executive Director, Property and Finance Direct: +45 3370 1281 Mail: pj@fida.dk
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Meeting with Peter Power (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

20 Nov 2020 · Discussion Implementation Basel III Europe

Response to Action Plan on the Capital Markets Union

31 Jul 2020

Finance Denmark welcomes the opportunity to comment on the Commission’s consultation on a roadmap for ‘A Capital Markets Union for people and businesses – new action plan’. Finance Denmark has also responded to the Commission’s recent consultation on the consultation on the CMU High Level Forums’ report. The economic repercussions of the current covid-19 pandemic only adds to the need for rebuilding and reallocating economic activi-ties across the EU in the medium and long term. A well-functioning CMU could significantly improve the potential as well as the speed for such a rebuilding of the EU economy, not least in the countries that are now hit the worst. Below, please find Finance Denmark's 6 priorities for a more relevant and well-functioning CMU underpinning the green transition and putting investors at the center 1. Ensure transparency and access to data, esp. on sustainability Proposal 1 The EU Commission should establish a digital EU-wide access point for data, with a key focus on covering the urgent need for standardized and comparable sustainability data, report-ed by companies under the revised Non-Financial Reporting Directive. 2. Foster long term investments for green projects and for retail investors Proposal 2: The investment fund regulatory framework (ELTIF and UCITS) needs to be reviewed to make the long-term sustainable investments accessible, attractive and safe for retail investors. 3. Put consumer protection and the well-being of the investor at the center Proposal 3: In the context of the MiFID II review, the opt-up criteria to the professional client category should be amended based on knowledge and experience. Introducing a new ‘qualified investor’ category could be introduced on a longer-term. Such a step should be backed by thorough consequence analysis and impact assessment. Proposal 4: Alignment of information requirements across MiFID II, IDD, PRIIPs, UCITS and AIFMD so that any given investor type receive for substitutable products or services regardless of which di-rective or regulation that regulate a product or service. Proposal 5: Regulatory changes should always be based on a thor-ough and in-depth consumer testing process and impact assessments. 4. Look into overcoming structural barriers for a true single market Proposal 6: The Commission should take steps to ensure a minimum harmonisation of targeted elements of core non-bank corporate in-solvency laws. The aim of such a harmonization should first and foremost be to ensure swift, effective and efficient insolvency proceedings in all Member States to the benefit Proposal 7: Develop a straightforward EU procedure for repayment of withholding taxes on dividends to investors. 5. Address the issue of potential market failure on the cost of market data Proposal 8: Ensure full regulatory scrutiny to ensure that market data fees and licensing practices are fair and reasonable. 6. Improve financial education Proposal 9: Support for the development of an EU-wide compe-tence framework. A more coordinated effort at Member state level to improve financial education should involve an active role of the financial services industry. Attached, please find an elaboration of our six priorities
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

31 Jul 2020

Finance Denmark welcomes the opportunity to comment on the Commission’s consultation on a roadmap for ‘A Capital Markets Union for people and businesses – new action plan’. Finance Denmark has also responded to the Commission’s recent consultation on the consultation on the CMU High Level Forums’ report. The economic repercussions of the current covid-19 pandemic only adds to the need for rebuilding and reallocating economic activi-ties across the EU in the medium and long term. A well-functioning CMU could significantly improve the potential as well as the speed for such a rebuilding of the EU economy, not least in the countries that are now hit the worst. Below, please find Finance Denmark's 6 priorities for a more relevant and well-functioning CMU underpinning the green transition and putting investors at the center 1. Ensure transparency and access to data, esp. on sustainability Proposal 1 The EU Commission should establish a digital EU-wide access point for data, with a key focus on covering the urgent need for standardized and comparable sustainability data, report-ed by companies under the revised Non-Financial Reporting Directive. 2. Foster long term investments for green projects and for retail investors Proposal 2: The investment fund regulatory framework (ELTIF and UCITS) needs to be reviewed to make the long-term sustainable investments accessible, attractive and safe for retail investors. 3. Put consumer protection and the well-being of the investor at the center Proposal 3: In the context of the MiFID II review, the opt-up criteria to the professional client category should be amended based on knowledge and experience. Introducing a new ‘qualified investor’ category could be introduced on a longer-term. Such a step should be backed by thorough consequence analysis and impact assessment. Proposal 4: Alignment of information requirements across MiFID II, IDD, PRIIPs, UCITS and AIFMD so that any given investor type receive for substitutable products or services regardless of which di-rective or regulation that regulate a product or service. Proposal 5: Regulatory changes should always be based on a thor-ough and in-depth consumer testing process and impact assessments. 4. Look into overcoming structural barriers for a true single market Proposal 6: The Commission should take steps to ensure a minimum harmonisation of targeted elements of core non-bank corporate in-solvency laws. The aim of such a harmonization should first and foremost be to ensure swift, effective and efficient insolvency proceedings in all Member States to the benefit Proposal 7: Develop a straightforward EU procedure for repayment of withholding taxes on dividends to investors. 5. Address the issue of potential market failure on the cost of market data Proposal 8: Ensure full regulatory scrutiny to ensure that market data fees and licensing practices are fair and reasonable. 6. Improve financial education Proposal 9: Support for the development of an EU-wide compe-tence framework. A more coordinated effort at Member state level to improve financial education should involve an active role of the financial services industry. Attached, please find an elaboration of our six priorities
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Response to Farm to Fork Strategy

