Europaudvalget 2012-13
EUU Alm.del Bilag 513
Offentligt
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European Commission
DG Internal Market and Services (DG MARKT)
DG Economic and Financial Affairs (DG ECFIN)
Rue de Spa 2
1049 Brussels
Belgium
General comments
The Danish government would like to thank the European Commission
for the opportunity to contribute to the consultation. The Danish govern-
ment generally finds that it is still too early to fully assess the impact of
the European System of Financial Supervision (ESFS) with only three
years of experience. Furthermore, the experience has so far been gained
during a period of severe financial crisis, which has had a significant im-
pact on the functioning of the ESFS. Finally, the EBA regulation has al-
ready been revised on some points during the negotiations on the Single
Supervisory Mechanism (SSM). As such, the assessment of the ESFS
could preferably be postponed. However, there may be a need to adjust
the mandate of the ESRB with regard to recommendations in light of the
SSM.
On this note, the Danish government, however, finds that the impact of
the ESFS overall is positive. The ESFS has had important impact on the
financial system the last three years in ensuring a consistent level of regu-
lation and supervision in financial services, strengthening international
supervisory coordination and contributing to the mitigation of systemic
risks to financial stability in the Union.
The European Supervisory Authorities (ESAs)
MINISTRY OF BUSINESS AND
GROWTH
Slotsholmsgade 10-12
DK-1216 Copenhagen K
Tel.
Fax
+45 33 92 33 50
+45 33 12 37 78
CVR no. 10 09 24 85
[email protected]
www.evm.dk
Generally, the Danish government finds that the ESAs perform well
against their mandates. For instance, the ESAs have performed well in
drafting technical standards at a high professional level at the same time
as they were building up their organizational capacity. However, when
handling the massive volume of technical standards due in the coming
years, it will be crucial that the ESAs ensure efficient project manage-
ment, so that output from the ESAs is delivered in time to the Commis-
sion and other stakeholders. We consider this essential in order to pro-
mote the internal market for financial services.
Moreover, the Danish government finds that the ESAs have sufficient re-
sources to perform well on their present tasks. It is, however, important
that the ESAs prioritize their resources to keep focusing on key risks ra-
ther than making e.g. guidelines and recommendations on each and every
issue. This should also be reflected in the recruitment policies of the
ESAs, by putting more emphasis on recruiting people with supervisory
 EUU, Alm.del - 2012-13 - Bilag 513: Regeringens høringssvar til Kommissionens offentlige høring om det Europæiske System for Finansielt Tilsyn (ESFS).
experience and capabilities, as well as more emphasis on project man-
agement skills when employing staff, as this will be vital for the signifi-
cant coming work load.
In our view the composition and voting rules of the Board of Supervisors
and the Management Boards as approved by Council and Parliament in
the revised EBA-regulation will function well and there is an adequate
review clause contained in this regulation if major changes should occur
as to non-euro Member States joining the SSM. In that regard it could be
considered whether there is a need for aligning these back-stops on block-
voting also for ESMA and EIOPA with the revised EBA-regulation, since
EBA voting block created with the SSM could translate into EIOPA and
ESMA territories as well.
The European Systemic Risk Board (ESRB)
Since the establishment of the ESRB at the beginning of 2011 the ESRB
has mainly focused on systemic risks and vulnerabilities arising from and
in the aftermath of the financial crisis. That is, the ESRB has in particular
focused on banks’ funding and liquidity and issued recommendations
within these areas. This is understandable but it is important that ESRB
focus on the risk incurring in the medium and longer term instead of the
immediate problems and crisis management.
The role of the ESRB has demonstrated a number of challenges. We be-
lieve it is mainly due to the fact that the ESRB was established during the
financial crisis.
Looking forward, the Danish government finds that the ESRB has an im-
portant role to play in identifying systemic risks in the entire financial
sector including areas outside of the banking system and across financial
sectors. It is highly relevant for the ESRB to give timely input on macro-
prudential aspects of financial regulation as well as recommendations on
macroprudential measures and if necessary coordination of macropruden-
tial policy among EU all countries inside as well as outside the SSM.
One of the advantages of the ESRB is the cooperation between ECB, na-
tional central banks and supervisory authorities. The discussions at ESRB
meetings of systemic risks and vulnerabilities benefit from macro-
prudential aspects, in which the central banks are specialized, as well as
of the micro-prudential viewpoints provided by supervisory authorities. It
is, therefore, important to maintain this positive interchange between
macro- and micro-prudential aspects.
The Danish government
welcomes the ESRB’s initiatives with respect to
analysis of how macro-prudential instruments would work but we find
that this analysis should have been focused further upon at an earlier
stage to ensure a more forward-looking approach, rather than focus on
recommendation on current legislation.
 EUU, Alm.del - 2012-13 - Bilag 513: Regeringens høringssvar til Kommissionens offentlige høring om det Europæiske System for Finansielt Tilsyn (ESFS).
Finally, the Danish government finds that it is important to ensure that
Member States not participating in the Single Supervisory Mechanism
will continue to have equal influence in the ESRB compared with partici-
pating Member States.