2014年-IMF国际货币组织全球_Denmark_Crisis_Management_Bank_Resolution_and_Financial_Sector_Safety_Nets_Technical_Note_43页_1mb

Summary of Denmark's Financial Sector Assessment Program on Crisis Management, Bank Resolution, and Financial Sector Safety Nets

Core Content

This Technical Note provides an in-depth analysis of Denmark's crisis management, bank resolution, and financial sector safety nets frameworks, as part of the Financial Sector Assessment Program (FSAP) Update in 2014. It outlines the findings and recommendations made by the International Monetary Fund (IMF) staff, based on legal and policy documents, as well as discussions with Danish authorities and private sector representatives. The report emphasizes the importance of aligning with international best practices, such as the Bank Recovery and Resolution Directive (BRRD) and the Key Attributes of Effective Resolution Regimes for Financial Institutions.

Main Findings and Recommendations

1. Crisis Management and Bank Resolution Framework

• Prompt Response to Crisis: Denmark's authorities responded swiftly to the financial crisis, implementing substantial public support measures, including funding guarantees and capital injections, to stabilize the financial sector.
• Resolution Scheme Introduced: In 2010, a resolution regime with bail-in features was introduced to address the need for resolving distressed banks without relying heavily on public funds.
• Resolution Tools: The Danish resolution toolkit includes crisis containment measures, emergency liquidity assistance (ELA), and a resolution regime that allows for the transfer of assets and liabilities to the Financial Stability Company (FSC) or third-party acquirers.
• Recommendations:
  • Establish an Administrative Resolution Authority: A dedicated authority with a clear mandate, operational independence, robust governance, adequate resources, and legal protection should be created.
  • Enhance Early Intervention Mechanisms: Implement additional triggers for early entry into resolution and improve the preparation of resolution plans and resolvability assessments, especially for systemically important financial institutions (SIFIs).
  • Limit Legal Remedies to Monetary Compensation: Restrict judicial review to monetary compensation to streamline the resolution process.
  • Introduce Depositor Preference: Ensure that depositors receive preferential treatment in the event of bank failure.

2. Financial Sector Safety Nets

• Deposit Guarantee Scheme (DGS): The DGS is a key component of the safety net, providing guarantees to the FSC and ensuring depositor payouts in case of bank failure.
• Recommendations for Improvement:
  • Enhance Governance Arrangements: Improve the governance structure of the DGS to ensure better coordination and transparency.
  • Fortify Funding Mechanisms: Introduce a robust public backstop and remove mandatory offsetting.
  • Shorten Maximum Payout Periods: Reduce the time it takes to pay out deposits in case of bank failure.
  • Amend Creditor Hierarchy: Align the DGS with BRRD requirements by granting insured depositors preferential claims.

3. Cross-Border Coordination

• Regional Ties and Global Presence: Denmark's banking system has strong regional ties and hosts one of the designated global systemically important financial institutions (G-SIFI), Nordea.
• Coordination Framework: The current cross-border coordination framework includes Memoranda of Understanding (MOUs) and cooperation with regional peers to manage spillovers.
• Recommendations:
  • Continue Harmonization of Resolution Regimes: Pursue regional harmonization of resolution frameworks, including the application of bail-in requirements.
  • Formalize Foreign Resolution Actions: Introduce mechanisms to give effect to foreign resolution actions and enhance bilateral coordination.

4. Legal Protection and Institutional Roles

• Legal Framework: A solid legal basis is essential for the exchange of confidential information among agencies during crisis management.
• Institutional Roles:
  • DN (Danmarks Nationalbank): Provides ELA and facilitates credit extension.
  • DFSA (Danish Financial Supervisory Authority): Supervises financial institutions and initiates resolution.
  • FSC (Financial Stability Company): Resolves failing banks by acquiring assets and liabilities.
  • MoBG (Ministry of Business and Growth): Sets policy and provides mandates for DFSA.
  • DGS (Deposit Guarantee Scheme): Provides deposit guarantees and supports the FSC.
  • DCG (Danish Coordination Group): Coordinates crisis management efforts among key institutions.

5. Institutional Framework in Denmark

• Roles and Responsibilities:
  • DN is responsible for the payment system and grants ELA.
  • DFSA licenses, regulates, and supervises financial institutions and initiates resolution.
  • FSC resolves failing banks by acquiring assets and liabilities.
  • MoBG provides policy guidance and mandates for DFSA.
  • DGS ensures depositor payouts and supports the FSC.
  • DCG facilitates coordination among institutions during the crisis.

6. Timeline and Implementation

• Short-Term (within 18 months): Establish an administrative resolution authority, enhance the DGS, and limit judicial review to monetary compensation.
• Medium-Term (within 18 months to three years): Strengthen funding arrangements, conduct recurrent crisis simulations, and improve the resolution toolkit with early triggers and additional powers.

Key Information

• The Danish financial sector is large and interconnected, with Danske Bank Group being the dominant player.
• The sector faced significant stress during the global crisis, particularly due to liquidity issues and substantial losses.
• The resolution framework has been effective in minimizing public costs and transferring losses to private creditors.
• Legal and institutional reforms are ongoing to align with EU regulations and international standards.
• The DGS is a private self-governing institution with a mandate to support the FSC and ensure depositor payouts.
• The DCG serves as an effective coordination forum, though its role could be expanded to include crisis preparedness.

Conclusion

Denmark has made significant progress in strengthening its financial sector crisis management and resolution frameworks. Continued improvements are necessary to ensure the system remains resilient, efficient, and aligned with international best practices. The establishment of an administrative resolution authority, enhancement of the DGS, and improved cross-border coordination are critical steps to achieve this.