16 Mar 2020

Finance Denmark supports the new Commission's focus on the climate and environmental challenges as expressed in the Commission's European Green Deal. The financial sector affects all parts of the economy and as such plays a central role in the transition to an environmentally sustainable society and economy. The members of Finance Denmark are all committed to this transition starting with the recommendations that were presented in the beginning of December 2019 by Finance Denmark's Sustainable Finance Forum on how the financial sector can contribute to this green transition. Finance Denmark is thus generally positive towards the Commission's European Green Deal including the Roadmap for the forthcoming Farm to Fork Strategy. The forthcoming strategy involves the national Strategic Plans and how to use the Common Agricultural Policy (CAP) to promote the sustainable transition of the agricultural sector, which we are positive about. Finance Denmark proposes that the Danish implementation of the strategic plan should ensure that as much as possible of the EU support is placed in Pillar 1. Eco-schemes are mandatory for the country, but voluntary for the farmer. Member States are obliged to reserve part of their direct payments (Pillar 1) to farmers participating in eco-schemes. We expect eco-schemes to motivate farmers and therefore promote sustainable development and transition in the agricultural sector. Hence, we believe that eco-schemes should be used as a tool instead of transfers of additional amounts from Pillar 1 to Pillar 2 - compared to the current situation. It is important that the incentive payment for eco-schemes is sufficient, which emphasizes the need to concentrate efforts on the application and use of eco-schemes instead of downscaling the amounts in Pillar 1. The new CAP moves focus from compliance rules to results. This leaves a larger part of the decisions about the implementation of the CAP requirements in the Strategic Plans to the individual Member States. It is positive that the CAP can be used more targeted nationally, e.g. to support the industry in the sustainable transition. At the same time, it is important to en-sure a level playing field across the Member States despite the different practices. That is, the different practices must not result in a re-nationalization of the CAP. This speaks in favor of expanding Pillar 1 rather than transferring additional amounts from Pillar 1 to Pillar 2 in the new CAP. Finance Denmark welcomes that supplementary support can be provided to young newly established farmers under the direct payments (Pillar 1) with a view to promoting generation change in the agricultural sector. If it is decided that the size of the individual payment entitlements should be lev-eled in Pillar 1, this must be introduced with reasonable transitional stages, as several farmers have adapted to a certain level of support, e.g. by entering into long-term leasing contracts. Since financing and administration of a farm is done with a long time horizon, we also support that farmers affected by leveling out individual payment entitlements are compensated using the full possible framework of coupled payments. Several measures are being introduced in which farmers must be included in schemes (voluntary or mandatory) that lead to a depreciation of value. It is important that the farmer is fully compensated for the depreciation. For a mortgage creditor who has provided a loan against security in land, a depreciation of the land value can mean that there is no longer adequate security behind the loan to the farmer. In these cases, it is necessary for the farmer to be able to reduce his loans corresponding to the depreciation. This requires that the farmer, upon entry into the scheme, receives a one-time compensation, which fully covers the actual depreciation of value, and the mortgage creditor must be con-sulted before a such compensation is released.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

3 Mar 2020 · Implementaion of Basel

Meeting with Jyrki Katainen (Vice-President) and Finanssiala ry - Finance Finland and

14 May 2019 · Basel Implementation

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finanssiala ry - Finance Finland and Finance Sweden

14 May 2019 · The finalization of Basel IV, and the European implementation of the new Basel requirements.

Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

Finance Denmark strongly supports the proposals of sustainable finance and we think The European Commission’s proposals overall are a positive step towards a sustainable economy. The Commission´s initiative is an important part of the steps to achieve the necessary funding for the transition to a low-carbon, resource-efficient and circular economy. We acknowledge that the financial sector has a key role to play in reaching those goals. We work actively with the SDG goals relevant for the financial sector and we also hope that we succeed with the ambition that the EU becomes a global leader in fighting climate change. We look forward to working in close cooperation with the Commission in implementing the proposals with our members in the future. We have some comments to the proposals as described in the attached file to make the proposals more useful for inves-tors and investment firms.
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Response to Initiative on an integrated covered bond framework

16 May 2018

Please see that attached response from Finance Denmark.
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

6 Mar 2018 · EMU and Banking Union

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

8 Nov 2017 · Banking Union and Capital Markets Union

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finanssiala ry - Finance Finland and Finance Sweden

8 Nov 2017 · Basel

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Związek Banków Polskich

31 Aug 2017 · PSD2

Response to Initiative on an integrated covered bond framework

7 Jul 2017

European Commission Feedback on the intended initiative on an integrated covered bond framework Finance Denmark represents the Danish issuers of covered bonds – one of the largest covered bonds jurisdictions globally. Finance Denmark supports the Commission’s ambition to further strengthen covered bonds as a core European funding tool for the real economy and encourage the announced legislative proposal for an EU-framework for covered bonds coming forward in Q1 2018. Given the potential impact to the Danish mortgage market, we appreciate the stated intentions of the Commission to create a more integrated covered bonds market in EU, without undermining the quality of existing covered bonds. Covered bond issuer models across the EU are not uniform. They have devel-oped in reflection of the regulatory, institutional and economic landscape of each Member State. Each covered bond issuer model is therefore deeply rooted in the specific economic and legal setting of Member States. Abandoning one covered bond issuer model in favor of another is likely to be a very costly and difficult process. As indicated by the Commission care should be taken to accommodate the different models and their differences. An initiative should be working with a bal-anced solution for harmonization, which builds on the strengths of existing na-tional regulations on covered bonds and gives room for different national imple-mentation, where it is appropriate, and based on the specialized national super-vision with its knowledge of each jurisdiction. We believe some of the particular strengths of the Danish covered bond model could inspire at an EU level. Unique-ly, the Danish model rests on being a specialized covered bond model, relying on not taking deposits and on an unusually high degree of transparency. Due to this, there are also no asset encumbrance concerns in the Danish model and any regulation to protect unsecured investors against encumbrance would be mis-placed. The characteristics of the Danish covered bond model have provided not only a high degree of investor confidence in the model, but also to high con-sumer appreciation of the model – as well as it underpinned financial stability during the crisis. Furthermore, when a credit crunch could have set in during the crisis, the rise in mortgage lending more than outweighed the decline in bank credit availability. It is important that a legislative initiative underpins the high quality of covered bonds as an asset class building on mortgages in real estate and ships, together with public lending and, thus, recognises that this might leave room for supple-menting initiatives like a European Secured Note with a broader asset base. This contributes to ensuring the very high quality of covered bonds compared to oth-er riskier types of funding and continues to provide cheap and transparent fund-ing to homeowners and businesses. The prudential measures in a covered bond framework should build on a risk-based approach. Furthermore, in order to create a solid foundation for economic growth, it is im-portant to ensure that a legislative initiative on covered bonds recognizes the universal banking model as well as specialized covered bonds models as the Danish mortgage model. At the same time a legislative initiative should be flexi-ble enough to distinguish between universal banks and specialized mortgage banks with respect to fulfilling the legislative requirements. We look forward to a continuous dialogue with the Commission on the upcoming legislative proposal on an integrated covered bond framework. Kind regards Ane Arnth Jensen Deputy CEO of Finance Denmark CEO of the Association of Danish Mortgage Banks
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

23 May 2017 · Financial Services

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

18 May 2016 · current issues in the banking sector

Meeting with Jonathan Hill (Commissioner)

4 Mar 2016 · Covered Bonds; CMU; Call for evidence; Proportionality

Meeting with Christina Holm Eiberg (Cabinet of Commissioner Margrethe Vestager)

15 Dec 2015 · Current EU Affairs

Meeting with Margrethe Vestager (Commissioner)

30 Oct 2015 · Financial sector developments

Meeting with Jonathan Faull (Director-General Financial Stability, Financial Services and Capital Markets Union)

3 Jun 2015 · Capital IV Directive, Denmark's possible joining the Banking Union, Capital Markets Union